20220407Reply Comments.pdf

sm.:.r' ,' i _ ! ' - ! il'.1.1-,fi..l ? Gr-,
;tit fiffr * j Pi'i h: trO
Il_rr,. -.,-'.-, l- i.r1": i--Iir., . l::l '-...;.'r..t-tlf1l.i.:!:-.:ir_- ... r: ".r1-,I!/r
An loAcof,P company
DONOVAN E. WALKER
Lead Couneel
dwalker@ida hooower.com
April 7, 2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building I
Suite 201-A
Boise, ldaho 837'14
Re: Case No. IPC-E-21-09
ldaho Power Company's Application for Capacity Deficiency To Be Utilized
For Avoided Cost Calculations
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Reply Comments in the
above entitled matter. !f you have any questions about the attached documents, please
do not hesitate to contact me.
Please be aware that Attachment No. 1 is confidential. Please handle the
confidential information in accordance with the Protective Agreement executed in this
mafter.
Very truly yours,
2detL
Donovan E. Walker
DEW:cld
Enclosures
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
122'l West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa lker@idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILIT!ES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOI DED COST CALCULATIONS
CASE NO. |PC-E-21-09
IDAHO POWER COMPANY'S
REPLY COMMENTS
)
)
)
)
)
)
)
ldaho Power Company ("!daho Powe/'or "Company") herby respectfully submits
the following Reply Comments pursuant to the ldaho Public Utilities Commission's
("Commission" or "IPUC') Order No. 35346, Notice of Amended Application/Notice of
Modified Procedure.
I. BACKGROUND
The original Application in this matter, Case No. IPC-E-21-09, was filed by ldaho
Power on April 9, 202'1. The Application was made after the Commission's
acknowledgment of the Company's Second Amended 2019 lntegrated Resource Plan
("lRP"), and pursuant to Order No. 34649, Case No. IPC-E-19-20.1 The lndustrial
1 Order No. 34649 dismissed ldaho Power's previously filed Application for approval of the capacity
deficiency to be utilized for avoided cost calculations that was made at the time of filing of the 2019 IRP
and directed the Company to make the filing after Commission acknowledgment of the lRP.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
Customers of ldaho Power ('lClP') and the ldaho Hydroelectric Power Producers Trust
("!daHydro") were granted intervention on June 23,2021. Order No. 35084. Commission
Staff ("Staff') and ldaHydro filed Comments on July 21 ,2021. lClP did not file Comments.
ldaho Power filed Reply Comments on July 28,2021, agreeing and accepting Staffs
recommended changes and adjustments to the capacity deficiency determination. The
Case appeared as a 'fully submitted" matter on the Commission's October 12, 2021,
Decision Meeting, where the Commission determined that the matter was fully submitted
and would be deliberated privately.2
On February 4,2022,ldaho Power filed an Amended Application concurrent with
a Motion for leave to file the same. On March 15,2022, the Commission issued Order
No. 35346 Notice of Amended Application and Amended Notice of Modified Procedure.
ldaHydro filed Comments pursuant to the Amended Application on March 29,2022, and
Staff filed Amended Comments on March 31, 2022. ldaHydro filed Reply Comments on
April 6, 2022.
II. COMMENTS
ldaho Power's Amended Application seeks the establishment of July 2023 as the
first capacity deficit, consistent with the Company's filed 2021 lntegrated Resource Plan.
ldaho Hydro's Reply Gomments reiterated its request to set the first capacity deficit for
PURPA pricing at July 2423. Staff, in its Amended Comments, recommends that the
Gompany file an updated Ioad and resource analysis and first capacity deficiency that
incorporates at least seven bulleted adjustments and changes.
ldaho Power appreciates Staffs thorough examination and recommendations, and
2 ldaho Public Utilities Commission Minutes of Decision Meeting, October '12,2021,1:30 p.m.
https://ouc.idaho.qov/Fileroom/PublicFiles/Aqenda?2021?2021 1013M1N. pdf
IDAHO POWER COMPANY'S REPLY COMMENTS.2
the Company has conducted Staffs recommended adjustments to the load and resource
analysis - attached hereto as Attachment 1 and incorporated herein by this reference. As
shown in Attachment 1, incorporation of Staffs recommended adjustments results in no
change from the July 2023 first capacity deficit requested by ldaho Power and ldaHydro
and shown in the filed 2021 !RP. Consequently, ldaho Power recommends that the
Commission set the first capacity deficiency for PURPA avoided cost pricing at July 2023
with no further filings or proceedings.
While it could be debated whether or not Staffs recommended adjustments to the
IRP based first capacity deficit are appropriate or not for purposes of PURPA pricing,
such determination is not necessary here, and moot, as incorporation of Staffs
recommended adjustments makes no change to the July 2023 first capacity deficit.
Further, the Company notes that this proceeding, addressing PURPA pricing, does not
address whether or not the recommended adjustments are proper or necessary in the
context of the lRP. The Company looks forward to discussing and working through these
items with Staff and stakeholders as part of the lRP process, but for purposes of this
matter respectfully requests that the Commission issue its final Order setting July 2023
as the first capacity deficiency for PURPA avoided cost pricing.
Respectfully submitted this 7th day of Apri! 2022.
Mzdd!4-
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 7th day of April2022l served a true and correct
copy of the within and foregoing ldaho Power Company's Reply Comments upon the
following named parties by the method indicated below, and addressed to the following:
Dayn Hardie
Deputy Aftomey General
!daho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Terri Carlock
I PUC Staff Administrator
Po Box 83720
Boise, ldaho 83720-0074
!ndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
Emailed to
davn.hardie@puc. idaho.qov
Emailed to:
terri.ca rlock@puc. idaho.oov
Emailed to:
peter@ rich a rd so n adams. com
Emailed to:
tom.arkoosh rkoosh.com
e rin.cecil@a rkoosh.com
Chris$ Davenport, Legal Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 4