20220630Reply Comments.pdf

Lisa D. Nordstrom
sHmr.
AnD CORPCo{npery
LISA D. NORDSTROM
Lead Counsel
[e-mail]
June30,2022
VIA ELECTRONIC EMAIL
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-2143
ln the Matter of ldaho Power Company's 2021 lntegrated Resource Plan
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Reply Comments in the
above-entitled matter. lf you have any questions about the attached document, please
do not hesitate to contact me.
Very truly yours,
X* !-7(^1.t..*,
LDN:cd
Enclosures
LISA D. NORDSTROM (!SB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S 2021 ! NTEGRATED
RESOURCE PLAN
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. |PC-E-2143
IDAHO POWER COMPANY'S
REPLY COMMENTS
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
Table of Contents
I. INTRODUCTION..
ll. STAFF'S COMMENTS...............
A. Reliability...............
1. Reliability Target.
2. Ensuring Reliability.
3. Loss of Load Expectation
B. Load and Resource Balance ("L&R Balance")
C. Model Validation and Verification............
D. Modeling - Development and Evaluation of Portfolios -B2H
E. Modeling - Evaluation and Mitigation of Risk.......
1. B2H Risk..........
2. Flexible Resource Strategy.
F. Supply-Side Resources ...........
1. Coal Unit Exits.
2. Renewable Energy and Storage Resources. .....................
3. Natural Gas Conversion..........
4. Natural Gas Forecast...............
G. Demand-Side Resources.........
1. Energy Efficiency.
2. Demand Response.
H. Action Plan ..........
lll. cEo GoMMENTS........
A. Energy Storage Modeling
B. Discount Rate........
lv. tcl CoMMENTS.........
A. Bridger Conversion
B. NaturalGas Price Forecast....
C. Customer-Owned So|ar.........
D. Policy Driven Scenarios..
v. MtcRoNCoMMENTS...............
VI. KIKI TIDWELL COMMENTS.........
A. Generation Capacity Concerns
B. Climate Change and Emissions..............
vll. ctTy oF BotsE CoMMENTS ...............
vlll. coNcLUSroN
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IDAHO POWER COMPANY'S REPLY COMMENTS - 2
I. INTRODUCTION
ldaho Power Company ("ldaho Powe/' or "Company") respectfully submits these
Reply Comments to the ldaho Public Utilities Commission ('Commission") in the matter
of ldaho Power's 2021 lntegrated Resource Plan ('lRP"). These comments respond to
Commission Staff ("Staff'), Clean Energy Opportunities for ldaho ('CEO"), ldaho
Conservation League ("lCL"), Micron Technology, lnc. ("Micron'), Kiki Tidwell, and the
City of Boise.
The 2021 IRP is a comprehensive analysis of the optimal mix of both demand- and
supply-side resources needed to reliably serve customer demand and flexible capacity
needs over the 2O-year planning horizon lrom 2021 to 2040. Development of the 2021
IRP incorporated meaningful feedback received from Staff and stakeholders during the
2019 IRP review and the public involvement process spanning almost 10 months. For
instance, the 2021 IRP includes improvements to scenario modeling and other planning
analyses, as wel! as enhanced process controls. A major improvement in scenario
modeling was achieved through leveraging AURORA's refined long-term capacity
expansion ('LTCE') mode! to co-optimize for ldaho Power and the broader west.
Additionally, the Company completed significant validation and verification of the
modeling, enhanced its reliability analysis, and conducted risk and scenario anatyses to
ensure the proper selection of the Preferred Portfolio.
The 2021 IRP Preferred Portfolio successfully positions ldaho Power to provide
reliable, economic, and environmentally sound service to its customers into the future.
The action plan ("Action Plan") associated with the Preferred Portfolio includes the
following core resource actions: (1) Conversion of Bridger units 1 and2 from coal to
IDAHO POWER COMPANY'S REPLY COMMENTS.3
natural gas by summer 2024with a2034 exit date; (2) Seek to acquire significant capacity
and energy resources to meet demand growth needs in2023 through 2027; (3) Exit from
both Bridger Unit 3 and Valmy Unit 2 by year-end2025; and (4) completing the Boardman-
to-Hemingway ("B2H") transmission line by 2026.
Parties to this proceeding generally support the Company's IRP and Action Plan.
ldaho Power appreciates Staffs recommendation that the Commission acknowledge the
Company's 2021 lRP. The Company's Reply Comments address concerns and
recommendations provided by Staff and the other parties.
II. STAFF'S COMMENTS
Staff recommends acknowledgement of ldaho Power's 2021 IRP and recognizes
the substantial efforts by the Company to improve its methods and its public process.l
Staff believes the Company's efforts have improved the credibility of the 2021 lRP. While
Staff noted multiple improvements that the Company implemented in the 2021 lRP, Staff
also identified concerns it believes need to be addressed in the2023lRP. The Company
appreciates Staffs thorough review and seeks to address each of the concerns and
recommendations herein.
A. Reliability
ldaho Power's 2021 IRP focused on ensuring system reliability. Utilizing the Long-
Term Capacity Expansion ('LTCE") capability of the AUORA model, the Company
developed resource portfolios under a 50th percentile hourly load forecast and required
the AUORA model's LTCE functionality to meet a 15.5 percent peak-hour planning margin
for each of the developed portfolios.
1 Staffls Comments at 3 (Jun. 2,2022).
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
Distinct from the approach in the 2019 lRP,2 the Company's 2021 IRP employed
a 15.5 percent target planning reserve margin ('PRM") based on a 1 day in 20 years (1-
in-20), or 0.05 days per year, reliability hurdle as determined by a Loss of Load
Expectation ("LOLE") analysis. The year 2023 was used as the benchmark year to obtain
the PRM value. ldaho Power specifically chose the 1-in-20 reliability threshold to account
for two region- and Company-specific considerations that can alter the reliability
landscape: 1) extreme weather events that are becoming more frequent, and 2) variability
of water availability year to year.3
While Staff believes the Company improved how it measures and ensures the
reliabili$ of its resource portfolios and how it determines the capacity contribution of
current and future resources within its system, Staff has identified two concerns that the
Company should address in the 2023 lRP.4
1. Reliabilitv Taroet.
Staff questions the Company's change from a 1-in-10 LOLE target that was used
throughout most of the 2021 IRP cycle to the more stringent 1-in-20 target used toward
the end of the cycle. Staff believes a reliability target should be determined independent
of the Company's load and resources. lnstead of using a more stringent target to
compensate forthe variability of weather, Staff thinks it is more appropriate to incorporate
year-to-year variability in both the Company's load forecast and availability of hydro
generation in its resource assumptions rather than assuming average weather conditions
in the lRP.s
2 A 1 5 percent planning margin was used in the 2019 IRP based in part on what peer utilities had selected at the
time.
3 2021 IRP Appendix C: Technical Report at 99.
4 Staffs Comments at 6.
5 Id. at9.
IDAHO POWER COMPANY'S REPLY COMMENTS.5
The Company agrees that adjusting the system peak load and hydrogeneration
data (instead of the LOLE reliability target) is another viable method of accounting for
weather variability. For the 2021 lRP, the Company chose to adjust the LOLE reliability
target to account for weather variability primarily because it maintains the important
historical relationship between load and weather, including the relationship between
hydroelectric and variable energy resources.
While a 1-in-10 reliability threshold is used by some utilities, the Company and the
Westem lnterconnection have experienced more frequent extreme weather events in
recent years. ln addition to the increased frequency of extreme weather events, water
availability can significantly alter the resource landscape for ldaho Power and the Pacific
Northwest. A poor water year-resulting in reduced hydro generation-can effectively
look equivalent to a season-long resource outage. Due to these considerations, the
Company chose to align its reliability threshold with that used by the Northwest Power
and Conservation Council (NWPCC) of 1-in-20.6
2. Ensurinq Reliabilitv.
To evaluate the reliability of resource portfolios, the Company utilized four
historical test years, and scaled the load in those test years to match the 50th percentile
load forecast in future years, thereby allowing the Company to maintain the historical
relationship between load and weather (seasonal and daily) when evaluating future
years.T
As an alternative, the Company considered scaling this load to match a higher
percentile load forecast, such as the 70th percentile based on daily peaks or seasonal
6 https:/Arww. nwcouncil.org/reports/seventh-power-plan/
7 2021 IRP Appendix C: Technical Report at 96-99.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
energy usage; however, this approach does not account for the variability of weather-
dependent resources, such as solar, wind, and hydro (i.e., a poor water year). Rather
than attempt to adjust the characteristics and generation profiles of weather-dependent
resources, and thereby break the historical relationship in the test years, the Company
elected to adjust the reliability target with the expectation of achieving a similar goal of
sufficiently modeling resou rce variability.
Staff concludes that using a more stringent 1-in-20 LOLE target achieves
approximately the same result as the Company's prior methodology and does not harm
the overall results of the lRP.8 While the Company believes that its shift to a 1-in-20
reliability threshold is wel!-supported and justified based on regiona! considerations, the
Company will continue to evaluate and improve its risk-based methods and analyses for
the 2023 lRP. The Company will also continue to work with Staff and stakeholders to
further refine its reliability-assurance process.
3. Loss of Load Exoectation.
Staff offered the Company praise on the new functionality and steps to verifi7 the
load-serving assumptions of resources, noting that the Company's approach improves
the ability to ensure an accurate measurement for the reliability of its resource portfolios
in the 2021 IRP. However, Staff is concerned the Company's method uses only a single
year (2023) as a benchmark to calculate the 15.5 percent PRM for all years through the
planning horizon.e Staff recommends the Company provide justification and additional
analysis of other years to confirm the validity of using only a single year in the 2023 lRP.
I Staffs Comments at 10.
e /d. at 6.
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
The Company appreciates Staffs recognition of the newfunctionality and the steps
taken to ensure an accurate measurement of reliability for the portfolios in the 2021 lRP.
While ldaho Power understands Staffs concerns, the Company would like to clarify that
the PRM calculation is only the first step in the reliability analysis. The PRM is a good
visual representation of reliability and is required as an input into the AURORA model.
The AURORA model produces portfolios designed to meet the PRM, but the definitive
check of reliability occurs in the LOLE analysis and in meeting the 0.05 days per year
LOLE threshold. The Company scrutinized reliability in the years beyond 2023 by
identiffing LOLEs for each year in every portfolio and ensuring that each year met the
0.05 days per year LOLE threshold. By completing this analysis, the Company verified
adequate reliability for all years across the planning horizon, not just 2023.
While ldaho Power is confident in its current approach, Staffs comments and
concerns reflect the importance of ongoing discussion and evaluation regarding how to
best solve for and implement PRM. The Company will lead such discussions in the 2023
lRP, in which one potential modification might be the replacement of PRM with the
Western Power Pool's Resource Adequacy Program, which is currently under
development.
B. Load and Resource Balance ("L&R Balance")
Staff concluded that the2021lRP L&R Balance was reasonable but recommended
that the Company only include market access backed by firm transmission reservations
in the L&R Balance.lo ldaho Power agrees and would like to clariff that the L&R Balance
in the 2021 IRP only included firm transmission with a corresponding third-party
to Id. at 4.
IDAHO POWER COMPANY'S REPLY COMMENTS .8
transmission reservation to market hubs. The Company acknowledges that Capacity
Benefit Margin ('CBM"), which is also accounted for in the L&R Balance, can only be
accessed as firm capacity if ldaho Power is in an energy emergency. ldaho Power will
work with Staff and the IRP Advisory Council ('|RPAC") during the 2023 IRP to determine
the most appropriate method for including transmission in the L&R Balance.
C. Model Validation and Verification
Staff acknowledged the Company's efforts to improve model validation and
verification in the 2021 IRP; however, Staff recommends the Company produce a
comprehensive Quality Assurance ("QA') plan in its next IRP that lists all the items the
Company verifies or validates in its modeling.ll The Company appreciates such detailed
feedback and hopes for continued constructive analysis that highlights where the process
worked wel!, as well as areas that could be improved upon in the future.
With respect to QA, development of the 2021 IRP involved substantial model
checking, validation, and verification tests with a specific focus on validation and
verification of items within the Action PIan window. A summary of the model validation
and verification tests is provided in Chapter 9: Portfolios - Model Validation and
Verification.l2 Staff states that "these tests were key to validating the mode! results and
improved the credibility of the lRP."13 The Company agrees and believes these QA tests
added significant robustness to the modeling process and supported the optimization
results and, ultimately, the selection of the Preferred Portfolio.
11 ld. a|14.
12 2021 IRP at 123.
13 Staffs Comments at 15.
IDAHO POWER COMPANY'S REPLY COMMENTS.9
As part of the 2023 lRP, the Company will seek to further bolster and refine its
modelvalidation and verification efforts. One change that may prove valuable to Staff and
other stakeholders is the addition of a dedicated Model Validation and Verification section
of the IRP that would compile information about the various methods used by the
Company throughout the IRP process to ensure its validity.
D. Modeling - Development and Evaluation of Portfolios - B2H
Regarding modeling of the Boardman to Hemingway (B2H) transmission line in the
2021 lRP, Staff determined that the Company's development and evaluation of portfolios
was appropriate. Staff also concluded that B2H modeling supports the need for the line
given planning case input assumptions. However, Staff finds that, based on cost
simulations, B2H may be less economical in the presence of high natural gas and carbon
prices.la Further, Staff disagrees with conclusions the Company drew from a portfolio
sensitivity run specifically designed to evaluate B2H, stating:
. . . these results [of the Base with B2H - High Gas, High
Carbon Test sensitivity analysisl are not comparable to any of
the results in the table. To make it comparable, the Company
would need to generate portfolios for all Base scenarios using
the high gas and carbon price inputs and then simulate them
through the production cost model using the same planning
gas and carbon prices to compare against the $7,997,339
amount and high gas and high carbon prices to compare
against the $9,424,935 amount. Until the Company runs this
analysis, Staff believes that increasing gas prices and
legislating carbon restrictions may make BzH less
economical.ls
ldaho Power notes that B2H sensitivity analyses were conducted in severalways
to contemplate the economics of the project under various conditions and assumptions.
1a ld. at16.
15 ld.
IDAHO POWER COMPANY'S REPLY COMMENTS.lO
Staffs suggestion would require extensive effort to perform additiona! LTCE analyses,
including developing a re-optimized resource portfolio for the Western Electricity
Coordinating Council (WECC). Additionally, portfolios with and without B2H would have
to be developed and compared. As a reasonable alternative, the Company instead
focused on a range of well-designed validation and risk assessments (i.e., sensitivities,
scenario analysis, and stochastic risk analysis) to ensure that the 2021 IRP Preferred
Portfolio is the most economical choice over a broad range of alternative future scenarios.
The Test scenario shared in Table 10.3 of lhe 2021 !RP, and referenced by Staff,
was developed to test B2H as an independentvariable, assuming the renewable resource
mix was the same between the Base with B2H and Base without B2H portfolios. The
resource makeup of the Base with B2H, Base without B2H, and Base with B2H - High
Gas, High Carbon Test portfolios are shown in the table below:
Table 1: Planning Condition Optimized Resource Additions
Resource Base with B2H
(MW)
Base without B2H
(Mw)
Base with B2H - High Gas, High
Carbon Test
Wind 700 1.300 1.300
Solar 1,405 1,805 1,805
Storaoe 1.685 2.115 1.570
B2H WTH WTHOUT WTH
ln these portfolios, the inclusion of B2H is a key differentiator, and the project's
absence drives changes in portfolios. The Base without B2H portfolio (under planning
conditions) required 1,430 megawatts ('MW') of additional resources (600 MW of
additional wind, 400 MW of additional solar, and 430 MW of additional storage) to perform
the same functions as the Base with B2H portfolio.
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
In the analysis,lo wind and solar prices are fixed following construction and are
unaffected by increases in gas and carbon prices. Therefore, the larger quantities of wind
and solar in the Base without B2H portfolio are precisely why that portfolio performed well
in a high-gas and high-carbon price future - not the lack of B2H. The Company also
tested whether B2H would remain a preferred resource in a high-gas and high-carbon
price future if in a portfolio assigned the same resource mix as the Base without B2H
portfolio. This new portfolio was named "Base with B2H - High Gas High Carbon Test"
and the wind and solar additions mirrored those of the Base without B2H portfolio, as
shown above in Table 1. Confirming ldaho Power's assumptions about the function and
value of B2H in a portfolio, the Base with B2H - High Gas High Carbon Test portfolio had
superior cost performance compared to the Base without B2H portfolio in a high-gas and
high-carbon price future.
ln addition to this single test scenario, the Company performed a robust analysis
of various portfolios through scenario and stochastic risk analyses. The stochastic risk
analysis showed that across a range of hydro conditions, customer loads, and natural gas
prices, the Base with 82H portfolio was the best combination of least cost and least risk.17
Based on the comprehensive stress testing of B2H and other scenario analyses, the
Company is confident that the Base with B2H portfolio is the best option for minimizing
both cost and risk and, as a result, is the appropriate choice for the Preferred Portfolio.ls
In the 2023 lRP, the Company plans to further develop and expand its approach
to stochastic analysis, including advanced modeling of carbon price volatility to better
16 2021 IRP at 130.
17 2021 IRP Appendix C: Technical Report at 92-95.
18 2021 IRP at 131.
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
elucidate the costs and risks of each portfolio. These methods may replace the scenario
analysis performed in the 2021 !RP.
E. Modeling - Evaluation and Mitigation of Risk
1. B2H Risk.
Staff is concerned by the extent to which the Company is relying on B2H to meet
future capacity needs. Staff believes that a cost overrun of 30 percent or a slip in schedule
of one year is may be realistic given current rates of inflation and supply chain issues that
may persist into the future. Staff also notes that transmission siting issues have
historically been difficult for ldaho Power to resolve.le
The Company performed robustness tests related to depth of the Mid-C market,
project cost, and timing of the project.2o
To test market depth, the Company evaluated varying levels of B2H capacity.
Holding totalproject costs constant, the Company assessed the change in portfolios costs
assuming the Company could only access 350 MW,400 MW,450 MW, 500 (the Preferred
Portfolio), and 550 MW of resource-equivalent capacity. !n the most conservative 350
MW scenario, the effective cost of B2H increased by 43 percent on a dollar-per-MW basis.
ln these tests, simply reducing available B2H capacity was not sufficient, as any reduction
in capacity would need to be offset by equivalent resource additions to ensure sufficient
resources to meet forecasted load. Therefore, the Company replaced the detemined
shortfall of B2H capacity in each test portfolio with the equivalent amount of battery
storage, ln doing so, the Base B2H Portfolio with B2H assigned 350 MW resource-
equivalent capacity was still $139 million Iess than the Base without B2H PAC Bridger
1e Staffs Comments at 17
20 2021 IRP at 144-146.
IDAHO POWER COMPANY'S REPLY COMMENTS.l3
Alignment portfolio (the least-cost non-B2H portfolio).21 Because the B2H project will
continue to have 500 MW of capacity, even if only 350 MW is utilized by the Company to
meet its customers' peak needs, the Company could sell the 150 MW differential to a
third-party to offset customer costs. In this case, the portfolio with B2H is $190 million less
than the least-cost non-B2H portfolio.
For comparison purposes, the difference between the Preferred Portfolio (B2H
assigned 500 MW of resource-equivalent capacity) and the least-cost non-B2H portfolio
is $266 million.22 Therefore, even a substantial reduction in the Company's abilfty to
import power with B2H still results in B2H remaining a vital and cost-effective part of the
Preferred Portfolio. lmportantly, through the B2H arrangement, ldaho Powerwillalso gain
200 MW of bidirectional capacity to the Four Corners market hub in northwest New
Mexico. The Company did not incorporate the benefits of this additiona! access, even
though it brings meaningful diversity benefits (i.e., transacting at a different market hub)
and may provide summer capacity.
While B2H is one of the higher-cost resources, it also provides 500 MW of summer
capacity, making it the least-cost resource on a cost per MW basis.23 ln the 2021 lRP,
ldaho Power assigned B2H a zero percent cost contingency in the Preferred Portfolio to
maintain consistency with other resources that are modeled with zero cost contingency.
As part of the B2H cost risk evaluation in this lRP, the Company evaluated B2H with a 0,
10,20, and 30 percent cost contingency. Underthe 30 percent cost contingency scenario,
the net present value ("NPV') ol B2H applicable to the 2021 IRP planning horizon
21 ld. at145.2ld.
23 2021 IRP Appendix D, Table 5, at 34.
IDAHO POWER COMPANY'S REPLY COMMENTS - 14
increases $56.5 million from the Preferred Portfolio.2a Given the $266 million gap between
the Preferred Portfolio, and the lowest-cost non-B2H portfolio, a $56.5 million cost
increase (as found in the 30 percent cost continency analysis) would not alter selection
of the Preferred Portfolio. This evaluation further shows that B2H can absorb significant
cost risk, even above the 30 percent evaluated, and still be cost-effective.
lmportantly, the IRP analysis only evaluated cost risk associated with B2H. The
Company did not stress test other resource types, even though their costs and
construction timelines have the same potential (if not more) to be impacted by current
economic conditions (i.e., inflation) and supply chain issues. Supply chain and inflation
issues are currently causing schedule delays and cost impacts on many types of energy
resources, including energy storage, solar, wind, and natural gas facilities. Any apples-
to-apples comparison would need to include equivalent contingency assumptions for
other resources.
Lastly, the Company evaluated the impact of a one-year delay in the B2H in-
service date from 2026 to 2027 and developed a re-optimized portfolio to evaluate that
risk. This one-year delay reduced the $266 million difference between the Preferred
Portfolio and least-cost non-B2H portfolio to $196 million.2s As the project in-service date
draws closer, more will become known and certain. ln this regard, the Company received
positive news on the B2H permitting front at the end of May 2022. The Administrative Law
Judge, who oversees the Company's permit application through the Oregon Department
of Energy's Energy Facility Siting Commission ("EFSC") process, recommended EFSC
24 2021 IRP at 145.
25 ld. at'146.
IDAHO POWER COMPANY'S REPLY COMMENTS - 15
approve the Company's B2H permit and issue a Final Order and site certificate.26 The
Company is hopeful B2H construction can begin next year.
2. Flexible Resource Strateov.
Staff also expressed concern related to the lack of risk mitigation and flexibility
strategies included in the Company's IRP and recommends that the Company study the
costs and benefits of implementing a flexible resource strategy in the 2023 lRP.27 The
Company appreciates Staffs concern around developing a strategy of resource flexibility
that could proactively mitigate a rapidly changing energy environment. The Company
understands this concern and believes the 2021 IRP addressed much of that flexibility
and uncertainty in the following ways:
o Resource Diversity - Expanded transmission wi!! provide renewable resource
diversity (solar and wind across the Westem lnterconnection), as well as load
diversity. The Company will continue to Iook at other resource options in the 2023
IRP.
. Market Hub Access - B2H will provide additional access to the Mid-C market, as
will the PacifiCorp asset swap associated with B2H. The Company will also gain
200 MW of bidirectional ownership capacity to the Four Corners market hub in
northwest New Mexico. The SWIP North portfolio sensitivity also suggested that
project may be beneficialto explore as well.
b ln the Matter of the Application for Srfe Certificate for the Boardman to Hemingway Transmission Line, OAH Case
No. 201 9-ABC-02833, Proposed Contested Case Order at 296 (May 31, 2022).
z7 StafFs Comments at 6 and 27.
IDAHO POWER COMPANY'S REPLY COMMENTS - 16
. Scalable/Modular Resources - the Company identified small baftery storage
projects that could be placed at substations to defer planned transmission and
distribution upgrades. The Company will continue to look for these opportunities.
Additionally, the Company's Preferred Portfolio achieves resource diversity
through acquisition of large amounts of wind and solar resources, as well as 1,685 MW
of battery storage, which will serve as a flexible resource that can aid in serving peak load
and also absorb power during times of excess renewables relative to load.
As for the 2023lRP, the Company will continue to analyze the potential of small
modular nuclear, as well as hydrogen and other future fuel types, as resources in the lRP.
The Company looks forward to future engagement with Staff in developing and
implementing a more robust flexible resource strategy in the next lRP.
F. Supply-Side Resources
The Company appreciates Staffs review of the various supply-side resources
included in the 2021 IRP and will in turn address the areas of concern identified by Staff.
1. Coa! Unit Exits.
Staff believes timing of coal unit exits and replacement with new resources
significantly impact customer rates and without proper planning may impact system
reliability. Because of this, Staff thinks the negotiation of an exit agreement should have
been included in the Company's 2021 IRP action plan and recommends that it be
incorporated into its coa! plant exit costs to properly value different exit dates in the
Company's portfolios in the 2023 lRP.28
28 Id. at2l-22.
IDAHO POWER COMPANY'S REPLY COMMENTS - 17
During the 2021 IRP process, the Company incorporated the most current
information into the coal exit date assumptions. Due to the uncertainty of exit dates at
Bridger, the Company included an Action Plan item to "Plan and coordinate with
PacifiCorp and regulators for the exiUclosure of Bridger Unit 3 by year-end 2025 with
Bridger Unit 4 following the Action Plan window in 2028." The Company recognizes that
the negotiation of exit agreement(s) is critical for the 2023 IRP and is working with
PacifiCorp, as well as necessary stakeholders, and more details will be shared as
available in the 2023 lRP.
2. Renewable Enerqv and Storaqe Resources.
Staff is concerned by the Company's transition toward Variable Energy Resources
("VERs") and energy storage in the 2021 IRP compared to the 2019 lRP. While Staff
recognizes the benefit of zero-fuel cost VERs, as the Company works toward its clean
energy goal, Staff reminds the Company that it is obligated to continually assess system
reliability and its need to maintain adequate dispatchable resources whether by deferring
its planned exits from coal units or its natural gas generating resources.2e ldaho Power
agrees that the 2021 IRP shows a markedly different Preferred Portfolio compared to the
2019 lRP. A key factor for the shift toward significantly more VERs and storage was the
decrease in cost assumptions for new VERs and storage between the two !RPs.
Given the significant change between IRPs, the Company compared the results of
the 2021 IRP Preferred Portfolio buildout to the resource mix from the NWPCC WECC
buildout in their 2021 Power Plan.30 The two plans show a similar mix of resources in their
regional projections. Additionally, to ensure the shift towards VERs and energy storage
2s ld. at22.n 2021 Northwest Power Plan at 51, https://www.nwcouncil.oro/fs/17680/2021oowerolan 2022-3.odf
IDAHO POWER COMPANY'S REPLY COMMENTS - 18
could occurwhile maintaining system reliability, ldaho Power performed a LOLE reliability
analysis for each portfolio to ensure they maintained adequate system reliability.3l
Ultimately, ldaho Power agrees with Staff that a continued focus on assessing
system reliability and maintaining adequate dispatchable resources is important,
especially as it pertains to carbon emitting resource exits, and the Company will continue
to monitor this in the 2023 lRP.
3. Natural Gas Conversion.
Staff states there is a level of uncertainty regarding the Company and PacifiCorp's
implementation of the planned conversion. Uncertainties include federal and state
regulations, date of conversion, future operating cost, and costs for eventual
decommissioning and retirement.32 While the Company understands Staffs concerns
around these uncertainties, the cost, timeline and permitting information the Company
used in the 2021 IRP was informed by PacifiCorp's recent conversion of Naughton Unit
3 from coalto naturalgas. ldaho Powerwillkeep Staff apprised of the conversion process
as more information is known and wil! include updated information in the 2023 lRP.
4. Natural Gas Forecast.
Staff believes the Company's analysis and utilization of the Energy lnformation
Administration ("ElA"), New York Mercantile Exchange ('NYMEX'), and Moody's data to
veriff that Platts' forecast is appropriate for planning purposes and the use of the forecast
in the IRP is reasonable.33 ldaho Power agrees with Staffs assessment of natural gas
prices and using
31 2021 IRP Appendix C: Technical Report at 96-100.
32 Staffs Comments at 23.
33 /d. at 19.
IDAHO POWER COMPANY'S REPLY COMMENTS - 19
Platts' natural gas price forecast for planning purposes. Given current natural gas price
volatility, the Company concurs with Staffs recommendation to monitor naturalgas price
forecasts and market conditions and will share insights with the IRPAC during the 2023
IRP cycle.
G. Demand€ide Resources
1. Enerov Efficiencv.
Staff believes the addition of EE bundles is an improvement to the IRP and
encourages the Company to continue refining this method of allowing additional EE
selections in the IRP to help alleviate energy constraints throughout the IRP planning
horizon.il The Company appreciates Staffs feedback and agrees that the recent
additions of EE bundles in the 2019 and 2021 lRPs were an improvement over prior
iterations of the lRP. The Company commits to evaluate the method used in the 2021
IRP for subsequent reports.
2. Demand Response.
Reviewing DR in the 2021 IRP, Staff recognizes that a threshold cap is likely
necessary to implement for additional DR capacity due to ramping issues with new DR
programs. Therefore, Staff recommends the Company discuss and explore adjusting the
20 MW threshold cap on additional DR capacity in the 2023 lRP.35 ldaho Power agrees
and will discuss and explore adjusting the threshold cap on additional DR capacity with
its Energy Efficiency Advisory Group ('EEAG") and the IRPAC in the development of the
2023 lRP. ldaho Power will continue to monitor existing DR program participation and
adjust its estimates for available DR capacity for use in the 2023 lRP.
u ld. at24.
35 ld. at25.
IDAHO POWER COMPANY'S REPLY COMMENTS - 20
H. Action Plan
Staffs concluding remarks on the Company's 2021 IRP are focused on the Action
Plan and state that because the Commission only acknowledges the lRP, Staff believes
that most of the resources included in its IRP portfolios should be considered as proxies.s
However, Staff noted certain exceptions to this process citing transmission resources
included in the Company's Preferred Portfolio that do not fit within the definition of a proxy
resource."37 Finally, when it comes to resource acquisition Staff posits that a sufficient set
of alternative resources is required to allow for competitive bidding in the Company's
request for proposals ("RFP") to obtain a reasonable low-cost resource.3s
The Company is in alignment with Staffs comments on this topic. The Company
views the IRP Action Plan as an indicative plan but not a prescriptive one. The Preferred
Portfolio selects a mix of 700 MW of new generic ldaho and Wyoming wind resources in
2024,3s however, the accompanying Action Plan item is more generic: "lssue an RFP to
procure resources to meet identified deficits in2024 and2025." When the Company goes
to acquire the new resources, it will engage in an all-resource RFP and the results of that
RFP may be dramatically different than the 700 MW of wind identified in the IRP modeling.
The resources selected through the RFP process are those that can meet the identified
energy and/or capacity needs on a least-cost and least-risk basis. ln this way, the
Company has not called the new resources in the IRP proxies but has treated them as
such. The exception to this generic process, as noted by Staff, is for specific decisions
3s 2021 IRP at 4, Table 1.1
% ld. at25-26.
37 ld. a|26.
38 d.
IDAHO POWER COMPANY'S REPLY COMMENTS - 21
like the retirement or exit of existing resources and changes to transmission system
topology.
III. CEO COMMENTS
CEO notes that as an active participant in the development of severalof the recent
IRP documents, they congratulate the Company on the improvements recently
introduced, yet are concerned about remaining limitations in the software and analytical
processes employed to produce the IRP plans. CEO respectfully suggest ldaho Power
consider two areas for careful review before developing the 2023 lRP.
A. Energy Storage Modeling
CEO suggests that the Company improve the ability of the softrare used (whether
AUORA or some other product) to analyze effects of battery storage on diurnal market
price patterns. This recommendation comes after a review of the Mid-C hourly prices used
when analyzing the Preferred Portfolio in the 2021 lRP.40 The primary concern being that
given a battery's ability to arbitrage, the daily price spreads seem unrealistically high.al
Finally, CEO conjectures that the modeled daily price spread may materially overvalue
portfolios with enhanced access to Mid-C.
CEO's arguments for lowered daily price spreads resulting from increased energy
arbitrage due to battery storage are unsupported and counterto the data presented in the
lRP. For an actionable arbitrage opportunity to exist, the price spread must be greater
than the cost to utilize it. That is, a rational investor would not attempt energy price
arbitrage if they could not cover the expenses and receive a return on investment. Using
the LCOE data in the year 2021 tor a 4-hour Li-battery, a rationa! investor would not be
a0 CEO's Comments at 2 (Jun. 2,2022).
a1 ld. at 3, the Mid-C price forecasts evaluated were 2023 and 2033.
IDAHO POWER COMPANY'S REPLY COMMENTS .22
able to create a profitable arbitrage opportunity if price spreads were less than
$130/M\ /h.42 Applying the cost curves found in Appendix Ca3, the minimum profitable
arbitrage price in 2023 would reduce to $115.44lM\ /h and in 2033 is $81.61/MWh. Far
from being "unrealistically high," the daily price spreads from the IRP modeling are well
below the minimum profitable arbitrage prices for battery storage. Merits of CEO's
arguments notwithstanding, the Company will continue to evaluate how storage is used
in its planning models in subsequent lRPs as storage technologies develop and model
capabilities expand. ln the 2021 IRP model, storage resources were built as a capacity
resource whose primary objective was to reduce peak demand net of must-run resources
and provide firming and ancillary services for the integration of renewables.
Lastly, CEO concludes that portfolios (such as those with the B2H transmission
line) with enhanced access to Mid-C markets may have been materially overvalued in the
2021 IRP analyses. This conclusion is unsupported conjecture and is counter to the data.
The IRP modeling shows that the next least cost portfolio without B2H under planning
conditions is $266 million more expensive on a net present value basis than the Preferred
Portfolio with B2H.a
B. Discount Rate
CEO believes the Company is using an inappropriately high discount rate which
inherently introduces bias into its associated cost analysis process, inherently
understating the cost exposure in portfolios which are more exposed to those types of
costs (such as carbon emission charges) that rise dramatically over the 20-year forecast
42 2021 IRP at 111.
43 2021 IRP Appendix C: Technical Report at 4445.
44 2021lRP at 8.
IDAHO POWER COMPANY'S REPLY COMMENTS.23
period.a5 CEO strongly believes that the appropriate base for converting future year cost
estimates back to a present value requires using a discount rate that reflects the
customer's cost of short-term funding.a6
ldaho Power disagrees with CEO and believes using its authorized after-tax
weighted average cost of capital ('WACC") to discount the cost of modeled portfolios is
appropriate because this rate best represents the overall longterm cost of capital to the
Company in financing its operations.
Under ldaho's regulatory mandate and model, the Company has an obligation to
provide adequate, efficient, just, and reasonable service on a nondiscriminatory basis to
all those that request it within its certificated service area.aT !n return, ldaho Power has an
opportunity to earn a reasonable return by investing capital into the resources and
systems necessary to perform its service obligation.as
The use of ldaho Powe/s after-tax WACC is consistent with prior years' lRPs,
serving as a clear and understandable method for measuring future customer obligations,
much of these driven by capital costs within the comparable portfolios, at a present value.
When comparing forecast costs of different portfolios, it is vital that the same discount
rate be used to have an 'apples to apples'comparison of each portfolio's cost at a present
value.
Finally, ldaho Power wishes to address CEO's closing comment, in which CEO
states:
However, when the bias in favor of B2H arising from what
CEO sees as unrealistic arbitrage opportunities in the hourly
4s CEO's Comments at 4.6 ld. atS..q ldaho Code $$ 61-302, -315, and -507.4 Application of Citizens Utilities Co.,112ldaho 1061, 1067, 739 P.2d 360, 366 (1987).
IDAHO POWER COMPANY'S REPLY COMMENTS - 24
Mid-C market price forecast is combined with an up to $%
billion understatement of carbon emission cost exposure
associated with the B2H portfolio due to the use of an
inappropriately high discount rate, we see opportunities for
improvement in future IRP analyses.ae
First, it is important to note that resource portfolios are optimized based on the inputs
provided by the Company. All inputs to the modelwere developed using the Company's
WACC as the discount rate. To take the final cost results of a portfolio optimized based
on the Company's WACC and apply a different discount rate to the final outputs than was
applied to the inputs is inappropriate. !f utilizing a lower discount rate for model inputs,
the Company's LTCE modelwould have developed different portfolios and a different set
of portfolio costs. Simply put, one can't take the portfolios developed in the 2021 IRP
utilizing the Company's WACC, and then apply a different discount rate to the portfolio
cost stream and draw any meaningful conclusion.
IV. ICL COMMENTS
ICL recognizes that the 2021 IRP represents an incrementa! improvement over the
2019 lRP. Pointing out improvements, ICL cites improved assessment of Bridger coal exit
dates, improved assessment of clean energy options and improved modeling of demand-
side resource potential. However, ICL believes there are four shortcomings in the
planning process that the Commission should direct ldaho Powerto address in the future.
The four issues cited by ICL are discussed in the Company's reply in the following
sections.
ae CEO's Comments at 6.
IDAHO POWER COMPANY'S REPLY COMMENTS - 25
A. Bridger Conversion
ICL argues that the Bridger Units 1 and 2 natural gas conversion was late in the
process and used speculative inputs.so The Company agrees that the natural gas
conversion was introduced later in the cycle of the 2021 IRP-this is because the
information was brought to the Company late in the IRP process. However, ldaho Power
strongly disagrees with the assessment that this limited stakeholder's ability to collaborate
with the Company. At the first opportunity after learning of PacifiCorp's intention to pursue
a conversion of Units 1 and2 at Bridger, the Company presented the details to the IRPAC
members in October 2021 and solicited comments and feedback.sl
Additionally, ICL's claim of the speculative nature of the modeling inputs to assess
the conversion is baseless. The inputs were informed by actual coal-to-natural gas
conversions. ldaho Power's Bridger plant partner, PacifiCorp, recently converted
Naughton Unit 3 to natural gas and is familiar with the costs and process.s2 The details
for the conversion related to timeline, permitting, and cost were provided to the Company
by PacifiCorp based on their experiences at Naughton. Again, these details were
discussed with IRPAC members in the October 21,2021 meeting.s3
B. Natural Gas Price Forecast
ICL believes that the planning case natural gas price forecast is wrong, and the
method of analysis prevents rigorous evaluation.il The Company disagrees with many of
the erroneous comments made by ICL in relation to the natural gas price forecast. ICL
s ICL's Comments at 4 (Jun. 2,2022).
51 2021 IRP Appendix C: Technical Report at 4.
52 PacifiCorp 2021 IRP table 10.2 a1327.
s3Bridger Units 'l & 2 Natural Gas Conversion IRPAC Presentation (Od. 21 , 2021).
https://docs.idahooower.com/odfs/AboutUs/PlanninoForFuture/iro/2021lBridoer%20Natural%20Gas%20Conversion.p
dfil ICL's Comments at 6.
IDAHO POWER COMPANY'S REPLY COMMENTS .26
stated numerous times that the forecast used for the 2021 IRP was either "highly
confidential" or "secret"Ss when the record and process show the opposite. The natural
gas price forecast methodology was presented by the forecast vendor directly to the
IRPAC on March 11,2021, and a follow up discussion was held on June 10,2021.s6
Further, an abridged version of the forecast methodology and drivers was provided in the
2021 lRP.57
As to the accuracy of the Platt's forecast, the Company used the natural gas price
forecast after performing an evaluation of available forecasts. Based on the available
information and thorough examination of the available forecasts at the time the IRP
analysis was done, the gas forecast used was determined to be most appropriate.ss The
assessment of the natural gas price forecast accuracy provided by ICL suffers acutely
from hindsight-bias. None of the natura! gas forecasts available before the filing of the
2021 IRP showed a significant change in gas markets as a result of the Russian invasion
of Ukraine.
Lastly, ICL's claim that "Despite clear and broad-based skepticism by the IRP
Advisory Committee, ldaho Power chose to use a highly confidential gas price forecast
methodology purchased from Platts,"se is also unsupported. The Company noted a Iively
discussion of the gas forecast during the March 11,2021 meeting, but during the follow
up conversation on June 10, 2021, the only observed skepticism came from lCL.
Notwithstanding, the Company continues to monitor inputs to the IRP and will evaluate
55 /d. at 6, 7 and 11.
tB 2021 IRP Appendix C: Technical Appendix at 3,
57 2021 IRP at 103-106,
58 /d. at 105.
se ICL's Comments at 6.
IDAHO POWER COMPANY'S REPLY COMMENTS - 27
natural gas price forecasts and market conditions and will share insights with the IRPAC
during lhe 2023 lRP cycle.
G. Gustomer-Owned Solar
ICL claims ldaho Power's "2021 IRP neglects to model the resource capacity of
customer-owned solar and storage resources"oo The Company disagrees with ICL's
assessment. Customer-owned generation was accounted for within the load forecast,
resulting in a monthly downward adjustment to the sales forecast for each class. At the
end of the forecast period, 2040, the annual residentialsales forecast reduction was about
65 aMW, the commercial reduction was 3 aMW, and the irrigation reduction was 6 aMW.61
ICL has asked the Company to develop policies including a value of solar ('VOS")
that is stable over the long term that wil! support solar investments, as well as develop a
customer-owned community solar program (virtua! net metering).62 Wrile these
recommendations are outside the scope of the lRP, ldaho Power supports its customers'
pursuit of clean energy and is currently working with Staff and stakeholders on a VOS
(the Value of Distributed Energy Resources-or VODER-study) through the on-site
generation docket in Case No. IPC-E-22-22.63 The Company has also committed to
include the community solar issue in a future Clean Energy Your Way ("CEYW')
stakeholder workshop.il
60 /d. at 8.
61 202'l IRP Appendix A: Sales and Load Forecast at 35.
82 ICL's CommenB at 9.8 ln the Mafter of ldaho Power Company's Application to Complete the Study Raview Phase of the Comprehensive
Sfudy of Cosfs and Benefits of On-Site Customer Generation & for Authoity to lmplement Changes to Schedules 6,
8, and 84 for Non-Legacy Sysfems, Case No. IPC-E-22-22.il ln the Matter of ldaho Power Company's Application to Expand Optional Customer Clean Energy Offeings
Through the Clean Energy Your Way Program, ldaho Power Reply Comments at21-22 (Jun.2,2022).
IDAHO POWER COMPANY'S REPLY COMMENTS .28
D. Policy Driven Scenarios
lCL stated their appreciation for ldaho Power's collaboration to assess four future
scenarios that help inform the Company, stakeholders, and this Commission about
attributes and costs forthe energy system of the future and recommends the Commission
encourage ldaho Power to continue to modelthis type of policy-driven futures along with
the traditional assessment.os ldaho Power appreciates ICL's positive response to the
rapid electrification, climate change, Clean by 2035, and Clean by 2045 scenario
analyses in the 2021 lRP. The Company will continue to model various types of policy-
driven futures along with the traditionalassessment of differing assumptions about Ioads,
gas prices, and hydro generation in the 2023 !RP.
V. MICRON COMMENTS
As Idaho Powe/s largest customer, Micron is keenly interested in all aspects of
ldaho Power's cost of service and service reliability, including ldaho Powe/s resource
planning processes and the types of resources used to serve its electric load.66 The
Company appreciates Micron's participation in the planning process and their support in
its transition to clean energy. Micron also notes that the Company supports customers'
clean energy needs and, as such, recommends that the Commission ensure ldaho Power
plans future resource procurements with an eye toward other large loads that may
transition to customer specific resources to ensure it does not procure excess
resources.GT VUhile the Company cannot always predict if a future resource may be a good
65 ICL'S Commenb at 9-10.s Micron's Comments at 1 (Jun. 2,2022)
67 ld. at2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 29
candidate for a Iarge load customer's clean energy objective, the Company commits to
evaluating resource needs wholistically to ensure it doesn't procure excess resources.
While Micron supports ldaho Power's clean energy transition, they encourage
ldaho Power to continually investigate and implement strategies to mitigate the rate
impacts of the transition. ldaho Power is sensitive to the rates and charges paid by its
customers. Through the IRP process, the Company seeks to produce a portfolio of
resources that represents the least-cost, least-risk path to serving its customers' needs
over the planning horizon.
VI. KIKI TIDWELL COMMENTS
A. Generation Gapacity Concerns
ln her comments, Ms. Tidwel! describes the near-term generation capacity
shortfalls and the various challenges that ldaho Power may face, including market access
issues, the delay of Jackpot Solar, relicensing of various hydroelectric facilities, a delay
in the construction of B2H, and the risks of losing generation capacity at Jim Bridger Units
1 and 2 due to environmental compliance obligations.s
The Company acknowledges the importance of reasonable resource assumptions
to ensure ldaho Power can reliably serve the needs of its customers. Significant
adjustments were made in the 2021 IRP to reflect the changing planning environment.
These changes include adjustments to the assumptions for market purchases in the L&R
Balance and updated capacity contributions for thermal and DR resources.
Regarding relicensing efforts associated with hydro facilities, the Company
believes that relicensing will occur and that these facilities will continue to provide low-
s Kiki Tidwell's Comments at 2-5 (Mar. 21,2022).
IDAHO POWER COMPANY'S REPLY COMMENTS - 30
cost capacity to ldaho Power and its customers. As stated earlier in response to Staffs
comments, the Company anticipates receiving a B2H permit in 2022 and acknowledged
construction delays were possible. To test the impact of a delay, the Company evaluated
a 2027 in-service date as a sensitivity in the 2021 !RP, as described above in response
to Staffs comments.oe The Company plans to work with its partner PacifiCorp in the
conversion of Jim Bridger Units 1 and 2 to natural gas over the next few years, which will
allow the Company to retain needed dispatchable capacity while also reducing emissions
relative to coal-fired resources.
B. Climate Change and Emissions
Ms. Tidwel! noted that she is affected by climate change and that the carbon
emissions from ldaho Power's operations are contributing to climate change.7o The
Company believes Ms. Tidwell's concerns are addressed in the new Climate Change
chapter of the !RP Report, which focused on identiffing climate-related risks, discussing
the Company's approach to monitoring and mitigating identified risks, and examining
climate-related risk considerations in the lRP.71 The Company also included a climate-
related risk assessment in the2021 lRP. Specifically, the Company conducted additional
scenarios to explore the impact these events could have on ldaho Power's system. These
scenarios are detailed in Chapter 9 of the 2021 lRP.
Ms. Tidwell also points out that the Preferred Portfolio greenhouse gas emissions
are higher than the CIean by 2045 scenario run in the 2021 lRP. While this is true, the
"10Oo/o Clean By" scenarios were significantly more expensive than the Preferred
6s 2021lRP at 125.
70 Kiki Tidwell's Comments at 5712021|RP at 27-34.
IDAHO POWER COMPANY'S REPLY COMMENTS.3l
Portfolio. The Company is confident that the selected Preferred Portfolio is the best
combination of least cost and least risk. Further, the path to ldaho Power's 2045 clean
energy goal will not be perfectly linear-and, as such, the emissions reduction path will
not be perfectly linear. The Company will have to adjust and adapt as new technologies
and opportunities become available and cost-effective.
!t should not go unnoticed, though, that the 2021 IRP represents a significant
departure from the 2019 IRP with respect to clean resources in the Preferred Portfolio:
700 MW of wind, 1,405 MW of solar, 1,685 of battery storage, 100 MW of demand
response, 440 MW of energy efficiency, and 500 MW of transmission. Idaho Power
believes it is planning appropriately and making strides toward its 2045 goal.
VII. CITY OF BOISE COMMENTS
ldaho Power appreciates the City of Boise for their participation in the 2021 IRP
planning process and for their support of the Company's plan. Specifically, the City of
Boise recommends the Commission acknowledge the 2021 lRP.72 The Company is eager
to convene the IRPAC in September to assist in development of the 2023 IRP and looks
forward to continued work and collaboration with the City of Boise.
VIII. CONCLUSION
Based on the detailed and comprehensive analysis set forth in the lRP, ldaho
Power has demonstrated that its preferred portfolio, which includes the B2H transmission
line as a least-cost, least-risk resource, meets the resource need identified in this lRP.
ldaho Power respectfully requests the Commission accept and/or acknowledge the
72 City of Boise's Comments at 1 (submitted June 2,2022)
IDAHO POWER COMPANY'S REPLY COMMENTS .32
Company's 2021 IRP as rneeting both the procedural and substantive requirements of
Order Nos.22299,25260, and 30317.
DATED at Boise, ldaho, this 3S day of June2022.
X;fr.ff"*t -*,
LISA D. NORDSTROM
Aftorney for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 33
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of June 2022, I served a true and
correct copy of ldaho 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
!daho Public Utilities Commission
1 1331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
ldaho Conservation League
Benjamin J. Otto
Emma E. Sperry
ldaho Conservation League
710 N.6th Street
Boise, ldaho 83702
Kiki Leslie Tidwell
704 N. River Street #1
Hailey, lD 83333
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
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espe rry@ ida h oco nse rvation . o rg
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tnelson @ho!land ha rt. com
awiensen@ holland hart.com
aclee@holland hart. com
g lo a ro a n oama ri@ hol la nd ha rt. com
IDAHO POWER COMPANY'S REPLY COMMENTS.34
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, lD 83707
Clean Energy Opportunities for ldaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Michael Heckler
Courtney VUhite
Clean Energy Opportunities for ldaho lnc.
3778 Plantation RiverDr., Ste. 102
Boise, lD 83703
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N.27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hil! Road
Boise, ldaho 83703
STOP B2H Goalition
Jack Van Valkenburgh
Valkenburgh Law, PLLC
P.O. Box 531
Boise, ldaho 83701
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co u rtnev@cleanenerovooportu n ities. com
m ike@clea ne ne rqvo ppo rtu n ities. com
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IDAHO POWER COMPANY'S REPLY COMMENTS.35
Jim Kreider
STOP B2H Coalition
60366 Marvin Rd
La Grande, OR 97850
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Christy Davenport
Legal Admin istrative Assistant
IDAHO PO\A'ER COMPANY'S REPLY COMMENTS.36