20220211IPC to Idahydro 1.pdf

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DONOVAN E. WALKER
Lead Counsel
dwalker@ida hooower.com
February 11,2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 2O1-A
Boise, Idaho 83714
Re: Case No. IPC-E-21-O9
ldaho Power Company's Application for Capacity Deficiency To Be Utilized
ForAvoided Cost Calculations
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to IdaHydro's
First Set of lnterrogatories in the above entitled mafter. lf you have any questions about
the attached document, please do not hesitate to contact me.
Very truly yours,
Zdattu
Donovan E. Walker
DEW:cld
Enclosures
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMlSSlON
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACIW
DEFICIENCY TO BE UTILIZED FOR
AVOI DED COST CALCULATIONS.
CASE NO. |PC-E-21-09
IDAHO POWER COMPANY'S
RESPONSE TO IDAHYDRO'S FIRST
SET OF INTERROGATORIES
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COMES NOW ldaho Power Company ("!daho Powefl or "Company"), and in
response to ldahHydro's First Set of lnterrogatories to ldaho Power Company dated
January 21,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S FIRST
SET OF INTERROGATORIES TO IDAHO PO\A'ER COMPANY - 1
REQUEST NO. 1: When is orwill ldaho Power Company be capacity deficient?
RESPONSE TO IDAHYDRO'S REQUEST NO. 1: ldaho Power's 2021 lntegrated
Resource Plan filed December 30,2021, indicates a first capacity deficit in July 2023.
Additionally, on February 4,2022,ldaho Power filed a Motion and Amended Application
in docket !PC-E-21-09 "Application for Capacity Deficiency To Be Utilized For Avoided
Cost Calculations" which seeks to establish a first capacity deficiency of July 2023 for
purposes of PURPA avoided cost pricing.
The response to this Request is sponsored by Mark Annis, Regulatory Consultant,
ldaho Power Company.
Respectfully submitted this 11th day of February 2022.
fuzdalq-
DONOVAN E. WALKER
Attorney for ldaho Power Company
]DAHO PO\A'ER COMPANY'S RESPONSE TO IDAHYDRO'S FIRST
SET OF INTERROGATORIES TO IDAHO POVVER COMPANY - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11th day of February 2022,1 served a true and
correct copy of the within and foregoing ldaho Power Company's Response to ldahydro's
First Set of lnterrogatories upon the following named parties by the method indicated
below, and addressed to the following:
Dayn Hardie
Deputy Attorney Genera!
!daho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Terri Carlock
! PUC Staff Administrator
Po Box 83720
Boise, ldaho 83720-0074
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, lD 83701
Emailed to:
davn. hard [e-mail]
Emailed to:
terri.carlock@puc. idaho.qov
Emailed to:
peter@ richa rdsonadams. com
Emailed to:
tom. a rkoosh@a rkoosh.com
[e-mail]
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S FIRST
SET OF INTERROGATORIES TO IDAHO PO\A'ER COMPANY - 3