20220211IPC to Idahydro 1.pdf

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DONOVAN WALKER
Lead Counsel
dwalker@ida hopower.com
DEW:cld
Enclosures
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Donovan E. Walker
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February 11,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-2141
!n The Matter Of ldaho Power Company's Application For Authority to
Proceed with Resource Procurements to Meet Identified Capacity
Deficiencies in 2023, 2024, and 2025 to Ensure Adequate, Reliable, and
Fair-Priced Service to its Customers
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Response to ldaHydro's
First Set of lnterrogatories in the above entitled matter. lf you have any questions about the
aftached document, please do not hesitate to contact me.
Very truly yours,
DONOVAN E. WALKER (lSB No. 5921)
Idaho Power Company
1221 West ldaho Street (83702\
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa [e-mail]
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO PROCEED WITH
RESOURCE PROCUREMENTS TO MEET
IDENTIFIED CAPACITY DEFICIENCIES IN
2023,2024, AND 2025 TO ENSURE
ADEQUATE, RELIEABLE, AND FAIR.
PRICED SERVICE TO ITS CUSTOMERS.
BEFORE THE IDAHO PUBLIC UTIL!T!ES COMMISSION
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CASE NO. IPC-E-2141
IDAHO POWER COMPANY'S
RESPONSE TO IDAHYDRO'S
FIRST SET OF
INTERROGATORIES
COMES NOW ldaho Power Company ("!daho Powe/' or "Company"), and in
response to IdahHydro'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 - 1
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 General
ldaho Public Utilities Commission
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
Northwest and lntermountain Power
Producers Coalition
Gregory M. Adams
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
Idaho Conservation League
Benjamin J. Otto
710 North 6th Street
Boise, !D 83701
Emailed to:
davn.hardie@puc. idaho.oov
Emailed to:
peter@ richa rdsonadams. com
Emailed to:
q req@ richardsonadams.com
Emailed to:
tom. a rkoosh@arkoosh. com
[e-mail]
Emailed to:
botto@ ida h oconservation.orq
Christy Davenport, Legal Assistant
REQUEST NO. 1: When is or will 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 IPC-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 tor
purposes of PURPA avoided cost pricing.
The response to this Request is sponsored by Mark Annis, Regulatory Consultant,
ldaho Power Company.
Respecttully submitted this 11th day of February 2022
Mzdat4-
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO IDAHYDRO'S
FIRST SET OF INTERROGATORIES - 2