20230620Idaho Power Reply Comments.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

June 20, 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 Reply Comments 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
Tuesday, June 20, 2023 12:15:16 PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER’S COMMENTS - 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]
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[e-mail]
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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

IDAHO POWER COMPANY’S
REPLY COMMENTS

Idaho Power Company (“Idaho Power” or “Company”) respectfully submits the
following Reply Comments in response to Comments filed by the Idaho Public Utilities
Commission Staff (“Staff”). The Company is grateful for supportive comments from Staff
with respect to Idaho Power’s request to extend the filing date of the 2023 Integrated
Resource Plan (“IRP”).
In addition to recommending approval of the Company’s Petition, Staff proposes
that the Company provide an action plan for timely delivery of the 2025 IRP as an action
item in the 2023 IRP. The Company acknowledges Staff’s concerns about the timing and
delayed delivery of prior IRPs and supports Staff’s additional request as a way to reinforce
timely filing of the 2025 IRP.
Idaho Power has been and continues to be committed to a timely and high-quality
IDAHO POWER’S COMMENTS - 2
long-term planning process. In an effort to ensure accurate and defensible IRPs, the
Company has requested extra time in recent cycles – largely a cascading effect of the
prolonged 2019 IRP cycle.
While Idaho Power is confident it can provide both high quality and timely IRP
filings moving forward, the Company considers it important to acknowledge that complex
energy system modeling is becoming more challenging and time-consuming. New
policies, new energy technologies, new market dynamics, new regional programs, and
retiring generation resources all complicate the process of energy system modeling and
portfolio development. Battery storage, for example, is increasingly an economic resource
selection but one that necessitates new approaches to modeling and also increases
model run times due to the dual (charge/discharge) nature of the technology. This
discussion is by no means offered as an excuse but, rather, is presented to explain the
ongoing challenges of robust energy system modeling that adapts to a rapidly changing
energy landscape. With this in mind, the Company commits to more frequent and timely
updates to Staff if modeling challenges associated with the shifting energy landscape look
to compromise timely IRP delivery.
In the current case, and in recognition of Staff’s concerns, the Company fully
supports Staff’s recommendation to provide a procedural action plan in the 2023 IRP for
timely filing of the 2025 IRP.
Respectfully submitted this 20th day of June 2023.

_______________________________
LISA NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER’S COMMENTS - 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 20th day of June 2023, I served a true and correct
Idaho Power Company’s Reply Comments upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Michael Duval
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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