HomeMy WebLinkAbout20211006Reply Comments.pdf3Em.
LISA D. NORDSTROT
Lead Counsel
lnordstrom@idahooower.com
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October 6,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. IPC-E-21-13
ln the Matter of ldaho Power Company's Application for Approval of lts Load
Curtailment and lnterruption Plan
Dear Ms. Noriyuki
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho
Power Company's Reply Comments.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
An DACORPComtrrny
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Lisa D. Nordstrom
LDN:sg
Enclosure
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (837021
P.O. Box 70
Boise, ldaho 83707
Telephone: (208) 388-5825
Facsimile: (208) 388€936
lnordstrom@ idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF ITS LOAD CURTAILMENT
AND INTERRUPTION PLAN
cAsE NO. !PC-E-21-13
IDAHO POWER COMPANY'S
REPLY COMMENTS
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Idaho Power Company ("ldaho Powef or "Company"), respectfully submits the
following Reply Comments pursuant to Order No. 35149 in response to Comments of the
ldaho Public Utilities Commission ('Commission') Staff dated September 22,2021.
I. BACKGROUND
On May 11,2021, ldaho Power applied for approval of its 2021 Load Curtailment
and lnterruption Plan and for authority to update its Electric Service Rule J, Continuity,
Curtailment, and lnterruption of Electric Service ("Rule J") (the "Application'). The
Application summarized the history of the Company's curtailment plan and laid out its
proposed 2021 Load Curtailment and lnterruption Plan ("LC!P") and the associated
updates to Rule J intended to increase transparency for customers and stakeholders. The
Company's filing was made pursuant to ldaho Code S 61-531, Plan for Curtailment of
Electric or Gas Consumption, which requires allsuppliers of electric power and energy to
IDAHO POVVER COMPANY'S REPLY COMMENTS - 1
file a plan for curtailment with the Commission.
On September 22,2021, Commission Staff filed Comments in this matter. Staffs
review found the LCIP to be in compliance with Idaho Code S 61-532 and recommended
approval of the Company's Application as filed. Staff further recommended the
Commission direct the Company to meet with Staff and interested parties to gather
feedback, and based on that feedback, update notification procedures related to the LCIP
and contained within the Company's Emergency Response Communication Plan
("ERCP").
!I. IDAHO POWER'S REPLY
ldaho Power appreciates Staffs recommendation that the Commission approve
the Company's Application as filed. These comments respond to Staffs additional
recommendations for the Company to (1) hold a meeting with Staff, the Idaho Office of
Emergency Management ('OEM"), and Emergency Support Function #12 ("Energy") to
develop a plan to clearly define communication requirements to be exercised in the event
of an emergency or disaster, and (2) meet with Staff, electric providing municipalities,
electric cooperatives, Demand-Side Management ('DSM') participants, and other
stakeholders to improve upon the plan's notification procedures to minimize stakeholder
impact of future curtailment.
A. Gommunication Requirements and Protocols
\Mth wildfire risks, resource adequacy concerns, climate change and other factors
prominently impacting portions of the Pacific Northwest and Western lnterconnection,
clear communication processes among the Company and state agencies are essential.
ldaho Power commits to meet with the identified stakeholders to more clearly define
IDAHO POWER COMPANY'S REPLY COMMENTS -2
communacation requirements and protocols. The Company will rely on this feedback to
ensure its ERCP contains the right level of detail to enhance its effectiveness. The
Company expects that, pending availability of the other participants, that it would be able
to initiate these discussions by the end of 2021 and incorporate any enhancements into
its annual internal ERCP review and update in early 2022.
B. lmprovements to Notification Procedures
The Company also agrees with Staffs recommendation to meet with Staff, electric
providing municipalities, electric cooperatives, DSM participants, and other stakeholders
to improve upon the LCIP's notification procedures to minimize stakeholder impact of
future curtailment. One of the primary goals of the LCIP is to minimize the impact of
curtailments and interruptions on customers. Notification to stakeholders of impending
system events as early as practicable is one of the ways the Company can achieve this
goal. The Company anticipates holding discussions with the identified stakeholders in
advance ofthe 2022 summer season.
ilt. coNcLusroN
ldaho Power respectfully requests that the Commission issue an order accepting
the Company's LCIP and Rule J revisions.
Respectfully submitted this 6th day of October 2021.
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LISA NORSTROM
Attorney for ldaho Power Company
IDAHO PO\A/ER COMPANY'S REPLY COMMENTS.3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day of October, 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:
Commission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HA\AK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
Pocatello, ldaho 83205
Hand Delivered_U.S. Mail
_Overnight Mail
_FAXX Emai! davn.hardie@puc.idaho.qov
FTP Site
Hand Delivered_U.S. Mail
_Overnight Mail_FAXX Email elo@echohawk.com
FTP Site
.:Umrk &r"t.
Stacy Gust
Regulatory Administrative Assistant
]DAHO PO\A'ER COMPANY'S REPLY COMMENTS.4