20220228IPC to ICIP 10.pdf

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An DACORP Company
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-, , -' -, : -:,.)i;',,f i.iSlOI,iDONOVAN E. WALKER
Lead Counsel
dwa lker@ida hooowe r.com
February 28,2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, ldaho 837'14
Case No. !PC-E-?1-O9
ldaho Power Company's Application for Capacity Deficiency To Be Utilized
For Avoided Cost Calculations
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to the Second
Production Request of the lndustrial Customers of ldaho Power in the above entitled
matter.
lf you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Re
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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]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO PO\A'ER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACIry
DEFICIENCY TO BE UTILIZED FOR
AVOI DED COST CALCULATIONS.
CASE NO. IPC-E-21-O9
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER
COMES NOW, ldaho Power Company ("ldaho Powe/' or'Company"), and in
response to the Second Production Request of the lndustrial Customers of ldaho Power
dated February 7,2022, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO PO\A'ER - 1
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REQUEST NO. 10: Please provide updated 'published' avoided cost rates
utilizing the SAR methodology for wind, solar and battery projects 100 kW or smaller and
all other types of QF projects 10 MW or smaller utilizing the firct deficit year contained in
the Company's Motion and Amended Application filed on February 4,2022 in this docket.
RESPONSE TO lClP'S REQUEST NO. 10: ldaho Power has not conducted the
requested analysis. Published Avoided Cost rates using the Surrogate Avoided Resource
methodology are calculated by the Staff of the ldaho Public Utilities Commission, not by
ldaho Power, and subsequently published on the Commission's website once approved.
This question is more properly addressed to Commission Staff and not ldaho Power
The response to this Request is sponsored by Mark Annis, Regulatory Consultant
of ldaho Power Company.
Respecttully submitted this 28h day ot February 2022
Mzdalq-
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCT]ON REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO PO\A/ER - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of February 2022,1 served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO
THE SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUTOMERS OF
IDAHO POWER upon the following named parties by the method indicated below, and
addressed to the following:
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 W. Bannock Street
Suite LP 103
Boise, lD 83701
Hand Delivered
U.S. Mai!
Overnight Mail_ FAXX Email:
davn.hardie@puc. idaho.qov
Hand Delivered
U.S. Mail
Overnight Mail_ FAXX Email:
peter@ rich a rdsonadams. com
q req@richa rdsonadams.com
Hand Delivered
U.S. Mail
Overnight Mail
_ FAXX Email:
tom.a rkoosh@a rkoosh. com
Erin. cecil@arkoosh. com
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3