20210728Reply Comments.pdf

3Em"
'' .t iiil An IDACORP Company
July 28,2021
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, ldaho 83714
Case No. IPC-E-21-09
ldaho Power Company'sApplication for Capacity Deficiency To Be Utilized
For Avoided Cost Calculations
Dear Ms. Noriyuki:
Attached for electronic filing is Idaho Power Company's Reply Comments in the
above entitled matter. lf you have any questions about the aftached documents, please
do not hesitate to contact me.
Very truly yours,
DONOVAN E. WALKER
Lead Counsel
[e-mail]
DEW:cld
Enclosures
Re
2ilatl<-
Donovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS.
CASE NO. !PC-E-21-09
IDAHO POWER COMPANY'S
REPLY COMMENTS
)
)
)
)
)
)
)
ldaho Power Company ("ldaho Power" or "Company"), in accordance with RP 201,
ef seg., as well as the ldaho Public Utilities Commission's ("|PUC" or "Commission")
Notice of Modified Procedure in this matter, Order No. 35091, hereby respectfully submits
the following Reply Comments.
I. INTRODUCTION
On April 9, 2021, ldaho Power filed an Application for Approval of the Capacity
Deficiency to be Utilized for Avoided Cost Calculation with the Commission. This
Application was made afterthe Commission's acknowledgment of the Company's Second
Amended 2019lntegrated Resource Plan ("!RP"), and pursuantto Order No. 34649, Case
No. IPC-E-19-20.1 The lndustria! Customers of ldaho Power ("lClP") and the Idaho
1 Order No. 34649 dismissed ldaho Powe/s previously filed Application for approvalof the capacity
IDAHO POWER COMPANY'S REPLY COMMENTS. 1
Hydroelectric Power Producers Trust ("ldaHydro") were granted intervention on June 23,
2021. Order No. 35084. Commission Staff ("Staff') and IdaHydro filed Comments on
July 21,2021. ICIP did not file Comments.
ldaHydro requests, "that the capacity deficiency date for PURPA QF avoided costs
be set at a mid-summer month in 2023." ldaHydro Comments, p 2. ldaHydro refers to
the Company's Notice of lntent to seek requests for proposals that references a capacity
need identified as early as Summer 2023 and asks the Commission to establish the same
for PURPA avoided costs. ld., atp 1-2.
Staff issued severa! discovery requests and filed Comments recommending that
the Company update the first capacity deficit from that contained in the acknowledged
Second Amended 2019 Amended lRP, which was that contained in the Company's
Application, by incorporating several updates and changes. Staff Comments, p 1-2, 10.
Staff also recommends that the Commission open a generic docket to determine the
timing of the deficiency date filing in relation to the timing of the lRP, "i.e., after the filing
of an lRP, after the acknowledgment of an lRP, or at other times." ld. at p 10.
II. REPLY COMMENTS
ldaho Power appreciates ldaHydro and Staffs review and Comments. The
Company acknowledges an apparent difference between the first capacity deficit that
appears in the acknowledged 2019 Amended IRP (20281and that which is referenced in
the Company's Notice of lntent to seek requests for proposals and the Request for
Proposals itself seeking generation to meet an identified capacity deficit in2023. As Staff
deficiency to be utilized for avoided cost calculations that was made at the time of filing of the 2019 lRP,
and directed the Company to make the filing after Commission acknowledgment of the lRP.
IDAHO POWER COMPANY'S REPLY COMMENTS.2
discussed in its Comments, this difference is due to severalfactors including differences
in timing, changed circumstances, and differing methodologicalapproaches between the
2019 and 2021 lRPs. Also, as noted by Staff, the unusually long delay in the processing
of the 2019 lRP, combined with the change in timing of the filing of the capacity
determination for avoided costs from the time of filing of the IRP to the time of
acknowledgment of the IRP caused an unusually Iarge overlap in timing between the
2019 and 2021 IRP cycles, and a longer period of time over which circumstances
changed. ldaho Power agrees with and accepts Staffs recommended changes and
adjustments to the capacity deficiency date which are as fo!!ows:
. Utilize the most recent load forecast developed by the Company;
o Reduce the amount of Market Purchases from southern
pathwavs by 310 MW and only include 50 MW starting in2021;
. A!!ow non-PUPRA PPAs to expire on their actual expiration
dates;
o Reflect contract changes since the preparation of the L&R, which
include PURPA contract updates identified in Response to Staffs
Production Request No. 7 and approval of the Jackpot Solar
contract; and
o Correct the capacity value of Valmy Unit 2 and Bridger.
Staff Comments, p 10. The Company is prepared to make the above adjustments to the
load and resource balance used to determine the first capacity deficit date, should the
Commission direct the same, and the Company requests up to two weeks with which to
make the compliance filing implementing the adjustments.
IDAHO POWER COMPANY'S REPLY COMMENTS. 3
With regard to Staffs recommendation to open a generic docket to determine when
the biannual deficiency date should be filed in relation to the IRP filing date, or IRP
acknowledgment, or some other time in relation to the lRP, ldaho Power reiterates its
preference that the capacity deficiency filing occur as it was originally directed to occur
by the Commission: at the time of filing of the lRP. lt is important to have changes in
avoided costs be implemented in a consistent, certain, and expeditious manner.
Prolonged delay and potentially protracted investigation and litigation over changes to
avoided costs and its various inputs introduces uncertainty into the process, the potential
for legally enforceable obligation claims and "grandfathering" issues related to the
previously effective rates, and the potentia! that customers may be harmed by a QF's
ability to lock-in a long term rate that may have otherwise been updated in a shorter, more
concise update process.
The capacity deficiency date determined in the IRP is presumed to be correct as
a starting point but wi!! be subject to the outcome of the capacity deficiency case for
avoided costs, separate from the lRP. Order No. 32697. ldaho Power believes the
original incarnation of the capacity deficiency filing, made at the time of the filing of the
IRP provides a better balance of utilizing current information, allowing opportunity to
update for changed information from that which was utilized in the !RP, and implementing
an avoided cost update in an expeditious and consistent manner and proceeding. lf the
capacity deficiency filing is removed in time until after the acknowledgment of the lRP, or
later, then more things can change, the potential for conflict between different
methodologica! approaches across different lRPs can emerge, and as happened with the
2019lRP and in this case can cause a long and protracted delay and uncertainty as to
IDAHO POWER COMPANY'S REPLY COMMENTS .4
the appropriate avoided cost rates. The farther away from the filing date of the IRP that
the filing of the capacity deficit case occurs, the more opportunity there is for divergence
from the first deficit contained in the IRP. The Company believes that using the IRP first
deficit date as a starting point is correct, and that the most expeditious way to separately
update the first capacity deficiency for avoided costs using the IRP first deficit as a starting
point to is to initiate the case at the time of filing, and run it simultaneously with the IRP
review.
Although Idaho Power appreciates Staffs recommendation to open a generic case
to determine the timing of the capacity deficiency filing in relation to the lRP, and supports
the Commission's consideration of this topic, the Company believes the Commission
could direct that the timing of the filing should revert back to the originally directed timing
- to be made at the time the IRP is filed - without further proceedings.
III. CONCLUSION AND RECOMMENDATIONS
ldaho Power appreciates ldaHydro and Staffs review and Comments. Idaho
Power agrees with and accepts Staffs recommended changes and adjustments to the
inputs in the load and resource balance used to determine the capacity deficiency date,
and should the Commission direct the same the Company requests up to two weeks with
which to make the compliance filing implementing the adjustments. ldaho Power also
supports Staffs recommendation for the Commission to re-examine the timing for the
filing of the capacity deficiency filing, however, the Company proposes that the
Commission revert the capacity deficiency filing to be made at the time of filing of the lRP,
as it was originally directed, without further process or procedure.
IDAHO POWER COMPANY'S REPLY COMMENTS. 5
Respectfrrlly submitted this 28h day of Ju$ 2A?1.
M?dettn-
DONOVAN E. WALKER
Attomey br ldaho Power Company
IDAHO POWER COMPANYS REPLY GOITIMENTS - G
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of July 2021, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S REPLY COMMENTS
upon the following named parties by the method indicated below, and addressed to the
following:
John Hammond
Deputy Attorney General
ldaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
lndustrial Customers of ldaho Power
Peter J. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
ldaHydro
C. Tom Arkoosh
ARKOOSH IAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, lD 83701
Hand Delivered
U.S. Mail
Overnight Mail
_ FAXX Email:
iohn. hammond@puc. idaho.qov
Hand Delivered
U.S. Mail
Overnight Mail_ FAXX Email:
peter@ richa rdsonadams. com
q req @richardsonadams. com
Hand Delivered
U.S. Mail
Overnight Mail
_ FAXX Email:
tom. arkoosh@arkoosh. com
erin. cecil@arkoosh. com
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS. T