20230518Comments.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

May 18, 2023

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

Re: Case No. GNR-E-23-01
Commission Staff’s Application to Alter the Filing Date of the Capacity
Deficiency Case

Dear Ms. Noriyuki:

Attached for electronic filing, please find Comments of Idaho Power Company in the
above-entitled matter. If you have any questions about the attached document, please do
not hesitate to contact me.

Sincerely,

Donovan Walker
DEW:cd
Enclosures
RECEIVED
Thursday, May 18, 2023 2:51:03 PM
IDAHO PUBLIC
UTILITIES COMMISSION
COMMENTS OF IDAHO POWER COMPANY - 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 COMMISSION
STAFF’S APPLICATION TO ALTER THE
FILING DATE OF THE CAPACITY
DEFICIENCY CASE
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CASE NO. GNR-E-23-01

COMMENTS OF IDAHO POWER
COMPANY

Idaho Power Company (“Idaho Power” or “Company”), in accordance with RP 201,
et seq., and the applicable provisions of the Public Utility Regulatory Policies Act of 1978
(“PURPA”), as well as the Idaho Public Utilities Commission’s (“IPUC” or “Commission”)
Notice of Modified Procedure in this matter, Order No. 35761, hereby respectfully submits
the following Comments.
On April 6, 2023, Commission Staff filed an Application requesting a Commission
Order modifying the filing date for the capacity deficiency date cases filed by Idaho Power,
Avista, and Rocky Mountain Power. The requested modification would shift the filing date
for the capacity deficiency date case from the current timing, after acknowledgment of the
most recent Integrated Resource Plan (“IRP”), to within 30 days of the utility’s IRP filing.
COMMENTS OF IDAHO POWER COMPANY - 2

Idaho Power fully supports Staff’s proposal and encourages the Commission to
approve it. Staff’s proposal will provide more accurate and timely information regarding
the utility’s capacity needs to PURPA Qualifying Facilities and other stakeholders.1 Idaho
Power thanks Staff for convening a workshop to discuss this issue and for the thoughtful
discussion.
Respectfully submitted this 18th day of May, 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

1 Idaho Power has consistently requested that the capacity deficiency filings be made coincident with the
time at which the IRP is filed, as opposed to the time at which the IRP is acknowledged. See, IPC-E-19-
20, IPC-E-21-09.
COMMENTS OF IDAHO POWER COMPANY - 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 18th day of May, 2023, I served a true and correct
copy of the within and foregoing COMMENTS OF IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:

Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

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Mike Louis
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

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________________________________
Christy Davenport, Legal Assistant