20220321Staff to ICIP 1-3.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BAR NO. 9917
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Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPAII-Y'S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS
CASE NO.IPC.E-2I.09
COMMISSION STAF'F'S
RESPONSE TO THE X'IRST
PRODUCTTON REQUEST Or
INDUSTRIAL CUSTOMERS OF
IDAHO POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attorney General, responds as follows to Industrial Customers of Idaho
Power's First Production Request to Commission Staff.
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF INDUSTzuAL
CUSTOMERS OF IDAHO POWER
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I MARCH 2I,2022
STAFF WITNESS YAO YIN WILL BE ABLE TO AI\ISWER QUESTIONS
ABOUT OR SPONSOR THE ANSWERS TO REQUEST NOS. 1-3, BELOW.
REQUEST NO. 1: Please provide copies of all communications between the Idaho PUC
and Idaho Power Company regarding the Company's Application.
STAFF RESPONSE NO. 1: Please see Attachment A to these responses containing
copies of email correspondence between IPUC Staff and the Company regarding the Company's
Application. IPUC Staffand the Company have not had any correspondence regarding the
Amended Application.
REQUEST NO.2: Please provide copies of all responses (both formal and informal)
provided to any other party to this proceeding and that have not already been produced.
STAFF RESPONSE NO. 2: Except for these responses to the Industrial Customers of
Idaho Power, Staff has not provided any responses-formally and informally-to any other party
to this proceeding.
REQUEST NO.3: Please provide updated "published" avoided cost rates utilizing the
SAR methodology for wind, solar and baffery projects 100 kW or smaller and for all other types
of QF projects 10 MW or smaller utilizing the fust deficit year contained in Idaho Power's
Motion and Amended Application filed on February 4,2022, in this docket. According to Idaho
Power Company's response to ICIP Request No. 10, the requested rates are, "calculated by the
Staff of the Idaho Public Utilities Commission" and not Idaho Power Company.
STAFF RESPONSE NO.3: This Request asks for updated published avoided cost rates
"utilizing the first deficit year contained in Idaho Power's Motion and Amended Application
filed on February 4,2022." The Motion and Amended Application proposes a first capacity
deficit year or deficiency date of July 2023. Provided are the SAR methodology rates based on
the Company's proposal. Levelized avoided cost of capacity rates are provided for new energy
storage projects that come online in2022 or 2023. Staffwill provide additional online years
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF INDUSTRIAL
CUSTOMERS OF IDAHO POWER 2 MARCH 2I,2022
after the SAR model has been fully revised and updated with the authorized first capacity deficit
date at the conclusion of this case. Please see Attachment B for Published Avoided Cost Rates
forNew Contracts, and Attachment C for Published Avoided Cost Rates for Renewal Contracts.
DATED at Boise, Idatro, this Ltt day of March2022
Attomey General
i:umisc/ipce2 1.9 Staff l"r Response to ICIP
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF INDUSTRIAL
CUSTOMERS OF IDAHO POWER J MARCH 21,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF MARCH 2022,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF INDUSTRTAL CUSTOMERS OF IDAHO POWER,
IN CASE NO. IPC-E-21-09, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL : [e-mail]
[e-mail]
PETER J zuCHARDSON
RICHARDSON ADAMS PLLC
5I5 N 27TH ST
BOISE ID 83702
E-MAIL: oeter(Erichardsonadams.com
C TOM ARKOOSH
ARKOOSH LAW OFFICES
913 RIVER ST STE 450
BOISE ID 83702
E-MAIL : [e-mail]
erin. [e-mail]
CAMILLE CHRISTEN
ENERGY CONTRACTS
P.O. BOX 70
BOISE,ID 83707
E-MAIL : [e-mail]
energy contracts@idahopower. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL : [e-mail]
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CERTIFICATE OF SERVICE