20210721Comments.pdf

IDAHYDRO’S COMMENTS – Page 1
C. Tom Arkoosh, ISB No. 2253 ARKOOSH LAW OFFICES 913 W. River Street, Suite 450 P.O. Box 2900 Boise, ID 83701 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Admin copy: [e-mail] Attorneys for IdaHydro BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION FOR APPROVAL OF THE CAPACITY DEFICIENCY TO BE UTILIZED FOR AVOIDED COST CALCULATIONS
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Case No. IPC-E-21-09 IDAHYDRO’S COMMENTS

COMES NOW the Idaho Hydroelectric Power Producers Trust, an Idaho Trust, d/b/a
IdaHydro (“IdaHydro”), by and through its counsel of record, C. Tom Arkoosh of Arkoosh Law
Offices, and hereby submits the following comments:
In this Application, Idaho Power Company (“Idaho Power”) seeks ratification of its
Second Amended 2019 Integrated Resource Plan (“IRP”) first capacity deficit date of August
2028. Subsequently, Idaho Power issued a Notice of Intent to seek requests for proposals as
early as June 30, 2021, stating:
D. Need for Action
IPC's service territory continues to experience customer growth and an increasing demand load) for electricity. IPC anticipates sustained load growth that will require the procurement of new resources to meet peak summer demand and maintain system reliability. Additionally, recent changes in the regional transmission markets have constrained the transmission system external to the
IPC service territory and significantly impacted the ability to import energy from western market hubs for delivery to IPC's system. The addition of new resources to meet peak demand is critical to ensure IPC can continue to reliably meet the growing demands on its electrical system and serve its customers. The need for additional capacity resources has been identified as early as Summer 2023 at
approximately BOMW, with peak deficits that grow to approximately 400 MW
RECEIVED
2021 July 21, AM 9:31
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHYDRO’S COMMENTS – Page 2
by Summer 2025. Responding to Staff discovery, Idaho Power acknowledges in its Response to Request
No. 23, “The load forecast used for the Notice of Intent is intended to represent permanent load
additions.”
An anomaly, or even a contradiction, exists between the conclusion of the IRP that Idaho
Power needs no new capacity until August 2028, and reaching out in requests for proposals for
new capacity by 2023. While the IRP does not have the sanction of this Commission, the
outcome of this Application will be a Commission order setting the capacity deficiency date for
avoided cost purposes. If the Commission grants Idaho Power’s request for an August 2028 date
rather than the Summer 2023 capacity deficiency date before which Idaho Power can fill in new
capacity from all sources, Idaho Power’s marginal capacity will most probably be filled by
sources other than Qualifying Facilities (“QF”), running the avoided cost capacity deficiency
date further into the future on a rolling and perpetual basis because non-QF power will continue
to fill the queue. It appears to violate the Public Utilities Regulatory Policy Act (“PURPA”) to
forestall a capacity component in the PURPA avoided cost calculation while taking on new
non-QF capacity at the same time.
Therefore, it is respectfully requested that the capacity deficiency date for PURPA QF
avoided costs be set at a mid-summer month in 2023.
DATED this 21st day of July 2021.

ARKOOSH LAW OFFICES _______________________________
C. Tom Arkoosh
Attorney for IdaHydro
IDAHYDRO’S COMMENTS – Page 3
CERTIFICATE OF MAILING I HEREBY CERTIFY that on the 21st day of July 2021, I served a true and correct copy
of the foregoing document(s) upon the following person(s), in the manner indicated:
Idaho Public Utilities Commission 11331 W. Chinden Blvd., Building 8, Suite 201-A P.O. Box 83720
Boise, ID 83720-0074

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-mail:
[e-mail]
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8,
Suite 201-A P.O. Box 83720 Boise, ID 83720-0074
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elivered
ile -mail: @puc.idaho.gov
Regulatory Dockets Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, ID 83707
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@idahopower.com
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Energy Contracts
Idaho Power Company
1221 West Idaho Street (83702) P.O. Box 70 Boise, ID 83707
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Delivered
ia Facsimile -mail: [e-mail]

Richardson Adams, PLLC 515 N. 27th St.
P.O. Box 7218
Boise, ID 83702
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-mail: richardsonadams.com
IDAHYDRO’S COMMENTS – Page 4

____________________________________ C. Tom Arkoosh
6070 Hill Road Boise, ID 83703 ____
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ourier Delivered
-mail: