20210716IPC to Staff Supplemental 20.pdf

DONOVAN E. WALKER
Lead Counsel
[e-mail]

July 16, 2021

VIA ELECTRONIC MAIL

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-21-09
Idaho Power Company’s Application for Capacity Deficiency To Be Utilized
For Avoided Cost Calculations

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Supplemental Response
to the Third Production Requests of the Commission Staff in the above entitled matter.

Please handle the confidential information in accordance with the Protective
Agreement executed in this matter.

If you have any questions about the attached documents, please do not hesitate
to contact me.

Very truly yours,
Donovan E. Walker

DEW:cld
Enclosures
RECEIVED
2021July 16, PM 4:08
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUESTS OF THE COMMISSION STAFF - 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS.
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CASE NO. IPC-E-21-09

IDAHO POWER COMPANY’S
SUPPLEMENTAL RESPONSE
TO THE THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and
supplements its response to the Third Production Request of the Commission Staff to
Idaho Power Company dated June 15, 2021, herewith submits the following information:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUESTS OF THE COMMISSION STAFF - 2
REQUEST NO. 20: Please identify the amount of peak capacity that the
Company needs to acquire through the RFP broken down by the following:
a. Load Growth
b. Lack of external firm transmission capacity
c. Early exit date of Valmy Unit #2
SUPPLEMENTAL RESPONSE TO REQUEST NO. 20: The following
supplements Idaho Power’s response to this Request originally provided June 25, 2021.
The attached Excel file provides the differences in load forecast, market
transmission, and Effective Load Carrying Capability (ELCC) Methodology Changes
(affecting Demand Response, Wind and Solar) using the 2019 IRP as a starting point and
the April 2021 Valmy Exit Date Study as an endpoint. Changes to market transmission
assumptions and ELCC methodology updates are the primary drivers of the NOI.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

Respectfully submitted this 16th day of July 2021.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE THIRD PRODUCTION
REQUESTS OF THE COMMISSION STAFF - 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 16th day of July 2021, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY’S SUPPLEMENTAL
RESPONSE TO THE THIRD PRODUCTION REQUESTS OF THE COMMISSION
STAFF upon the following named parties by the method indicated below, and addressed
to the following:

Matt Hunter
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074

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Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702
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________________________________
Christy Davenport, Legal Assistant