20231221Reply Comments.pdf

DONOVAN WALKER
Corporate Counsel
[e-mail]

December 21, 2023

VIA ELECTRONIC MAIL

Commission Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-27
Idaho Power Company’s Application for Approval of the Capacity Deficiency
Period to be Utilized for Avoided Cost Calculations

Dear Commission Secretary:

Attached for electronic filing is Idaho Power Company’s Reply Comments in the
above-entitled matter. If you have any questions about the attached document, please
do not hesitate to contact me.

Very truly yours,

Donovan Walker

DEW:cd
Enclosures
RECEIVED
2023 DECEMBER 21, 2023 4:02PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S REPLY COMMENTS - 1
MEGAN GOICOCHEA ALLEN (ISB No. 7623)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorney for Idaho Power Company

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-23-27

IDAHO POWER COMPANY’S
REPLY COMMENTS

Idaho Power Company (“Idaho Power” or “Company”), in accordance with RP 201,
et seq., as well as the Idaho Public Utilities Commission’s (“IPUC” or “Commission”)
Notice of Modified Procedure in this matter, Order No. 35997, hereby respectfully submits
the following Reply Comments.
I. INTRODUCTION
On October 23, 2023, Idaho Power filed an Application for Approval of the Capacity
Deficiency to be Utilized for Avoided Cost Calculation with the Commission. This
Application was made after the filing of the Company’s 2023 Integrated Resource Plan
(“IRP”) and pursuant to Order No. 35810, Case No. GNR-E-23-01, in which the
Commission found it reasonable that each utility file its application for a new capacity
IDAHO POWER COMPANY’S REPLY COMMENTS - 2
deficiency date within 30 days of its IRP filing with the Commission. The Idaho
Hydroelectric Power Producers Trust (“IdaHydro”) was granted intervention on November
29, 2023. Order No. 36013.
During the course of this proceeding, Staff issued several discovery requests and,
on December 14, 2023, filed Comments recommending that the Company update its
initial capacity deficiency date filing with a compliance filing incorporating certain updates
and changes. Staff Comments, p 2, 7. IdaHydro did not file Comments.
II. REPLY COMMENTS
Idaho Power appreciates Staff’s Comments, which demonstrate a thorough review
and evaluation of significant assumptions contained in the Company’ initial capacity
deficiency filing. Based on its analysis, Staff made the following recommendations:
Staff recommends that the capacity deficiency period and amounts
of deficiency for purposes of determining when capacity payments should
begin for new PURPA contracts be based on a compliance filing that reflects
the following:

1. The Company file the most recent load forecast and explain the
difference between the latest load forecast and the proposed
forecast; and
2. The Company exclude the WRAP capacity benefit of 14
Megawatts ("MW") in determining the capacity deficiency period.

Staff also recommends that the Company use the latest load forecast for
future capacity deficiency filings as required by Order Nos. 33958, 34918,
and 35415, and that the Company provide evidence to substantiate its
proposed Capacity Benefit Margin ("CBM") capacity size in the next
capacity deficiency case.

Staff Comments, p. 2, 7.
As Staff notes in its Comments, the load forecast used by the Company in its
application in this case was created in the second quarter of 2023 and was used in the
Company’s 2023 IRP. Staff stated that though the capacity deficit date determined in the
IDAHO POWER COMPANY’S REPLY COMMENTS - 3
IRP process is the starting point, the Company should set its first capacity deficit based
on the most up-to date information available. Staff was concerned, however, that the
Company did not use the most recent information noting that the Company had developed
a load forecast in September 2023 that it used in another regulatory filing (IPC-E-23-25).
Staff also highlighted that the Company’s proposed capacity deficiency period in
this case incorporated capacity benefits from the Western Resource Adequacy Program
(“WRAP”) beginning in 2027. However, because the Company has not made a binding
commitment to participate in the WRAP, Staff did not believe the WRAP capacity benefit
should have been included in the Company’s determination of the capacity deficiency
date.
With respect to CBM, the Company understands Staff’s concern and the resulting
request to substantiate the continued inclusion of CBM as a capacity resource. It is worth
noting that Idaho Power has seen diminishing reliability of CBM in recent years because
of limited to no availability of third-party transmission to facilitate market energy
purchases. As a result, the Company does not believe it can continue to rely on CBM as
a capacity resource for planning or procurement purposes. That said, Idaho Power is
open to making changes in this deficiency filing to align with evolved thinking about CBM
for PURPA avoided cost determinations.
Idaho Power appreciates Staff’s thorough review and assessment of the
Company’s proposed capacity deficiency date. The Company is not opposed to pursuing
Staff’s recommended adjustments to the assumptions considered in determining the
capacity deficiency period and amounts should the Commission direct the same. In the
event it does, the Company raises an additional consideration with respect to Staff’s
IDAHO POWER COMPANY’S REPLY COMMENTS - 4
recommendation for the Company to use the load forecast developed in September 2023
to determine the deficiency date rather than the second quarter forecast from the IRP.
The Company notes that the load forecast is one of many inputs used to determine the
deficiency date and that changing one assumption without considering other factors that
impact capacity deficiency determinations may lead to an incomplete or inaccurate result.
Subject to that caveat, the Company will conduct Staff’s recommended adjustment if the
Commission deems it appropriate.
III. CONCLUSION AND RECOMENDATIONS
Idaho Power appreciates Staff’s review and Comments and is not opposed to
Staff’s recommended changes and adjustments to the inputs used in the development of
the capacity deficiency date should the Commission direct the same. If the Commission
accepts Staff’s recommendations, the Company requests the Commission direct Staff
and the Company to work together to develop a process and timeline for the Company to
implement the recommended adjustments that will provide Staff the opportunity to review
and attempt to reconcile any issues with the Company prior to it making the compliance
filing in an effort to avoid further iterations of filings in this case. Moving forward, the
Company further agrees to use the latest load forecast for future capacity deficiency
filings and to provide evidence to substantiate its proposed CBM capacity size in its next
capacity deficiency case or an earlier relevant filing such as its next IRP, if appropriate.
Respectfully submitted this 21st day of December 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S REPLY COMMENTS - 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 21st day of December 2023, I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY’S REPLY
COMMENTS upon the following named parties by the method indicated below, and
addressed to the following:

Adam Triplett
Deputy Attorneys General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

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C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
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Christy Davenport, Legal Assistant