20220509Withdrawal of Application.pdf

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AnD COIPComoanY
May 9, 2022
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 83720-007 4
Re Case No. IPC-E-2141
ln The Matter Of ldaho Power Company's Application For Authority to
Proceed with Resource Procurements to Meet ldentified Capacity
Deficiencies in 2023, 2024, and 2025 to Ensure Adequate, Reliable, and
Fair-Priced Service to its Customers
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Withdrawl of Application in
the above entitled matter. lf you have any questions about the aftached document, please
do not hesitate to contact me.
Very truly yours,
DONOVAN WALKER
Lead Couneel
dwal ker@ida hopower.com
DEW:cd
Enclosures
Donovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa [e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UT!LIT!ES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO PROCEED WITH
RESOURCE PROCUREMENTS TO MEET
IDENTIFIED CAPACITY DEFICIENCIES IN
2023,2024, AND 2025 TO ENSURE
ADEQUATE, RELIABLE, AND FAIR-PRICED
SERVICE TO ITS CUSTOMERS.
CASE NO. IPC-E-2141
WTHDRAWAL OF
APPLICATION
ldaho Power Company ("ldaho Powef or "Company"), in accordance with RP 68,
hereby respectfully gives Notice of the Withdrawal of the Company's Application
previously filed in this matter. "A party desiring to withdraw a pleading must file a notice
of withdrawal of the pleading with the Commission and serve all parties with it. Unless
otherwise ordered by the Commission, the notice is effective fourteen (14) days after
filing.' RP 68.
The Application in this matter,IPC-E-21.41, requests that the Commission issue
an order: (1) eliminating the IPUC requirement to comply with the Public Utility
Commission of Oregon ("OPUC') resource procurement rules in favor of a competitive,
but expedited process; (2) authorizing Idaho Power to move foruard expeditiously with
IDAHO POWER COMPANY'S WTHDRAWAL OF APPLICATION - 1
resource procurements to meet identified generation resource needs in 2023,2024, and
2025; and (3) affirming support and the continuation of the state of ldaho's system of
public utility regulation under which the interests of customers are best served by a
vertically integrated electric utility maintaining ownership of the necessary generation,
transmission and distribution utility functions, with limited exceptions. Application p 1.
After the filing of the Application in this mafter, ldaho Power filed an Application for
a Certificate of Public Convenience and Necessity (CPCN') to acquire 120 MW of
dispatchable energy storage necessary to meet the identified capacity deficiency in2O23,
and required to provide safe, reliable service to its customers. Case No. !PC-E-22-13,
Application p 1. The requested relief in IPC-E-2141 related to moving forward
expeditiously with resource procurements necessary to meet capacity deficits starting in
2023, and the consideration of utility ownership of such facilities has been made moot by
the subsequentfiling of the requestfora CPCN in IPC-E-22-13. AIlof the related issues
raised in the IPC-E-2141 case are properly raised and considered in the IPC-E-22-13
case. Out of consideration for the efficient use of everyone's time, effort, energy, and
resour@s ldaho Power proposes withdrawal of the IPC-E-2141 Application. This
withdrawal should not result in any prejudice, hardship, or inconvenience of any Party, as
al! the related and relevant issues are properly before the Commission in the IPC-E-Z2-
13 mafter.
Additionally, regarding the OPUC resource procurement rules, OAR 860-089-0010
et seq., the OPUC considered and ruled upon ldaho Power's requested waiver at its
Public Meeting on March 8, 2022. The OPUC adopted an OPUC Staff Memo
recommending denialof the Company's requestfora broad waiver. However, in its memo
OPUC Staff suggested that ldaho Powerconsiderthe OPUC Resource Procurement Rule
exception process for the resource acquisitions needed to meet the shortfalls identified in
IDAHO POWER COMPANY'S WTHDRAWAL OF APPLICATION - 2
the Company's request. ldaho Powerfiled an exception requestwith the OPUC on March
18,2022, and is currently compliant with the OPUC resource acquisition process.
Consequently, ldaho Power now hereby provides this notice of the withdrawal of
its Application in Case No. IPC-E-2141 pursuant to RP 68 and looks forward to
addressing the important issues raised in this matter as part of its CPCN filing in Case
No. IPC-E-22-13.
Respectfully submitted this 9th day of May 2022 at Boise, ldaho.
Mzdat4-
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S WTHDRAWAL OF APPLICATION - 3
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 9th day of May 2022,1 served a true and correct
copy of the within and foregoing ldaho Power Company's Withdrawalof Application upon
the following named parties by the method indicated below, and addressed to the
following:
Dayn Hardie
ldaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, !D 83703
ldaHydro
C. Tom Arkoosh
Amber Dresslar
ARKOOSH LAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, lD 83701
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
710 North 6th Street
Boise, lD 83701
Greg M. Adams
RICHARDSON ADAMS, PLLC
515 N.27th Street
Boise, ldaho 83702
Spencer Gray
NIPPC
P.O. Box 504
Mercer lsland, WA 98040
Emailed to:
davn. hardie@puc. idaho.oov
Emailed to:
peter@ richardsonadams.com
Emailed to:
d [e-mail]
Emailed to:
[e-mail]
amber.d ressla r@a rkoosh.com
e rin. cecil@a rkoosh.com
Emailed to:
botto@ ida hoconservation. orq
esperrv@ida hoconse rvation.orq
Emailed to:
q [e-mail]
Emailed to:
[e-mail]
IDAHO POWER COMPANY'S WTHDRAWAL OF APPLICATION - 4
Abigail R. Germaine
Elam & Burke, P.A.
251 E. Front St., Suite 300
P.O. Box 1539
Boise, lD 83701
Scott Miller
Western Power Trading Forum
1540 River Park Dr., Suite 211
Sacramento, CA 95815
Max Greene
Renewable Northwest
421 SW 6th Ave., Suite 1400
Portland, OR 97204
Jim Kreider
STOP BB2H Coalition
60366 Marvin Road
La Grande, OR 97850
Jack Van Valkenburgh
Van Valkenburgh Law, PLLC
P.O. Box 531
Boise, lD 83701
Ed Jewell
Boise City Attorneys Office
P.O. Box 500
Boise, lD 83701
\A/il Gehl
Boise City Dept. of Public Works
P.O. Box 500
Boise, lD 83701
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
[e-mail]
Emailed to:
iack@va nva lkenbu ro h law.com
Emailed to:
[e-mail]
bo isecitvatto rnev@citvofbo ise. o rq
Emailed to:
wqe h l@citvofbo ise. o ro
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S WTHDRAWAL OF APPLICATION - 5