20210721Redacted Comments.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10655
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR APPROVAL )CASE NO.IPC-E-21-09OFTHECAPACITYDEFICIENCYTOBE)UTILIZED FOR AVOIDED COST )CALCULATIONS )REDACTED COMMENTS OF
)THE COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on Idaho Power
Company's Application.
BACKGROUND
On April 9,2021,Idaho Power Company ("Company")applied for Commission approval
of its capacity deficiency period determination for avoided cost calculations under the Public
Utility Regulatory Policies Act of 1978 ("PURPA").
Under PURPA,the Commission has established a surrogate avoided resource ("SAR")
method and an integrated resource plan ("IRP")method to calculate avoided cost rates for
qualifying facilities ("QFs").Under both methods,a QF receives capacity payments only after
the applicable capacity deficit date is reached.Order Nos.33377,33159,and 33898.The first
deficit date under the IRP method will float (change)to reflect the changes in the QF queue,
REDACTED STAFF COMMENTS 1 JULY 21,2021
while the first deficit date under the SAR method will not float to reflect the changes in the QF
queue.Order No.33933.
The capacity deficiency period is determined through the IRP planning process and is
submitted to the Commission in a proceeding separate from the IRP docket.The capacity deficit
date determined in the IRP process is presumed to be correct as a starting point but will be
subject to the outcome of the capacity deficiency case.Order No.32697.
In its Application,the Company anticipates its capacity deficiency period will begin in
August 2028 and explains how this capacity deficiency period was calculated.To calculate its
capacity deficiency period for PURPA avoided cost calculations,the Company explains that its
"load and resource balance has been determinedbased on the [Company's]system as modeled in
the 2019 IRP."Application at 3;see Case No.IPC-E-19-19,Order No.34959 (acknowledging
the Company's 2019 IRP).The Company asks that the Commission approve the capacity
deficiency period.
STAFF ANALYSIS
Staff examined the load forecast and resources in the load and resource balance ("L&R")
filed in this case.The L&R is used to determine the proposed capacity deficiency date used in
both the IRP and SAR methods.Based on its analysis,Staff recommends the Company update
the L&R and the resulting capacity deficiency date by incorporating the followingchanges:
Use the most recent load forecast developedby the Company because the
proposed load forecast does not reflect current economic conditions;
Reduce the amount of Market Purchases from southern pathways by 310 MW and
only include 50 MW starting in 2021;
Allow non-PURPA PPAs to expire on their actual expiration dates;
Reflect contract changes since the preparation of the L&R,which include PURPA
contract updates identified in Response to Staff's Production Request No.7 and
approval of the Jackpot Solar contract;and
Correct the capacity values of the Valmy Unit 2 and Jim Bridger ("Bridger")
generating facilities.
If Staff's recommendations are authorized by the Commission,Staff proposes to update
published rates on the Commission's website after the Company files an updated L&R and
REDACTED STAFF COMMENTS 2 JULY 21,2021
capacity deficiency date through a compliance filing.Furthermore,Staff recommends that a
generic docket be opened to determine the timing of the deficiency date filing in relation to the
timing of the IRP.This will allow the utilities,other parties,and Staff to weigh the pros and
cons of different filing schedules.Details for each of the recommendations are contained in the
followingsections.
Deficiency Date Filing Timing and Notice of Intent
The deficiency date in this filing is based on the information used to develop the L&R from
the Company's 2019 IRP.In Order No.33917,the Commission decided to change when the
utilities file their bi-annual first deficiency date updates until after the Commission
acknowledgedtheir IRPs based on Staff s recommendation.Staff's recommendation and the
Commission's decision were based on ensuring a full review of the IRP so that any findings
through the IRP review that affects L&R could be incorporated into the analysis of the
deficiency date when the case was filed.However,this change in timing,exacerbated by the
Company's delay in processing the 2019 IRP,has caused a larger than usual overlap in timing
with the start of the 2021 IRP cycle prior to the 2019 IRP acknowledgment.
The overlap in timing and the practice of updating information,such as the load forecast,
recent long-term contracts,and non-method driven inputs using the most recent IRP as a starting
point,2 has caused unintended consequences as it relates to the Company's Notice of Intent for an
All-Source Request for Proposals ("NOI")announced in May 2021.The need for the NOI is
driven by information and preliminaryanalysis that the Company has performed as part of the
2021 IRP,not the 2019 IRP.This has caused some apparent contradictions between the timing
and need for resources in this filing versus the need and timing of resources in the NOI.Because
of these contradictions,Staff's investigation separated the different drivers precipitating the NOI
to determine which of those drivers and related data should be used to update the L&R and the
deficiency date for this filing versus those items that should be evaluated in the next deficiency
1 The Second 2019 Amended IRP was not filed until October 2,2020,about 15 months after it normally would havebeenfiled.It was acknowledged on March 16,2021.
2 Order No.32697,p.23 states that the "capacity deficiency determined through the IRP planning process will be thestartingpoint,and will be presumed to be correct subject to the outcome of the [capacity deficiency date case]proceeding."This is furtherreinforced in Order No.33958 which states,'Recognizing that IRPs are long-term plansthatare"flexible and responsive to its customers'needs over time,'[Order 32697 at 23]we find it appropriate for autilitytousethemostupdatedinformationavailableincalculatingitscapacitydeficitdate."
REDACTED STAFF COMMENTS 3 JULY 21,2021
date case associated with the 2021 IRP after it has been acknowledged.Through responses to
discovery requests,Staff has identified the primary drivers of the NOI which are (1)load growth,
(2)availability of firm transmission to access purchases from the market,and (3)changes in the
Effective Load Carrying Capability ("ELCC")of solar,wind,and demand response,and a Loss
of Load Expectation-derived planning margin.
In summary,Staff has determined that the load growth has already been incorporated into
the peak load forecast filed in the Application and in the latest peak load forecast.Second,Staff
believes the market availability from the Company's southern transmission pathways should be
reduced.Finally,changes in ELCC and planning margins should be evaluated as part of the
2021 IRP and the subsequent capacity deficiency date filing.Each of these items and Staff's
rationale will be discussed in further detail.
Furthermore,Staff recommends that a generic docket be opened to determine when the
biannual deficiency date should be filed to reduce the issues due to the overlap in timing between
IRP cycles (e.g.after the filing of an IRP,after the acknowledgement of an IRP,or at other
times).This will allow the utilities,other parties,and Staff to weigh the pros and cons of
different filing schedules.
Peak-Load Forecast
Because Staff is concerned that circumstances have changed since the proposed load
forecast was developed,especially given COVID and its potential impacts on customer
consumption patterns that could change the amount of load during system coincident peak,Staff
recommends using the latest forecast in the L&R instead of the proposed load forecast.
The forecast used in the Application is the same forecast used in the Second Amended
2019 IRP.The Company states in Response to Staff's Production Request No.11 that the
proposed load forecast in the Application is not the latest load forecast,and the latest load
forecast reflects the impacts of the COVID-19 pandemic.The pandemic-related adjustments in
the latest load forecast include an increase in usage in the Residential sector,a decrease in usage
of Industrial and Large Commercial customers for 2021 and 2022,a decrease in usage of
remaining Commercial sector from 2021 through 2025,and load forecasts provided by Special
Contract customers that reflect near-term demand and energy impacts attributable to recent
changes in economic conditions.See Response to Staff's Production Request No.I 1.Because
REDACTED STAFF COMMENTS 4 JULY 21,2021
the latest load forecast is slightly lower than the proposed load ,using the
latest load forecast while holding all other factors constant will push the first deficit date from
August 2028 to July 2029.See Response to Staff's Production Request No.25.Because Staff
believes the latest load forecast is more current and accurate,Staff recommends that the
Company recalculate the deficiency date using the Company's most recent load forecast.4
Resources in the L&R
Staff compared the resources included in the L&R in the recent capacity deficiency
filings and IRP filings between Idaho's three regulated electric utilities and examined the
rationale each electric utility used for determining what and how resources should be included in
its L&R.Staff's objective in making these comparisons was to develop a common standard for
what should be included in the L&R for each type of resource to guide Staff's review.In Order
No.29880,the Commission made it clear that consistency is important between the three
regulated utilities:
The Commission develops its PURPA contract standards and requirementsingenericmethodology,ratesetting[,]and complaint cases...It is reasonableforQFstoexpectthatthecontractrequirementsofIdahoregulatedelectricutilitieswillbesimilarandthataQFwillnotbedisadvantagedbychoosingtoselltooneutilityratherthananother.
Order No.29880 at 10.
After identifyingdifferences between the utilities,Staff used the justificationsand
rationales obtained through production requests,meetings with utilities,and Staff's evaluation of
resources to document resources that are "available"and/or "existing"to include in the L&R.6 A
summary of these common standards for each resource type are included in Attachment A.
After developing common standards,Staff compared them to the resources the Company
included in its L&R for establishing its proposed capacity deficiency date.Staff used the
common standards as a default;if the Company's proposal deviated from the standard but the
Company provided sufficient evidence,an exception could be made.
3 Both forecasts are 50th percentile loads,and the comparison is conducted at the annual level.4 BOth the proposed load forecast and the latest load include the load growth referenced in the NOI.Changes in loadforecastarenotthemaindriveroftheNOLSeeResponsetoStaff's Production Request No.22.
6 The Commission expressed its expectation for focusing on "available"and/or "existing"resources when decidingwhethertransmissioncapacityshouldbeincludedintheL&R in Order No.33425.
REDACTED STAFF COMMENTS 5 JULY 21,2021
Market Purchases
The Commission has stated that "import capability must be considered as part of its
overall capacity balance.Avoided cost calculated without considering the Company's import
capability would fail to recognize the entirety of the Company's available capacity resources."
Order No.33425 at 7.Import capability in this context does not center on the purchases of
energy themselves,but on the ability to make purchases and as such must consider its ability to
make short-term purchases using its transmission capacity.Id Based on information supplied in
response to Production Request No.26,Staff believes it is appropriate to reduce the amount of
Market Purchases from southern pathways by 310 MW and recommends only including 50 MW
starting in 2021 in the L&R,effectivelypulling in the deficit date.
The IRP is a long-term resource planning process used to ensure that the Company has
identified cost-effective future resources outside of the lead-time required to acquire those
resources so that the Company has sufficient infrastructure in place to maintain customer
reliability.To maintain reliability,this infrastructure only includes generationand transmission
that the Company can control on a long-term basis.
In contrast,operationalplanning involves planning how the Company will operate this
infrastructure to optimize cost.In general,operational planning involves decisions regarding
how much of which resources will be run and how much will be supplemented with market
purchases sourced outside of the Company's system.Not locking in purchases on a long-term
basis provides the Company with the flexibilityto serve load while managing the risk of
fluctuatingmarket prices.In past IRPs,includingthe 2019 IRP,the Company has assumed that
it can obtain market purchases up to the amount of transmission capacity within its own system
because the market had sufficient liquidity.
However,one of the drivers necessitating the need for additional capacity through the
NOI was a reduction in the amount of firm transmission capacity through "southern market hubs
to North Valmy through the NV Energy system"and "on the PacifiCorp East transmission path
through Utah to Idaho."Response to Staff's Production Request No.26.Additionally,when
asked whether the fundamentals driving the constraints in the transmission market were
permanent or temporary,the Company responded that it expects third-partytransmission
availabilityto remain tight for the foreseeable future until incremental transmission is added to
the system.Response to Staff Production Request No.23.Staff's recommendation in this case
REDACTED STAFF COMMENTS 6 JULY 21,2021
is based on this new information.Staff further recommends the Company monitor its other
transmission pathways in the 2021 IRP and future IRPs,since the market availabilityof firm
transmission has tightened across the entire Western Interconnection.Staff believes it is
appropriate to reduce the amount of Market Purchases from southern pathways by 310 MW and
recommends only including 50 MW starting in 2021 in the L&R.
PURPA Contract Renewals
The Company assumes all PURPA contracts will renew,except for wind PURPA
contracts.Based on the explanations provided by the Company,Staff believes this assumption is
reasonable.
The common default position Staff developed for all three utilities is that all existing
PURPA contracts are assumed to be renewed throughout the planning horizon,unless utilities
have received information from QFs that contracts will not be renewed.Staff believes that
almost all PURPA contracts will seek renewals and will be "available"to serve the Company's
load for three reasons.First,utilities are mandated by PURPA to take energy produced by a
facility determined to be a QF.18 C.F.R.§292.303.Second,since these facilities are already
"existing"and currentlyin operation the roadblocks to establishinga renewal contract are
minimal.Third,a total of 26 projects across three utilities were scheduled to expire in 2019 and
2020.Onlytwo of them have expired without establishing a renewal.In every case,every
facility continuing operation after its contract expired has established another contract with the
same utility.
The Company assumes all PURPA contracts will renew except for wind PURPA
contracts,given the high cost of repowering wind facilities,reductions and/or elimination of tax
credits,current integration costs for wind,and the fact that none of the Company's wind QFs
have requested or entered replacement energy sales agreements.Staff believes the rationale
behind the assumption is reasonable.
Non-PURPA Contract Renewals
In the proposed L&R,the Company assumes all power purchase agreements ("PPA")
will renew,except for wind PPAs.Through a teleconference meeting with Staff on July 9,2021,
the Company confirmed that the renewal of non-PUPRA PPAs was incorrect in the proposed
REDACTED STAFF COMMENTS 7 JULY 21,2021
L&R and should be corrected.Staff supports this correction because project owners can sell
power to any buyer through competitive bidding once capacity is no longer under contract.
Therefore,Staff recommends that all PPAs expire in the L&R on their actual expiration dates.6
Contract Changes Since Developmentofthe L&R
Since the preparation of the L&R in the Application,there have been several PURPA
contract changes.See Response to Staff's Production Request No.7.The followingPURPA
contracts in Table No.I have been terminated or expired without a replacement contract.
Table No.1:Termination or Expirationof PURPA Contracts
Project Resource Type Nameplate Capacity (MW)
Bettencourt Dry Creek Biofactory Biomass 2.25
Big Sky West Dairy Digester Biomass 1.5
Double A Digester Biomass 4.5
Rock Creek Dairy Biomass 4
Kasel and Witherspoon Hydro 0.9
Idaho Power has also added the followingPURPA QFs in Table No.2 since the
development of the L&R.
Table No.2:New PURPA Contracts
Project Resource Type Nameplate Capacity (MW)
Durkee Solar Solar 3
Coleman Hydro Hydro 0.8
On December 24,2019,Jackpot Solar,a non-PURPA PPA,was approved by the
Commission in Order No.34515.Staff believes this PPA should be included in the L&R to
accurately reflect resources in the Company's system.
6 This adjustment alone may not have an impact on the first deficit date,because the PPAs'expiration dates are farbeyondtheproposedfirstdeficitdateof2028.For example,Raft RiverPPA expires April 2033,and Neal Hot SpringsPPAexpiresNovember2037.See IPC-E-19-19,Second Amended 2019 IRP,p 43.However,this adjustment insynergywithotheradjustmentsmentionedinthecommentsmayleadtoafirstdeficitdatedifferentthan2028.
REDACTED STAFF COMMENTS 8 JULY 21,2021
Staff recommends that the Company update the L&R to reflect the PURPA and non-
PURPA contracts mentioned above.
Company-ownedResources
Valmy Unit 2 is assumed to retire at the end of 2025 in the L&R,and Staff believes this
is a reasonable assumption.Valmy Unit 2 started operation in 1985 with a 50-year useful life.
However,in the Settlement of IPC-E-16-24,the parties agreed Idaho Power will negotiate with
co-owner NV Energy -using prudent and commercially reasonable efforts -to accomplish a
permanent end to coal-burning operations of Valmy Unit 1 by December 31,2019,and of Valmy
Unit 2 by December 31,2025.Or,alternatively,the parties agreed that Idaho Power will use
prudent and commercially reasonable efforts to end its participation in the operation of Valmy
Unit 1 by December 31,2019,and Valmy Unit 2 by December 31,2025.The Settlement was
approved in Order No.33771.Therefore,Staff believes it is reasonable to reflect retirement of
Valmy Unit 2 in the J&R based on the approved Settlement.
Non-owned Reserves
Non-owned reserves represent capacity sales through an Open Access Transmission
Tariff to wholesale customers in a utility'sBalancing Authority Area for which a utility is
obligated to provide reserves.Staff believes existing non-owned reserve sales are included
throughout the planning horizon,unless utilities are informed by the transmission customer of
future changes.The Company confirmed that the non-owned reserves were included in its 15
percent planning margin in the proposed L&R.See Case No.IPC-E-19-19,Idaho Power's Reply
Comments at 71.Staff believes it is reasonable.The 2021 IRP has used a Loss of Load
Expectation-derived method to determine the planning margin,which may affect how non-
owned reserves will be determined in the future.Staff will evaluate the method in the 202 l IRP
review and the subsequent capacity deficiency date filing.
Capacity Contribution ofResources
It is critical that capacity values of various resources reflect their actual generation
capability at system peak so that the first deficit date is calculated accurately.Staff identified
that the capacity contribution of Valmy Unit 2 and Bridger units should be updated.In addition,
REDACTED STAFF COMMENTS 9 JULY 21,2021
the new method for determining the capacity contribution at peak for solar,wind,and demand
response driving needs for resources identified in the NOI is a new method being developedin
the 2021 IRP,not the 2019 IRP,and therefore Staff believes it should be evaluated as part of the
2021 IRP and the subsequent deficiency date filing.
The proposed L&R shows that the capacity value of Valmy Unit 2 is 136 MW.However,
the correct capacity value should be 134 MW.See Response to Staff's Production Request No.13.
The proposed L&R also shows that the capacity value of Bridger is 703 MW.However,the
correct capacity value should be 708 MW.See Response to Staff's Production Request No.14.
The ELCC method used to determine the capacity contribution at system peak for solar,
wind,and demand response-as well as the amount of planning margin used to adjust load-is a
significant departure from past IRP practice.The new method has not been fully vetted in the
2021 IRP,and it is impractical to evaluate them outside of the context of a fully completed 2021
IRP.Until the 2021 IRP has been gone through its full cycle,Staff cannot with any certainty
determine that the methods and the resulting impacts are valid.
STAFF RECOMMENDATIONS
Based on its analysis,Staff recommends the Company update the L&R and the resulting
capacity deficiency date by incorporating the followingchanges:
Utilize the most recent load forecast developed by the Company;
Reduce the amount of Market Purchases from southern pathwavs by 310 MW and
only include 50 MW starting in 2021;
Allow non-PURPA PPAs to expire on their actual expiration dates;
Reflect contract changes since the preparation of the L&R,which include PURPA
contract updates identified in Response to Staff's Production Request No.7 and
approval of the Jackpot Solar contract;and
Correct the capacity value of Valmy Unit 2 and Bridger.
If Staff's recommendations are authorized by the Commission,Staff proposes to update
published rates on the Commission's website after the Company files an updated L&R and
capacity deficiency date through a compliance filing.Furthermore,Staff recommends that a
generic docket be opened to determine when the biannual deficiency date should be filed (i.e.,
after the filing of an IRP,after the acknowledgementof an IRP,or at other times.).This will
REDACTED STAFF COMMENTS 10 JULY 21,2021
allow the utilities,other parties,and Staff to weigh the pros and cons of different filing
schedules.
Respectfully submitted this 3 /day of July2021.
Matt Hunter
Deputy AttorneyGeneral
Technical Staff:Yao Yin
Kevin Keyt
i:umisc/comments/ipce21.9mhyyksk comments
REDACTED STAFF COMMENTS 11 JULY 21,2021
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n
e
w
e
d
th
r
o
u
g
h
o
u
t
th
e
pl
a
n
n
i
n
g
ho
r
i
z
o
n
,
un
l
e
s
s
ex
i
s
t
i
n
g
cu
s
t
o
m
e
r
an
d
hi
s
t
o
r
i
c
a
l
da
t
a
sh
o
w
s
ut
i
l
i
t
i
e
s
ha
v
e
re
c
e
i
v
e
d
in
f
o
r
m
a
t
i
o
n
th
a
t
su
c
h
th
e
y
pr
o
v
i
d
e
in
t
e
r
r
u
p
t
i
b
l
e
se
r
v
i
c
e
s
as
lo
n
g
co
n
t
r
a
c
t
s
wi
l
l
no
t
be
re
n
e
w
e
d
.
th
e
y
re
m
a
i
n
a
lo
a
d
cu
s
t
o
m
e
r
.
Pl
a
n
n
i
n
g
Re
s
e
r
v
e
No
t
As
s
o
c
i
a
t
e
d
In
t
e
r
r
u
p
t
i
b
l
e
ca
p
a
c
i
t
y
is
fi
r
m
an
d
do
no
t
re
q
u
i
r
e
In
t
e
r
r
u
p
t
i
b
l
e
ca
p
a
c
i
t
y
co
n
t
r
a
c
t
s
ar
e
fi
r
m
.
Wi
t
h
In
t
e
r
r
u
p
t
i
b
l
e
Lo
a
d
Co
n
t
r
a
c
t
s
pl
a
n
n
i
n
g
re
s
e
r
v
e
s
.
De
m
a
n
d
Re
s
p
o
n
s
e
Ex
i
s
t
i
n
g
DR
pr
o
g
r
a
m
s
ar
e
in
c
l
u
d
e
d
at
cu
r
r
e
n
t
Po
t
e
n
t
i
a
l
ne
w
DR
pr
o
g
r
a
m
s
ar
e
pl
a
n
n
e
d
as
le
v
e
l
s
,
bu
t
ca
n
re
f
l
e
c
t
fo
r
e
c
a
s
t
e
d
ch
a
n
g
e
s
in
th
e
al
t
e
r
n
a
t
i
v
e
s
to
me
e
t
fu
t
u
r
e
ca
p
a
c
i
t
y
de
f
i
c
i
t
s
am
o
u
n
t
ba
s
e
d
on
fo
r
e
c
a
s
t
le
v
e
l
s
of
pa
r
t
i
c
i
p
a
t
i
o
n
or
an
d
co
n
s
t
r
a
i
n
e
d
by
fu
t
u
r
e
lo
a
d
.
Un
t
i
l
kn
o
w
n
ch
a
n
g
e
s
to
pr
o
g
r
a
m
.
Fu
t
u
r
e
ne
w
DR
pr
o
g
r
a
m
s
ar
e
im
p
l
e
m
e
n
t
e
d
,
am
o
u
n
t
of
pr
o
g
r
a
m
s
ar
e
no
t
in
c
l
u
d
e
d
.
ca
p
a
c
i
t
y
is
sp
e
c
u
l
a
t
i
v
e
.
Or
d
e
r
No
.
33
1
5
9
al
l
o
w
s
cu
r
r
e
n
t
DR
pa
r
t
i
c
i
p
a
t
i
o
n
to
be
us
e
d
as
a
re
a
s
o
n
a
b
l
e
es
t
i
m
a
t
i
o
n
of
pa
r
t
i
c
i
p
a
t
i
o
n
in
t
o
th
e
fu
t
u
r
e
fo
r
ex
i
s
t
i
n
g
pr
o
g
r
a
m
s
.
At
t
a
c
h
m
e
n
t
A
Ca
s
e
No
.
IP
C
-
E
-
2
1
-
0
9
St
a
f
f
Co
m
m
e
n
t
s
07
/
2
1
/
2
1
Pa
g
e
1
of
2
En
e
r
g
y
Ef
f
i
c
i
e
n
c
y
Al
l
co
s
t
-
e
f
f
e
c
t
i
v
e
EE
is
in
c
l
u
d
e
d
ba
s
e
d
on
Ut
i
l
i
t
i
e
s
ar
e
ex
p
e
c
t
e
d
to
pu
r
s
u
e
al
l
co
s
t
-
fo
r
e
c
a
s
t
e
d
pa
r
t
i
c
i
p
a
t
i
o
n
.
ef
f
e
c
t
i
v
e
EE
.
Se
e
Or
d
e
r
No
s
.
32
4
2
6
an
d
33
9
1
7
.
Am
o
u
n
t
of
EE
is
no
t
co
n
s
t
r
a
i
n
e
d
by
fu
t
u
r
e
lo
a
d
.
Pr
i
v
a
t
e
Ge
n
e
r
a
t
i
o
n
:
Ne
t
Me
t
e
r
i
n
g
Ne
t
me
t
e
r
i
n
g
in
c
l
u
d
e
d
at
cu
r
r
e
n
t
le
v
e
l
s
bu
t
ca
n
Ca
p
a
c
i
t
y
on
th
e
sy
s
t
e
m
is
no
t
co
n
s
t
r
a
i
n
e
d
by
re
f
l
e
c
t
fo
r
e
c
a
s
t
e
d
ch
a
n
g
e
s
in
th
e
am
o
u
n
t
ba
s
e
d
on
lo
a
d
.
Am
o
u
n
t
de
p
e
n
d
s
on
cu
s
t
o
m
e
r
s
th
a
t
fo
r
e
c
a
s
t
le
v
e
l
s
of
pa
r
t
i
c
i
p
a
t
i
o
n
or
kn
o
w
n
ch
a
n
g
e
s
.
ch
o
o
s
e
to
ma
k
e
th
e
in
v
e
s
t
m
e
n
t
.
Ca
p
a
c
i
t
y
is
sh
o
w
n
as
an
ad
j
u
s
t
m
e
n
t
to
lo
a
d
.
Pr
i
v
a
t
e
Ge
n
e
r
a
t
i
o
n
:
La
r
g
e
Pr
i
v
a
t
e
ge
n
e
r
a
t
i
o
n
in
c
l
u
d
e
d
at
ex
i
s
t
i
n
g
le
v
e
l
s
wi
t
h
Pr
i
v
a
t
e
ge
n
e
r
a
t
i
o
n
ar
e
al
s
o
la
r
g
e
cu
s
t
o
m
e
r
s
Cu
s
t
o
m
e
r
s
Ge
n
e
r
a
t
i
n
g
In
t
o
Ow
n
fu
t
u
r
e
am
o
u
n
t
s
ba
s
e
d
on
kn
o
w
n
ch
a
n
g
e
s
.
Ca
p
a
c
i
t
y
an
d
ex
p
e
c
t
e
d
to
se
l
f
-
g
e
n
e
r
a
t
e
as
lo
n
g
as
Lo
a
d
is
sh
o
w
n
as
an
ad
j
u
s
t
m
e
n
t
to
lo
a
d
.
cu
s
t
o
m
e
r
is
in
c
l
u
d
e
d
as
lo
a
d
.
Fr
o
n
t
Of
f
i
c
e
Tr
a
n
s
a
c
t
i
o
n
/
Ma
r
k
e
t
pu
r
c
h
a
s
e
s
in
c
l
u
d
e
d
in
th
e
Lo
a
d
an
d
Or
d
e
r
No
.
33
4
2
5
st
a
t
e
s
th
a
t
a
ut
i
l
i
t
y
'
s
im
p
o
r
t
Ma
r
k
e
t
Pu
r
c
h
a
s
e
s
Re
s
o
u
r
c
e
Ba
l
a
n
c
e
.
Bo
t
h
ex
i
s
t
i
n
g
tr
a
n
s
m
i
s
s
i
o
n
ca
p
a
b
i
l
i
t
y
-
it
s
ab
i
l
i
t
y
to
ma
k
e
sh
o
r
t
-
t
e
r
m
ca
p
a
c
i
t
y
an
d
ma
r
k
e
t
av
a
i
l
a
b
i
l
i
t
y
sh
o
u
l
d
be
pu
r
c
h
a
s
e
s
us
i
n
g
it
s
tr
a
n
s
m
i
s
s
i
o
n
ca
p
a
c
i
t
y
-
co
n
s
i
d
e
r
e
d
.
sh
o
u
l
d
be
in
c
l
u
d
e
d
in
th
e
L&
R
.
Lo
n
g
-
T
e
r
m
Wh
o
l
e
s
a
l
e
Sa
l
e
s
Ex
i
s
t
i
n
g
ob
l
i
g
a
t
i
o
n
s
ex
p
i
r
e
at
th
e
en
d
of
co
n
t
r
a
c
t
s
.
Ut
i
l
i
t
i
e
s
pl
a
n
re
s
o
u
r
c
e
s
to
me
e
t
na
t
i
v
e
lo
a
d
,
Ob
l
i
g
a
t
i
o
n
s
No
ne
w
,
fo
r
e
c
a
s
t
e
d
co
n
t
r
a
c
t
s
ar
e
in
c
l
u
d
e
d
.
wh
i
l
e
on
l
y
se
l
l
i
n
g
in
t
o
th
e
wh
o
l
e
s
a
l
e
ma
r
k
e
t
op
p
o
r
t
u
n
i
s
t
i
c
a
l
l
y
.
No
n
-
O
w
n
e
d
Re
s
e
r
v
e
Sa
l
e
s
Ex
i
s
t
i
n
g
no
n
-
o
w
n
e
d
re
s
e
r
v
e
sa
l
e
s
ar
e
in
c
l
u
d
e
d
Th
e
s
e
ty
p
e
s
of
re
s
e
r
v
e
sa
l
e
s
wi
l
l
co
n
t
i
n
u
e
to
th
r
o
u
g
h
o
u
t
th
e
pl
a
n
n
i
n
g
ho
r
i
z
o
n
,
un
l
e
s
s
ut
i
l
i
t
i
e
s
ar
e
ex
i
s
t
si
n
c
e
ut
i
l
i
t
i
e
s
ar
e
re
q
u
i
r
e
d
to
ba
l
a
n
c
e
in
f
o
r
m
e
d
by
th
e
tr
a
n
s
m
i
s
s
i
o
n
cu
s
t
o
m
e
r
of
fu
t
u
r
e
th
e
ge
n
e
r
a
t
i
o
n
an
d
lo
a
d
fr
o
m
th
e
s
e
ty
p
e
s
of
ch
a
n
g
e
s
.
tr
a
n
s
m
i
s
s
i
o
n
cu
s
t
o
m
e
r
s
(e
.
g
.
mu
n
i
c
i
p
a
l
s
an
d
co
-
o
p
s
)
At
t
a
c
h
m
e
n
t
A
Ca
s
e
No
.
IP
C
-
E
-
2
1
-
0
9
St
a
f
f
Co
m
m
e
n
t
s
07
/
2
1
/
2
1
Pa
g
e
2
of
2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF JULY 2021,SERVEDTHEFOREGOINGREDACTEDCOMMENTSOFTHECOMMISSIONSTAFF,INCASENO.IPC-E-21-09,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
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PO BOX 70 P.O.BOX 70
BOISE ID 83707-0070 BOISE,ID 83707
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[e-mail] [e-mail]
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C TOM ARKOOSH
ARKOOSH LAW OFFICES
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E-MAIL:[e-mail]
erin.cecil arkoosh.com
SECRET RY
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