20230616RMP Letter.pdf

1407 W. North Temple 
Salt Lake City, UT 84116 

June 16, 2023

VIA ELECTRONIC FILING

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

RE: CASE NO. GNR-E-23-01
IN THE MATTER OF THE COMMISSION STAFF’S APPLICATION TO
ALTER THE FILING DATE OF THE CAPACITY DEFICIENCY CASE

On June 8, 2023, the Idaho Public Utilities Commission (“Commission”) issued Order No. 35810
in the above referenced case directing the utilities, including Rocky Mountain Power, a division
of PacifiCorp (“the Company”), to “file its capacity deficiency case within thirty (30) days of filing
its respective IRP.”

The capacity deficiency period determination is to be used in avoided cost calculations using the
Surrogate Avoided Resource (“SAR”) methodology. On October 4, 2022, the Company filed its
application for a capacity deficiency period in the summer of 2023 explaining how the deficiency
period was identified in Case No. PAC-E-22-14. On January 20, 2023, the Company filed reply
comments again identifying summer 2023 as the capacity deficiency date. An order from the
Commission is pending in that case. On March 31, 2023, the Company filed its 2023 integrated
resource plan (“2023 IRP”).

The Company respectfully requests that the capacity deficiency period filing requirement as
outlined in Order No. 35810 be waived for the 2023 IRP because the 2023 IRP would not change
the capacity deficiency date from the summer of 2023. For details on PacifiCorp’s load and
resource balance in the 2023 IRP, please refer to Tables 6.11 and 6.12. These tables show
uncommitted front office transactions (“FOTs”) for 2023-2025 are needed that are well in excess
of PacifiCorp’s 500 MW planning target in the summer and its 1,000 MW planning target for the
winter.

In the event that the Commission still requires a capacity deficiency application; the Company
plans to submit its capacity deficiency filing for the 2023 IRP after the 2023 IRP is acknowledged
in accordance with Order Nos. 32697 and 32802 in Case No. GNR-E-11-03 since Order No. 35810
was issued more than 30 days after the filing of the 2023 IRP.

RECEIVED
Friday, June 16, 2023 10:39:38 AM
IDAHO PUBLIC
UTILITIES COMMISSION
Idaho Public Utilities Commission
June 16, 2023
Page 2

Informal questions related to this matter may be directed to Mark Alder at [phone].

Sincerely,

Joelle Steward
Senior Vice President of Regulation and Customer/Community Solutions

CC:
John Lyons [e-mail]
James Gall [e-mail]
Shawn Bonfield [e-mail]
Avista Corp [e-mail]
Donovan E. Walker [e-mail]
Camille Christen [e-mail]
Idaho Power Company [e-mail]
Dan MacNeil [e-mail]