20040504Application.pdf

BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
P. O. Box 70
Boise , Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
RECEIVED 0FiLED
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jiJ PUbLICUffLi fiES COHt1fSSION
Attorneys for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING BY
IDAHO POWER COMPANY OF ITS
2004 ELECTRIC INTEGRATED
RESOURCE PLAN (IRP)
CASE NO. IPC-04-1!--
MOTION FOR EXTENSION OF
TIME TO FILE 2004 INTEGRATED
RESOURCE PLAN
In accordance with the provisions of Commission Order No. 22299 issued
in Case No. U-1500-165 , Idaho Power biennially files its Integrated Resource Plan
I RP"). The IRP describes the Company s expectations for load growth and provides
an overview of available resource options, including purchases of power from the
wholesale market, the acquisition of additional generating resources and demand-side
management programs. The Commission s Orders addressing the procedure to be
followed in the IRP process require that the Company file the IRP by the end of June
every other year.
MOTION FOR EXTENSION OF TIME TO FILE INTEGRATED RESOURCE PLAN, Page
In Order No. 29189 issued on February 11 2003, in Case No. IPC-02-
the Commission acknowledged and accepted Idaho Power s 2002 IRP. Order No.
29189 also described a number of changes that the Commission directed the Company
to pursue in future IRPs. The Commission first directed the Company to modify the IRP
development process so that the public could be involved in the development process in
a more meaningful way. The Commission also directed the Company to modify its
process to address not only supply options, but to undertake serious consideration and
reasoned discussion of available demand-reduction options. In Order No. 29189 the
Commission described its expectation that the Company consider the IRP to be an
actual planning document. In that Order the Commission also expanded the IRP to
accurately represent the Company s best estimate of future changes in loads, resources
and contract obligations , and directed that the IRP be indicative of how the Company
intends to meet its statutory obligations to serve native load.
In response to the Commission s direction contained in Order 29819 , the
Company has made a number of significant changes in the scope, allocation of
resources and process it is using to develop the 2004 IRP. Probably the most visible
change is the creation of the Integrated Resource Plan Advisory Council ("I RPAC"
The IRPAC consists of 16 different individuals representing various customer groups
environmental organizations, representatives of the Staffs of the Idaho Public Utilities
Commission and the Oregon Public Utility Commission, members of the Idaho
Legislature , the Governor s Office and others.
The IRPAC has held regular monthly meetings since September, 2003.
Attendance (excluding Idaho Power employees) has averaged approximately 13 or 14
MOTION FOR EXTENSION OF TIME TO FILE INTEGRATED RESOURCE PLAN , Page 2
at each meeting. The meetings have essentially been all-day meetings and a
substantial amount of information has been provided to and received from members of
the IRPAC.
In addition to the expanded public involvement process , the Company has
invested substantial additional resources in human resources and computer modeling
capability and effort. This effort includes development of techniques to evaluate both
supply-side and demand-side resources on an equivalent basis. Adjustments have also
been proposed to model the role of renewable resources and the potential risks
associated with CO2 controls and other external costs associated with various types of
generating resources.
While the Company has invested substantial additional time and effort in
preparing the 2004 IRP , the increased scope and complexity has delayed development
of the plan document.
At the most recent IRPAC meeting on April 15, 2004, the Company
advised the IRPAC of its current schedule , including completion and distribution of the
draft IRP, receipt of comments from the IRPAC on the draft IRP document, a series of
four public meetings around the state and in Oregon to take public comment and then
completion of the final 2004 IRP document to include both the comments received from
the IRPAC and at the public meetings. The Company indicated tothe IRPAC that while
it is feasible for the Company to accomplish all of those goals prior to the scheduled
end-of-June filing deadline, the Company was seeking advice from the IRPAC as to
whether it would be preferable to seek a delay from the Commission of the filing date for
the final 2004 IRP to allow the IRPAC additional time to review the draft IRP document
MOTION FOR EXTENSION OF TIME TO FILE INTEGRATED RESOURCE PLAN, Page 3
and to give the Company additional time to integrate comments from the IRPAC and the
public meetings into the finallRP document.
After discussion , it was apparent to the Company that the participants in
the April 15, 2004 IRPAC meeting (including representatives from the IPUC and OPUC
Staffs) believed it would be better for the Company to spend additional time consulting
with the IRPAC members and the public before it completed the 2004 IRP document
even if that meant asking the IPUC and OPUC for permission to file the 2004 IRP later
than the scheduled end-of-June 2004 date.
Idaho Power is hereby requesting that the Commission allow the
Company to file the 2004 IRP on or before August 31 2004. Idaho Power will work
diligently to file the 2004 IRP prior to that date, but the Company believes it would be in
the public interest for the Commission to allow the Company this sixty-day extension in
the filing date.
Based on the foregoing, the Company respectfully requests that the
Commission , either by order or by minute entry, authorize the Company to file its 2004
IRP on or before August 31 2004.
Respectfully submitted this 30th day of 2004.
BARTON L. KLINE
Attorney for Idaho Power Company
MOTION FOR EXTENSION OF TIME TO FILE INTEGRATED RESOURCE PLAN, Page 4