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HomeMy WebLinkAbout20211006Reply Comments.pdf3Em. LISA D. NORDSTROT Lead Counsel lnordstrom@idahooower.com ,-1 =r.ftt/tr}ni'iL-tJ!-l { t-t/ ?il:t 0cT -6 PH 12: h5 s5i0l{ 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 X;!.(^t t.*, 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 ) ) ) ) ) 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. X*!.ff"t t.^, 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