20220608Replacement Reply Comments - Redacted.pdf

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An TDACORP Company
DONOVAN WALKER
Lead Counsel
dwa I [e-mail]
June 8,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Sulte 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-21-42
ln the Matter of ldaho Power Company's Application for Approval of Specia!
Contract and Tariff Schedule 33 to Provide Electric Service to Brisbie, LLC's
Data Center Facility
Dear Ms. Noriyuki:
Aftached for electronic filing, please find ldaho Power Company's Redacted
Replacement Reply Comments in the above matter. Please note that language was not
added to or modified in these Reply Comments; the only change is the leve! of
confidentiality.
The confidential version of ldaho Power Company's Replacement Reply
Comments will be sent in a separate encrypted email to the parties who sign the
Protective Agreement in this matter.
Please feel free to contact me directly with any questions you might have about
this filing.
Very truly yours,
Mzd*4
Donovan E. Walker
DEW:sg
Enclosures
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]
dwalker@ idahopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COM PANY'S APPLICATION FOR
APPROVAL OF SPECIAL CONTRACT AND
TARIFF SCHEDULE 33 TO PROVIDE
ELECTRIC SERVICE TO BRISBIE, LLC'S
DATA CENTER FACILIry.
CASE NO. |PC-E-2142
IDAHO POWER COMPANY'S
REDACTED REPLACEMENT
REPLY COMMENTS
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ldaho Power Company ("ldaho Powe/'or "Company") hereby respectfully submits
the following Reply Comments in response to Comments filed by Staff ("Staff') of the
ldaho Public Utilities Commission ("Commission") in the matter of the Company's
application for approval of a specia! contract and tariff schedule 33 to provide electric
service to Brisbie, LLC ("Brisbie").
The Company is grateful for the opportunity to offer Reply Comments in this case
and would Iike to extend special appreciation to Staff for their time and thoughtfulness in
reviewing the Company's Application on an accelerated timeline.
ldaho Power supports Staffs recommendation to approve the Brisbie Special
Contract-+r Energy Services Agreement ("ESA'). However, the Company respectfully
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 1
disagrees with Staffs proposed ESA modifications and the rationale to support them. The
Company reviews each of Staffs 11 proposed recommendations in detail below and is
confident that some of the recommendations may no longer be necessary after
considering the Company's Reply.
ldaho Power recognizes that the Brisbie ESA constitutes a new frarnework--one
that is necessary to incorporate the renewable resources that will support Brisbie's energy
requirements. This framework is distinctly different from traditional Specia! Contracts the
Commission has previously authorized. The framework is also distinctly different from
projects under the Public Utility Regulatory Policies Act of 1978 CPURPA") in that the
customer is bringing both load and resources. While the matching of Brisbie's load to its
resources may not be perfect hour-to-hour, the structure of the Brisbie ESA as proposed
incentivizes the parties to right-size resources and minimize the imbalance of renewable
resource generation to load. Further, the agreement does not serve as a source of
revenue for excess generation for Brisbie and Brisbie's rate structure covers the cost of
balancing associated load and resources.
The proposed Brisbie ESA, and the associated pricing and compensation structure
therein, is the result of approximately two years of negotiation between ldaho Power and
Brisbie. During negotiations, both the Company and Brisbie agreed that the top priority of
the Special Contract was to ensure fair treatment of all parties-Brisbie, ldaho Power,
and all other customers.
A key objective of Brisbie's pricing and compensation structure was not to establish
winnerc and losers, but, rather, ensure that the broader customer base would be
protected without penalizing Brisbie. ldaho Power's no-harm analysis validates that the
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 2
pricing and compensation structure as proposed in the ESA has accomplished those
objectives and does not shift costs to other ldaho Power customerc. ln fact, the no-harm
analysis shows that the Brisbie arrangement results in a benefit to other customers over
the life of the contract. lf Staffs recommendations to modiff the credit components were
enacted, the benefits to other customers would grow while penalizing Brisbie in equal
measure.
Given the extensive effort that ldaho Power and Brisbie undertook to ensure just
and reasonable pricing and credit components, the Company respectfully requests that
the Commission approve the Brisbie ESA with acceptance of certain Staff
recommendations, as explained in the sections below.
I. BACKGROUND
On December 22,2021,|daho Power filed its application with the Commission for
approva! of a new Specia! Contract for Brisbie's data center facility, which will require
electric service in excess of 20,000 kilowatts ('kW') or 20 megawatts ('MW'). Per the
Commission's Order No. 33038 at 11,'each special contract customer is considered a
separate class with different conditions and contract terms affecting their rates..."
Differentiation between classes of customers is permissible when it is based on cost of
service, quantity of electricity used, differences in conditions of service, or the time,
nature, and pattern of the customers'use.1
ln addition to its large load service requirements in excess of 20 MW, Brisbie has
a sustainability objective to support 100 percent of its operations with new, incremental
l Building Contractors Assocratrbn of Soufhwestem ldaho, lnc. v. ldaho Public Utilities Comm'n,128 ldaho
534, 539, 916 P.2d 1259,'1264 (1996); Agricultural Prcducts Corp.v. Utah Power & Light Co., 98 ldaho
23, 557 P .2d 617 (1 976); and ldaho State Homebuilders v. Washington Water Power, 107 ldaho 41 5,
420, 690 P.2d 350, 355 (1984).
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 3
renewable resources added to ldaho Powefs system. As proposed in the Company's
Application, ldaho Power and Brisbie negotiated pricing associated with retail electric
service from the Company, cost and credit components associated with the renewable
resources that will support Brisbie's operations, and the terms and conditions governing
the structure of this new arrangement. To validate the proposed pricing structure, ldaho
Power conducted an analysis to ensure that the provisions of the ESA would not shift
costs to other ldaho Power customers.
The Brisbie ESA is consistent with and mirrors the regulatory framework set forth
in the Clean Energy Your Way ('CEYW') - Construction offering, as outlined in ldaho
Power's Application with the Commission to establish new clean energy offerings for
customers under the CEYW Program (Case No. IPC-E-2140).ln that Application, ldaho
Power states its belief that it can work with existing or future Specia! Contract customers
to integrate renewables into their service agreement with the Company. To that end, the
Brisbie Special Contract is the first representation of the CEYW - Construction option.
ln addition to the ESA and tariff schedule 33, ldaho Power requested explicit
approval of several specific components of a regulatory framework designed to implement
and administer Brisbie's Special Contract with its supporting renewables: 11) authority to
procure renewable resources for the purpose of supporting Brisbie's energy use under a
standard procurement agreement, (2) the cost basis and pricing structure for the supply
of retail electric service by ldaho Power, (3) the compensation structure for excess
renewable energy generation and capacity contribution of the renewable resources, (4)
authorization to treat bill credits provided to Brisbie under the proposed compensation
structure as prudently incurred expenses for ratemaking purposes, and (5) the cost
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 4
recovery mechanisms necessary to protect existing ldaho Power customers from cost-
shifting and ensure ldaho Power has an opportunity to recovery its cost of service.
On April 27,2022, Staff submitted Comments in this case recommending approva!
of Brisbie's ESA contingent on severa! proposed modifications. Clean Energy
Opportunities for ldaho, the only intervenor in this case, did not submit comments. The
Company did not receive public comments on its Application.
II. REPLY COMMENTS
ln its Comments, Staff recommends approval of the Brisbie ESA contingent on
several modifications. Considering the complexity of the Brisbie ESA, ldaho Power was
encouraged that Staff and the Company are aligned on the majority of the components
and constructs in the Brisbie arrangement.
Staff is supportive of the pricing components related to energy service (that is, the
rates that Brisbie will pay for service from ldaho Power), the guarantees provided in each
Power Purchase Agreement ('PPA"), and accounting treatment in the Power Cost
Adjustment ('PCA"). But Staff proposes substantial revision to crediting components that
Brisbie wil! receive for the renewable resources to support their load.
Before addressing Staffs recommended modifications in detail, the Company
highlights the overarching goal of the Brisbie Specia! Contract to ensure that the intended
purpose of the arrangement is not overshadowed by the detailed mechanics of the
arrangement. As negotiated, the ESA is a framework to support 100 percent of Brisbie's
operations with renewable resources, and the ESA does so in a way that balances the
concern for other customers while still recognizing the costs and benefits Brisbie-and
their associated renewables-bring to ldaho Powe/s system.
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 5
ldaho Power sought a pricing framework that, to the extent possible and
reasonable, borrowed from previously approved constructs. For example, the two-block
pricing structure that includes embedded and marginal costs supported by Staff is
grounded in the structure of previously approved Special Contracts for Hoku Materials
and J.R. Simplot Company's Caldwell Facility.2
For new components of this ESA-namely, compensation for the renewable
resources-ldaho Power sought to establish crediting mechanisms that would reasonably
and fairly reflect the energy and capacity value of the new resources to ldaho Power's
system. The Company shares Staffs desire to apply some leve! of methodologica!
consistency when valuing energy and capacity on ldaho Power's system. However, in the
development of the proposed ESA, the Company was also mindful that the transaction
with Brisbie is dissimilar to power purchases under PURPA.
Unlike PURPA projects, the Brisbie-associated resources wil! be fully negotiated
additions to the Company's generation portfolio. These resources will be procured like
traditionalsystem resources (Brisbie's associated resources will either be secured with a
PPA or Company-owned) and distinctly different from PURPA projects, in which the
Company has limited to no negotiating power. Further, the Brisbie arrangement-and any
other CEYW - Construction arrangements-involves a customer that will be financially
supporting their accompanying renewable resources. Separating these renewable
resources from the customer that necessitated them is not a reasonable way to identiff
resource value. While certain aspects of PURPA pricing may be appropriately applied to
the Brisbie ESA and other CEYW - Construction agreements, Staffs proposed changes
2 Tatum Direct at 10.
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 6
to move the ESA compensation structure closer to a PURPA-like valuation methodology
are misapplied.
ln addition to assessing Brisbie's resources as PURPA projects, Staff has applied
a "virtual behind-the-mete/'framework to explain the relationship between Brisbie's load
and its supporting renewables. Staff at 7. ln Staffs framework, Brisbie's supporting
renewable resources create a "net load" shape for Brisbie - that is, a load shape reflecting
Brisbie's energy needs onoe renewable resource generation has been accounted for.
Staff notes that Brisbie's load is "less stable" as a result of the varying output of the
renewables. Staff at 10.
The Company considers this an incorrect framework that misconstrues the
fundamentalstructure of the Brisbie arrangement. To be clear, no aspect of Brisbie's load
is unstable-the customer is expected to have a 90 percent load factor. The renewable
resources to support Brisbie's load were specifically required to be system resources to
preventthe kind of load instability that Staff has referenced. ldaho Powerwill manage the
generation from the Brisbie-associated resources just as it does its other system
resources-and Brisbie will be served with electricity in the exact manner as al! other
customers. The resources to support Brisbie are not directly interconnected to serve
Brisbie. Considering the specific dynamics of the Brisbie ESA and other CEYW -
Construction arrangements, the treatment of and accounting for renewables under these
arrangements are most appropriately viewed as financial exchanges, not direct
exchanges of electrons.
The Company would like to reinforce that Brisbie is a customer with significant
load that is also bringing (and paying for) supporting resources. The combination of new
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 7
customer load and supporting renewable resource generation in no way acts like or
mirrors the characteristics of PURPA projects, which only include generation
interconnected to ldaho Power's system. Rather than viewing the Brisbie ESA in the
context of PURPA, the arrangement is best characterized as a novel and fair approach
to serving a stable, large load customer and supporting that customer's renewable
resource needs in a way that enhances ldaho Power's system to the benefit of all
customers.
III. RESPONSE TO STAFF'S RECOMMENDATIONS
Staffs final recommendations on page 20-21 include 11 specific proposals, some
of which involve overlapping topics. ldaho Power addresses each recommendation below
and has grouped the discussion by the relevant topic.
A. Pricinq Updates
Recommendation 7. ln its first recommendation, Staff proposes that all pricing
components of the Brisbie ESA stemming from the Company's lntegrated Resource Plan
('lRP') be filed in parallel with, or shortly following, submission of the lRP. ldaho Power
agrees and supports this recommendation. The Company envisions that it would submit
an advice filing to update the components of Brisbie's Schedule 33 that are related to the
IRP.
B. Excess Enersv Generation Credit
Staffs second and third recommendations address the credit to Brisbie for any
excess energy generation-that is, the amount ldaho Power would credit Brisbie for any
renewable resou rce generation
Recommendation 2. Staff proposes approving the method for calculating the
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 8
excess energy generation credit in the ESA but with "an additional 85% adjustment
consistent with Schedule 86." Staff at 20. ldaho Power respectfully disagrees with this
recommendation. ldaho Power's economic analysis of the Brisbie ESA as filed (i.e.,
without Staffs proposed additional adjustment) demonstrates there is no harm to ldaho
Power's other customers. lndeed, that analysis shows that the Brisbie ESA goes beyond
"no harm" and shows positive benefits to ldaho Power's other customers. Accordingly,
rather than protecting other customers from cost shifts, the proposed additional
adjustments to the excess energy component would increase the benefits other
customers would see at Brisbie's expense. As noted in the introduction to these Reply
Comments, ldaho Power's goal in negotiating the Brisbie ESA was to create a structure
that fairly balances Brisbie's sustainability and energy requirements against the need to
ensure no harm to other customers. lf the Commission accepts Staffs recommendation,
it risks disrupting the careful balance between these two principles.
Recommendation 3. Staff proposes that the be
recommendation and rationale for
I because Staff believes
inaccurate.
Yet, Staff also states that the
"Staff believes the proposed
Staff at 20. ldaho Power disagrees with Staffs
may be
is a good basis for
provides a
reasonable
Staff at 12.
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 9
Staff is also concerned that the Brisbie arrangement will create substantial excess
energy during some hours of day-relative to Brisbie's load-and that the Company may
overcompensate Brisbie in some hours if
I But this is an asymmetrical view that overlooks the possibility that,
ldaho Power cannot state with certainty whether any
As a result, the
Company believes that a reasonable
As proposed in the ESA, the forecast
(and the associated excess energy generation credit amounts for each hour) would be
updated every two years with the Company's IRP to ensure alignment with the most
current forecast of the Mid-C market and to eliminate out-year variation and escalation
that naturally occurs in a 2O-year forecast.
Further, the Company would not be able to implement an
per Staffs recommendation,
ln its negotiations with Brisbie, the Company
reviewed the potentialof a
The value of such predictability would be eliminated in I
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS.lO
G. Renewable Gapacitv Credit
Staffs Recommendations 4 through 7 alladdress the Renewable Capacity Credit.
Recommendation 4. Staff recommends that any renewable capacity credit not be
received by Brisbie until the Company is capacity deficient. Staff at 20. Staff argues in its
Comments on page 13: "the Company's proposed treatment for capacity is inconsistent
with Staffs ideal framework because
Staffs idealframework extends the virtua! behind{he-meter approach to the capacity
portion of Brisbie's load service by hypothetically netting Brisbie's new, incremental
system load by the capacity of the new, incremental renewable resources. This construct
already contemplates that the hypothetical netting occurs at the time Brisbie's load
service begins, irrespective of an ldaho Power deficiency date.
ln a true behind-the-meter arrangement (which, as the Company has already
stated, does not accurately describe the Brisbie arrangement) the customer's load is
immediately reduced (netted) at the time the renewable resource begins generating. ln
this way of viewing capacity value, the Company's actual capacity deficiency date is
irrelevant-which is counter to Staffs recommendation.
ldaho Power and Staff are aligned in achieving the same outcome (capacity costs
accurately reflecting capacity value) but disagree on approach. ldaho Power has
proposed assigning the costs and benefits for capacity without netting.
Conceptually, Brisbie should not be viewed as bringing only resources (which is the
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 11
perspective in a "netted'capacity view) but, rather, as load with resources-that is,
Brisbie will be served by all of ldaho Power's resources, including the new resources that
they are paying for in full. Brisbie will pay for the cost of its reliance on the system I
and is also covering the cost of bringing new capacity through the
resources acquired on its behalf. By considering only one side of the equation, Staffs
recommendation would result in charging Brisbie twice
!n turn, ldaho Power believes it is fair to credit Brisbie for the
capacity value of the resources that the customer will pay for in full at the time the
resources come online.
Recommendation 5. Staff argues that the rate structure for the renewable capacity
credit should be based on the avoided capacity rate used to compensate PURPA
Qualiffing Facility ("QF") storage projects. ldaho Power disagrees with this assessment
and recommendation first and foremost because Brisbie's associated resources are not-
and should not be viewed-as PURPA storage projects. The Company's proposed
method of calculating each resource's capacity credlt
is both fair and
reasonable-and is also consistent with the determination of capacity contribution of
those same resource types within the Company's IRP. lf Staff desires a different
methodology to determine capacity contribution of renewable resources, the Company's
considers the IRP the appropriate venue to propose those modifications to ensure the
consistent treatment and application of resource capacity with respect to operations and
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS.l2
planning.
Recommendation 6. Staff recommends that
While the Company believes that
Staffs recommendation has merit, the determination of a surrogate resource is best
handled in the context of Demand-Side Management ("DSM") alternate cost. lf the
capacity cost basis is changed for DSM, the ESA as written will adopt the new method,
making it unnecessary and premature to make such a change in this case. The Company
considers it important to maintain consistency with current practice with respect to DSM
alternate cost.
Recommendation 7. Staff recommends only providing Brisbie with
Staff
at 21. ldaho Power disagrees with Staffs recommendation and assessment. As
articulated in the Company's response to Staffs Recommendation 5,
based on a
Effective Load Carrying Capability ('ELCC") model
because it is applicable
Suggesting
ll result in a gross mischaracterization
In comparison, the Company's
and can effectively
of
determine Further, the
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 13
already
for which the Company must make assumptions
about the
D. Workshops
Staffs eighth and ninth recommendations involve ldaho Power hosting workshops
on topics related to the Brisbie ESA.
Recommendation 8. Staff recommends that the Company host a workshop to
discuss treatment of Brisbie's costs (as specified in Schedule 33) prior to the Company's
next general rate case ('GRC'). ldaho Power is uncertain whether Staff is recommending
a public workshop or a workshop limited to parties in this case. Regardless, the Company
would be happy to host a workshop at an appropriate time and with the appropriate level
of confidentiality for the intended audience before the Company's next GRC.
Recommendation 9. Staff also recommends that the Company hold a workshop to
"evaluate" the allocation of "system-generated" Renewable Energy Certificates ("REC")
to Brisbie and other CEYW - Construction customers. Staff a|21. \Mth respect to the
Brisbie ESA, Staff states in its comments on page 5 that "Brisbie should retain 100o/o of
the RECs generated by its renewable resource(s)." ldaho Power strongly supports this
recognition of appropriate and full REC assignmentto Brisbie for its associated resources.
However, the Company disagrees with Staffs inference that Brisbie (and other CEYW -
Construction customers) should not receive the benefit of system-generated REC sales
that pass through the PCA.
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 14
Under the Company's REC Management Plan, all Company-owned RECs
(including RECs from PURPA projects) are sold, with proceeds passing through the PCA.
That is, the proceeds from REC sales result in a reduction of power supply costs. Brisbie,
and all future CEYW - Construction customers, are not unlike other customers-they will
continue to pay for energy service from ldaho Power. These customers should have the
same right to a PCA reduction as every other customer. The pursuit of a CEYW -
Construction agreement (or Subscription participation) should not penalize this subset of
customers from experiencing the same reduction of power costs as all other customers.
\Nhile ldaho Power would be happy to hold a workshop to discuss REC-related
transactions and PCA impacts of "system-generated RECs," the Company does not
believe there is anything to evaluate on this topic. Reduced power supply costs from ldaho
Power REC sales should be enjoyed and shared by allcustomers.
E. Future Renewable Construction Aqreements
Recommendation 70. Staffs penultimate recommendation is that every CEYW -
Construction agreement "customer PPA" be reviewed and authorized by the Commission.
Staff at 21. This recommendation appears to be in response to the Company's request
for authority to procure necessary resources for Brisbie (as contemplated within the ESA)
without seeking individual Commission approval of each such resource. Tatum Direct at
16.
The Company disagrees with Staffs recommendation that each PPA should be
individually reviewed and authorized by the Commission-and relies on Staffs own logic
to support this position. Staff notes on page 19 of its Comments: "Staff agrees that the
selection of the resource and rates in the PPA do not need to be authorized by
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 15
Commission because the cost of the PPA will be 100% passed through to Brisbie..." The
Company agrees. The selection, size, and other details of Brisbie's supporting resources
are not necessary for the Commission to review so long as Brisbie pays in full for those
resources-which is precisely what the ESA requires.
Staff nevertheless argues that "other elements within the PPA...should be
reviewed and authorized by the Commission." Staff at 19. Staff references the
interconnection agreement as an example. The Company would note that interconnection
agreements do not live within PPAs and that, further, non-PURPA generation
interconnection agreements are not Commission jurisdictional. To the extent Staffs
concerns are related to a fear that interconnection and transmission upgrades for new
resources under the Brisbie ESA could result in cost shifts, it should be noted that ldaho
Power will
This requirement helps to ensure that
lf there are specific elements of a PPA that Staff believes need Commission review
and approval, the Company would like to have those articulated. From ldaho Powefs
perspective, the requirement of Brisbie to pay in full for all its associated resources should
make it unnecessary-and a not insubstantialadministrative burden-for each individual
PPA to be reviewed and approved by the Commission.
F. Annual PCA Treatnent
Recommendation 11. Staffs eleventh and final recommendation is that the
Company include Brisbie's load, as well as its "consumption and generation from the
renewable resources serving Brisbie" in the PCA. Staff recommends similar requirements
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS. 16
for all future CEYW - Construction agreements. ldaho Power supports this
recommendation and can provide the requested information-urith the appropriate
safeguards for confidentiality-in the PCA upon Brisbie taking service from ldaho Power.
rv. coNcLUsroN
ldaho Power again would like to thank Staff for their time and effort in expeditiously
reviewing this case. The Company supports Staffs broad recommendation to approve
the Brisbie ESA. Additionally, ldaho Power supports several of Staffs recommendations
that will provide more information and additional transparency around Brisbie and other
CEYW - Construction agreements, including: filing updates to Brisbie's pricing at the time
of filing the IRP (recommendation 1), holding workshops on updates to Brisbie's Schedule
33 (recommendation 8) and on the treatment of RECs under the CEYW Program
(recommendation 9), and the inclusion of Brisbie's load and associated generation in the
annua! PCA filing (recommendation 11).
The Company respectfully disagrees with Staff on severalof the recommendations
associated with changing the credit components of the Brisbie arrangement. The
proposed credit components in the ESA-that is, the crediting for excess energy and
renewable resource capacity-were developed between ldaho Power and Brisbie with
the specific objective of fair and equitable compensation. Through the no-harm analysis,
which included the impact of the crediting components in question, the Company
validated that the Brisbie arrangement will not shift costs to other customers. Staffs
proposed modifications to the crediting mechanisms have been made without
demonstrating that these changes will result in a more equitable arrangement than what
was originally proposed.
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 17
Considering the Reply Comments herein, Idaho Power requests that the
Commission approve the Brisbie ESA without modification. The Company also requests
that, in conjunction with ESA approva!, the Commission approve Staffs first, eighth, ninth,
and eleventh recommendations, each of which is intended to facilitate transparency
around Brisbie and future CEYW - Construction arrangements.
Respectfully submifted this 6th day of May 2022.
fuz.dat/<-
DONOVAN E. WALKER
Aftorney for ldaho Power Company
IDAHO POVVER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS - 18
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of May 2022,1 served a true and correct
copy of the foregoing ldaho Power Redacted Replacement Reply Comments upon the
following named parties by the method indicated below, and addressed to the following:
Taylor Brooks
Deputy Attorney General
ldaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-0074
Clean Energy Opportunities for ldaho
Michael Heckler
Courtney White
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO INC.
3778 Plantation River Drive, Suite 102
Boise, ldaho 83703
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, !D 83703
Emailed to:
Tavlor. Brooks@puc. idaho.oov
Emailed to:
m ike@cleanenerovopportu n ities. com
cou rtnev@cleanenerovopportu n ities.com
Emailed to:
[e-mail]
Christy Davenport
Legal Admin istrative Assistant
IDAHO POWER COMPANY'S REDACTED REPLACEMENT REPLY COMMENTS.l9