20210506Comments.pdf

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JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILTTIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
Street Address for Express Mail:
I I33I 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
COMPANY'S PETITION TO EXTEND THE
FILING DATE OF ITS 2O2I INTEGRATED
RESOURCE PLAN
CASE NO.IPC.E.2I.06
COMMENTS OF THE
COMMISSION STAFF
coMES NOW the Staff of the Idaho Public utilities commission ("staff'), by and
through its attorney of record, John R. Hammond, Jr., Deputy Attorney General, and in response
to the Notice of Application and Modified Procedure issued in Order No. 35007 on April 16,
2021, in Case No. IPC-E-21-06, submits the following comments.
BACKGROUND
On March 25,2021, Idaho Power Company ('oCompany") petitioned the Commission to
extend the filing date for the Company's 2021 Integrated Resource Plan ("IRP") from the last
business day of June 2021 to no later than the last business day of December 2021.
The IRP examines the anticipated demand for energy over the next 20 years and the least-
cost, least-risk altematives for the Company to meet that demand while balancing reliability,
environmental responsibility, efficiency, risk, and cost. The IRP is updated every two years.
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ISTAFF COMMENTS MAY 6,2021
The Company's IRP is typically due on the last business day of June in odd-numbered
years. The Company requests the filing date for its 2021 IRP to be moved from the last business
day of June 2021to no later than the last business day of December 2021.
The Company's 2019 IRP was significantly delayed to provide accuracy and
accommodate the leaming curve associated with using a new long-term capacity expansion model
to develop potential resource portfolios. The Commission did not acknowledge the Company's
2019 IRP until March 2021. Because of the longer than anticipated processing of the 2019 IRP,
the Company requests extension of the 2021 IRP filing deadline to allow for more stakeholder
participation and comment.
STAFF ANALYSN
Staff believes there will be limited impact to upcoming filings that are dependent upon the
IRP. Staff recommends that the Commission grant the Company's request for filing the 2021 IRP
no later than the last business day of December 2021.
IRP Advisory Council ("IRPAC")
Staff supports the thorough development and analysis of a least-cost, least-risk integrated
resource plan. The IRPAC membership consists of major industrial customers, irrigation
representatives, elected officials, members of the environmental community, public utility
commission representatives, and other interested parties. A series of public meetings have been
and are scheduled to be held online in the months of May, June, July, and final meeting scheduled
in September. The Company states that they cannot take full advantage of the IRPAC's input and
expertise prior to filing in June of 2021and believes its customers are best served by an IRP that
has been fully discussed and stakeholders have ample time to provide input prior to its filing.
Staff supports the Company's willingness to continue to hold public meetings to collect
stakeholder input and the Company should continue to hold IRPAC meetings and keep to the
scheduled dates to keep the filing on time for the last business day of December 2021. Staff
believes it is appropriate to permit the IRP extension to allow the Company time to resolve issues
and concerns that are discussed in TRPAC meetings.
2STAFF COMMENTS MAY 6,2021
Related IRP Cases
Considering the proposed IRP filing delay, Staff believes the Annual Load and Natural
Gas Forecast Update case should not be affected. The updated forecasts become effective on
October l5th of each year, and the Company typically uses the latest load and natural gas forecasts
available at that time.
Staff recognizes that the IRP delay will lead to a delayed update of the First Capacity
Deficiency Date used for avoided cost pricing under both the Surrogate Avoided Resource
Method and the IRP Method, since the First Capacity Deficiency Date case is filed after
acknowledgement of each IRP. See Order Nos. 33917 and34649. A delay in the filing of this
case will result in extending the currently acknowledged First Capacity Deficiency Date for a
longer period. The timing when capacity payments will begin for new PURPA contracts depends
on whether the new First Capacity Deficiency Date is earlier or later than the currently
acknowledged First Capacity Deficiency Date.
STAFF RE,COMMENDATIONS
Staff recommends the Commission grant an extension for filing the202l IRP from the last
business day of June 2021 to no later than the last business day of December 2021.
Respectfully submitted this Ut!" day of May 202t.
R. Hammond, Jr
Attorney General
Technical Staff: Travis Culbertson
Kevin Keyt
Yao Yin
i:umisc:commens/ipce2 l.6jhtnckkTy comments
JSTAFF COMMENTS MAY 6,2021
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 6ft DAY OF MAY 2021,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E.21.06, BY E-MAILING A COPY TIIEREOF, TO THE
FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
[e-mail]
ALISON WILLIAMS
REG POLICY & STRATEGY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE