20230613Comments of Commission Staff.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL U "
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 SSN
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S PETITION TO EXTEND THE )CASE NO.IPC-E-23-17
FILING DATE OF ITS 2023 INTEGRATED )RESOURCEPLAN )
)COMMENTS OF THE
)COMMISSION STAFF
COMMISSION STAFF ("STAFF")OF the Idaho Public Utilities Commission,by and
through its Attorneyof record,Chris Burdin,Deputy AttorneyGeneral,submits the following
comments.
BACKGROUND
On May 5,2023,Idaho Power Company ("Company")filed a petition ("Petition")with
the Idaho Public Utilities Commission ("Commission")for a three-month extension to file the
Company's 2023 electric integrated resource plan ("IRP").The Company requests that the
Commission modify the filing date of the 2023 IRP from the last business day of June 2023 to
the last business day of September 2023.The Company requested that its Petition be processed
through modified procedure.
The Company represents that its IRP examines the demand for energy over the next 20
years and identifies the best strategy to meet the forecasted demand for its customers.Petition at
STAFF COMMENTS 1 JUNE 13,2023
2.The Company updates its IRP 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.Id.
The Company represents that at the start of the 2023 process,the Company planned to
share preliminarymodeling results in the Spring of 2023;however,input changes,model
refinements,and model validation and verification have taken more time than expected.Id.at 4.
The Company represents that permitting the Company to delay filing until the end of
September of 2023 will ensure a more complete process,and that a delay is in the public interest
and good cause exists to allow the modification of the filing date to allow public participation
more fully prior to filing.Id.
STAFF ANALYSIS
Staff recommends that the Commission grant the Company's request to file the 2023 IRP
no later than the last business day of September 2023.Staff believes the delayed filing will
enable a better final report which will benefit ratepayers,and it will minimallyimpact upcoming
filings that are dependent upon the IRP.Staff also recommends that the Company include an
action item in the 2023 IRP to ensure timely delivery of the 2025 IRP.
Verifying Model Accuracy is Important
Staff believes that the recent model input changes are significant,and that verification of
the revised models is both important and time consuming.Therefore,Staff agrees that delaying
the IRP deadline to validate the accuracy of the models and to analyze the results is in the best
interest of customers.
The Company's fundamental reason for requesting a delay is that "input changes,model
refinements,and model validation and verification have taken more time than expected."
Petition at 4.The Company cited two recent changes to major IRP inputs.First,it expanded and
refined its Effective Load Carrying Capability ("ELCC")model.Second,it adjusted the
modeling parameters and assumptions for Jim Bridger Units 3 and 4,based on recent updates
announced in PacifiCorp's 2023 IRP filing.These major input changes not only impact the
model results,but they "extend the time needed for model setup,validation,verification,and
portfolio analysis."Id.at 3.
STAFF COMMENTS 2 JUNE 13,2023
In its Final Order regarding the Company's 2021 IRP,the Commission said,"the
planning process is worthwhile when Idaho Power strenuously evaluates model inputs,verifies
the model logic,and collaborates with engaged stakeholders."Order No.35603 at 8.In its
Comments on the 2021 IRP,Staff also highlighted the importance of validating the models used
to plan the Company's resources.Staff Comments,Case No.IPC-E-21-43 at 14.
Customer Participationis Important
The IRP Advisory Council ("IRPAC")membership consists of major industrial
customers,irrigation representatives,elected officials,members of the environmental
community,public utility commission representatives,and other interested parties.These
members have actively participated in the IRP planning and scenario development for the past
nine (9)months.The Company represents that because of the modeling delays,there is
insufficient time to let the IRPAC review the modeling results and offer feedback to the
Company.The Company states that it values the IRPAC consultation process,and to allow
robust participation by the IRPAC,the Company requests an extension of the schedule.Staff
agrees with this justification.
Furthermore,after the IRPAC review,it is customary to open the IRP to 14 days of public
review and comment before filing the report with the Commission.Unless the deadline is
extended,this review will be forfeited.Staff believes the public review is important,which adds
more justification for extending the deadline.
Impacts from a Delayed IRP are Negligible
Two recurring filings typically rely on the IRP data,so an IRP delay could impact these
other filings.Staff believes the impacts will be negligible.
Staff believes the Annual Load and Natural Gas Forecast Update case should not be
affected.The updated forecasts become effective on October 15th of each year,and the Company
typically uses the latest load and natural gas forecasts available at that time,not necessarily the
most recent IRP.
A delayed IRP will delay update of the Capacity Deficiency Date ("CDD")filing,which
is used to determine the start of eligibilityfor avoided capacity payments for new Public Utility
Regulatory Policy Act ("PURPA")contracts.See Order Nos.33917 and 34649.However,since
STAFF COMMENTS 3 JUNE 13,2023
the Company is currentlyin deficit,and is expected to remain in deficit over the next three years,
the capacity deficiency date will likelynot change;therefore,Staff believes this to be a
negligible consideration.
Pattern of Delay
Staff is concerned that this is the second consecutive IRP that the Company has requested
an extension.In addition,although the 2019 IRP was technicallysubmitted by the deadline,it
had to be subsequently reworked,delaying the final submission by several months.To avoid a
recurring pattern,Staff recommends that the Commission require the Company to submit a plan
and schedule to ensure timelydeliveryof the 2025 IRP as part of the 2023 IRP action plan.
STAFF RECOMMENDATION
Staff recommends the Commission approve the following:
Approve the Company's request to file the 2023 IRP no later than the last business
day of September 2023;and
Require an action item in the 2023 IRP to ensure timely deliveryof the 2025 IRP.
Respectfully submitted this day of June 2023.
Chris Burdin
Deputy AttorneyGeneral
Technical Staff:Matt Suess
i:umisc/comments/ipce23.17cbmscomments
STAFF COMMENTS 4 JUNE 13,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF JUNE 2023,
SERVED THE FOREGOING COMMENTS OF THE COMMSSION STAFF,IN
CASE NO.IPC-E-23-17,BY E-MAILING A COPY THEREOF,TO THE
FOLLOWING:
LISA D NORDSTROM ALISON WILLIAMS
MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-MAIL:[e-mail]
E-MAIL:[e-mail]
[e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE