20230505Petition.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
May 5, 2023
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-23-17
In the Matter of Idaho Power Company’s Petition to Extend the Filing Date
of Its 2023 Integrated Resource Plan
Dear Ms. Noriyuki:
Attached for electronic filing is Idaho Power Company’s Petition in the above-
entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosures
RECEIVED
Friday, May 5, 2023 2:47:45 PM
IDAHO PUBLIC
UTILITIES COMMISSION

PETITION - 1
LISA D. NORDSTROM (ISB No. 5733)
MEGAN GOICOCHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S PETITION TO EXTEND THE
FILING DATE OF ITS 2023 INTEGRATED
RESOURCE PLAN
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CASE NO. IPC-E-23-17

PETITION

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”) in
accordance with Rule of Procedure 053, petitions the Idaho Public Utilities Commission
(“Commission”) to modify Order No. 30317 issued on May 23, 2007, in Case No. IPC-E-
06-24, in which the Commission directed Idaho Power to file its next full Integrated
Resource Plan (“IRP”) “no later than the last business day of June 2009.”1 To allow for
more opportunity for IRP modeling and associated stakeholder participation and
comment, Idaho Power requests that the Commission modify the filing date for the 2023

1 In the Matter of Idaho Power Company’s 2006 Integrated Resource Plan, Order No. 30317, p. 2 (May
23, 2007).

PETITION - 2
IRP from the last business day of June 2023 to no later than the last business day of
September 2023.
I. BACKGROUND
1. Idaho Power’s IRP examines the demand for energy over the next 20 years
and identifies the best strategy to meet the forecasted demand for its customers. The IRP
is updated every two years and describes the Company’s projected need for additional
electricity and the resources needed to balance customer load, system reliability,
environmental responsibility, efficiency, risk, and cost.
2. In Order No. 30317, the Commission reviewed the IRP filing dates for its
jurisdictional electric utilities—Idaho Power, Rocky Mountain Power, and Avista Energy—
and directed Idaho Power to file its biennial IRP no later than the last business day of
June 2009.
3. Idaho Power has subsequently filed its IRPs by the last business day of
June in odd-numbered years, with two exceptions: an extension of filing the 2009 IRP
approved by Commission Order No. 30815 and an extension of filing the 2021 IRP
approved by Commission Order No. 35053.
4. The IRP analysis involves a series of inputs and resulting outputs that
necessitate validation and verification in the AURORA model. For the 2023 IRP, the
Company has refined and made changes to several IRP-related inputs. For example,
Idaho Power expanded and refined its Effective Load Carrying Capability (“ELCC”) model,
which impacts the planning reserve margin—a major input to the AURORA model.
Additionally, the Company adjusted the modeling parameters and assumptions for Jim
Bridger Units 3 and 4 based on recent updates announced in PacifiCorp’s 2023 IRP filing.

PETITION - 3
Each adjustment to a major IRP input not only significantly impacts the model results, but
extends the time needed for model setup, validation, verification, and portfolio analysis.
The Company prioritizes accuracy in developing and transparency in reviewing the
selected IRP Preferred Portfolio and Action Plan. As such, Idaho Power respectfully
requests this IRP filing delay to ensure customers and stakeholders have the most
updated, accurate, and transparent IRP analysis accompanied by a robust public review
process.
5. Considering the above, Idaho Power submits this petition requesting that
the Commission modify the filing date for the 2023 IRP from the last business day of June
2023 to no later than the last business day of September 2023.
II. 2023 IRP
6. With assistance from customers and stakeholders through the IRP Advisory
Council (“IRPAC”), Idaho Power began the process of developing the 2023 IRP in
September 2022. The IRPAC consists of members of major industrial customers,
irrigation representatives, elected officials, members of the environmental community,
public utility commission representatives, and other interested parties.
7. The IRP process allows the Commission to evaluate a utility’s planned
resources and ensure they are reasonable, cost effective, and necessary to provide the
Company’s customers adequate service at reasonable rates. In an effort to consider
stakeholder and customer input throughout plan development, the IRP process also
encourages substantial public participation and engagement in the plan preparation
through the facilitation of IRPAC meetings.

PETITION - 4
8. At the start of the 2023 IRPAC process, the Company planned to share
preliminary modeling results in the Spring of 2023. However, input changes, model
refinements, and model validation and verification have taken more time than expected.
A three-month delay, as outlined in the schedule below, will allow for the completion of
the 2023 IRP in a way that does not shortcut vital public process. Idaho Power believes
that its customers are best served by an IRP that has been fully reviewed and on which
stakeholders have had ample time to provide input and review. Accordingly, additional
time to file the Company’s 2023 IRP will better serve Idaho Power’s customers.
9. Permitting the Company to delay filing until the end of September of 2023
will ensure a more complete IRPAC process. Idaho Power believes such a delay is in the
public interest and good cause exists to allow the modification of the filing date to more
fully allow public participation prior to filing.2 The full IRPAC schedule—including tentative
dates for future meetings and public review—is as follows:

2 In the Matter of Public Utility Commission of Oregon Investigation Into Integrated Resource Planning,
UM 1056, Order No. 07-002, Appendix A, pp. 2-3 (Jan. 8, 2007) (Guideline 2a and c. “The public, which
includes other utilities, should be allowed significant involvement in the preparation of the IRP.
Involvement includes opportunities to contribute information and ideas, as well as to receive information.
Parties must have an opportunity to make relevant inquiries of the utility formulating the plan. ...” and “The
utility must provide a draft for public review and comment prior to filing a final plan with the Commission.”)

PETITION - 5
Meeting/Deadline Date Topics
Energy Efficiency
Subcommittee
Meeting
May 4, 2022 Energy Efficiency and T&D Deferral
IRPAC Meeting #1 September 8, 2022 2021 IRP Review, 2023 IRP Overview,
Carbon Outlook, Transmission Update
IRPAC Meeting #2 October 13, 2022 Forecasts (Natural Gas, CSPP, Energy &
Demand)
IRPAC Meeting #3 November 10, 2022 Hydro System, Energy Efficiency (EE),
Demand Response (DR), Future Supply-
Side Resources, Modeling Scenarios
IRPAC Meeting #4 December 8, 2022 Reliability & Capacity Assessment,
Bridger Coal to Natural Gas Conversion,
Follow-Ups
IRPAC Meeting #5 January 12, 2023 T&D Deferral, Solar on Underutilized
Lands, Stochastics, Northwest Resource
Adequacy
IRPAC Meeting #6 February 9, 2023 Portfolio Development Update
IRPAC Meeting #7 March 9, 2023 Analysis Inputs Update, RFP Update
IRPAC Meeting #8 April 27, 2023 Transmission Update
IRPAC Analysis
Preview
July 2023 Modeling Update, Preliminary Results
IRPAC Meeting
Final Results
Early to mid-August
2023
Analysis Results, Preferred Portfolio and
Action Plan
Public Review 14 days in late
August – early
Septembe 2023
Final draft of 2023 IRP open to public
review and comment
IRP Filing No later than
September 29, 2023
2023 IRP filed with the Commission

PETITION - 6
III. COMMUNICATIONS
10. Service of pleadings, exhibits, orders, and other documents relating to this
proceeding should be served upon the following:
Lisa Nordstrom Alison Williams
Megan Goicoechea Allen Regulatory Policy and Strategy Leader
Idaho Power Company Idaho Power Company
P.O. Box 70 P.O. Box 70
Boise, ID 83707 Boise, ID 83707
[e-mail] [e-mail]
[e-mail]
[e-mail]

IV. MODIFIED PROCEDURE
11. Idaho Power believes that consideration of this petition does not require an
evidentiary proceeding and accordingly the Company requests that this Application be
processed under RP 201 allowing for consideration of issues under Modified Procedure,
i.e., by written submissions rather than by evidentiary hearing.
V. CONCLUSION
12. Based on the foregoing, Idaho Power respectfully requests that the
Commission issue its Order modifying the filing date for the Company’s 2023 IRP from
the last business day of June 2023 to no later than the last business day of September
2023.
Respectfully submitted this 5th day of May 2023.

_______________________________
LISA NORDSTROM
Attorney for Idaho Power Company