20221209Motion for Extension of Time.pdf

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MEGAN GOICOECHEA.ALLEN
Corporate Counsel
mqoicoecheaallenidahooower.com
December 9,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretiary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 2O1-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. IPC-E-22-06
ln the Matter of ldaho Power Company's Application for Approval of a
Replacement Special Contract with Micron Technology, !nc. and A Power
Purchase Agreement with Black Mesa Energy, LLC
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power's Motion for Extension of Time to Make
Compliance Filing in the above-entitled matter.
Please feel free to contact me directly with any questions you might have about this
filing.
Very truly yours,
WT.ui;^t^fi0ll,,r
Megan Goicoechea-Allen
MGA:cd
Enclosure
DONOVAN E. WALKER (lSB No. 5921)
MEGAN GOICOECHEA ALLEN (!SB No. 7623)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa [e-mail]
mooicoecheaal [e-mail]
Aftomeys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COM PANY'S APPLICATION FOR
APPROVAL OF A REPLACEMENT
SPECIAL CONTRACT WITH MICRON
TECHNOLOGY, INC. AND A POWER
PURCHASE AGREEMENT WITH BLACK
MESA ENERGY, LLC.
)) CASE NO. rPC-E-22-06
)) IDAHO POWER COMPANY'S
) MOTTON FOR EXTENSTON OF
) T|ME TO MAKE COMPLIANCE
) FTLTNG
)
)
COMES NOW, ldaho Power Company ('ldaho Powe/'or "Company") and moves
the ldaho Public Utilities Commission ('Commission") for an order granting additional time
forthe Company to make its compliance filing in this case as directed by the Commission
in Order No. 35532. The grounds and reasons for this request are as fotlows:
1. On August 1, 2022, the Commission issued its ruling on ldaho Power's
Application seeking approval, of the Revised SpecialContract ("Micron ESA") with Micron
Technology, lnc. ('Micron"). ln pertinent part, Order No. 35482, directed modifications to
the Micron ESA, including use of a new method for calculating renewable capacity
IDAHO POWER COMPANY'S MOTION FOR EXTENSION OF TIME TO MAKE
COMPLIANCE FIL!NG . 1
credit(s) ('RCCs"), and instructed the Company to file an updated ESA and Schedule 26
as a result.
2. The Company filed a Petition for Clarification and Reconsideration on
August 22,2022, which, among other things, sought clarification on how to calculate the
renewable capacity credit(s) ("RCCs") under the Micron ESA. ln granting the Company's
Petition, the Commission noted that the method of calculating the RCC that it directed
with respect to the Micron ESA departed from traditiona! lntegrated Resource ('lRP")-
based methodologies and incorporated new methods. Accordingly, the Commission
found it would be beneficial to have the Company and Staff 'work together to develop a
rate structure for calculating Micron's RCC under the ESA which the Company shall file
as a compliance filing in this case by December 13, 2022." Order No. 35532, p. 10.
3. Following the issuance of Oder No. 35532, the Company and Staff have
worked together in good faith to fulfill the Commission's mandate, participating in five
meetings between November 2,2022, and December 8, 2022, during which the parties
engaged in open dialogue and exchanged information and ideas with a goal of
implementing the Commission's intent for the treatment of RCCs under the ESA.
4. As a result of these efforts, Straff and the Company have agreed on the basic
parameters of the rate structure for calculating Micron's RCC, but additional time is
needed to work through some of the details and finalize the understanding.
5. ln order to provide it with adequate time to prepare a considered and
appropriate compliance filing, ldaho Power respectfully requests that the Commission
issue an order extending the deadline for the Company to make its compliance filing by
10 days, from December 13th to December 23d.
IDAHO POWER COMPANY'S MOTION FOR EXTENSION OF TIME TO MAKE
COMPLIANCE FILING .2
6. ldaho Power contacted Statr, regarding his reguest br extension and was
advised that Staff has no objection to extending the deadline for the Company's
mmpliance filing.
Respectftrlly submitted this 9m day of December 2022.
'h-ryTittrh,-fi0ht
MEGAN GOICOECHEA ALLEN
Attomey for ldaho Power Company
IDAHO POVVER COMPANY'S MOTION FOR EXTENSION OF TIME TO MAKE
COMPLIANCE FILING.3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the th day of December 2022, ! served a true and
correct copy of the foregoing ldaho Power Company's Motion for Extension of Time to
Make Compliance Filing upon the following named parties by the method indicated below,
and addressed to the following:
Commission Staff
Riley Newton
DeputyAttomey General
ldaho Public Utilities Commission
Po Box 83720
Boise, ldaho 83720-007 4
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, lD 83703
City of Boise
Ed Jewell
Deputy City Attomey
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701 -0500
Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, ldaho 83701-0500
Emailed to:
rilev. newton@puc. idaho.qov
Emailed to:
peter@richa rdsonadam s.com
Emailed to:
d read inq@m i ndsprinq.com
Emailed to:
ejewe I l@ citvofboi se.o rq
boisecitvatto rnev@citvofboise. orq
Emailed to:
[e-mail]
Christy Davenport
Legal Administrative Assistant
IDAHO POWER COMPANY'S MOTION FOR EXTENSION OF TIME TO MAKE
COMPLIANCE FIL]NG . 4