20240506Staff Comments.pdf

RECEIVED
Monday, May 6, 2024 12.28.33 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
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
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S PETITION TO MODIFY A ) CASE NO. IPC-E-24-08
COMPLIANCE REQUIREMENT RELATED )
TO UPDATING SCHEDULE 87 )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Chris Burdin, Deputy Attorney General, submits the following
comments.
BACKGROUND
On February 27, 2024, Idaho Power Company("Company") filed a petition("Petition")
with the Idaho Public Utilities Commission("Commission")requesting to modify a compliance
requirement in Commission Order No. 36048, issued in Case No. IPC-E-23-14, regarding
updating the Company's Schedule 87, Intermittent Generation Integration Charges ("Schedule
87").
The Company requests that the Commission modify the Company's compliance
requirement to (1) authorize the Company to update Schedule 87 integration costs based on the
forthcoming 2024 Variable Energy Resource ("VER") Study, instead of the 2020 VER Study,
STAFF COMMENTS 1 MAY 6, 2024

and(2) authorize the Company to file both the forthcoming 2024 VER Study and updated
Schedule 87 no later than December 31, 2024.
STAFF ANALYSIS
Staff believes the Company's rationale to forego updating Schedule 87 rates using the
2020 VER study and updating them based on a new 2024 VER study filed by the end of this year
is reasonable, and Staff recommends approval of the Company's proposal. Staff evaluated the
Company's proposal from the perspectives of the timing of Schedule 87 updates, the improved
accuracy of Schedule 87 rates by using a more up-to-date study, changes in the methods that will
be used in the new study, rate stability, and regulatory efficiency. Staff also considered the need
and reasons for the compliance items identified in Order No. 36048.
Timing of Updates
The Company's proposal will delay the update of Schedule 87 for existing wind and solar
Public Utility Regulatory Policies Act of 1978 ("PURPA")by several months. However, the
Company stated that it currently has no pending new wind or solar PURPA contracts. Petition at
3. Staff believes there is no urgency to update the integration rates for new wind or solar
PURPA contracts that likely would be signed prior to the new integration rates going into effect.
Result Accuracy
Staff believes the system has changed sufficiently that an update to Schedule 87 using the
2020 VER Study would be questionably accurate and that integration rates using an updated
2024 VER Study will better reflect the Company's current situation and future trends, resulting
in more accurate results.
Methodological Changes
The 2024 VER Study will use a new methodology and a different rate structure than the
integration rates currently approved. Staff believes processing these changes through a single
case will provide a smoother transition to the new method and rate design and will ultimately
reduce confusion for PURPA developers.
STAFF COMMENTS 2 MAY 6, 2024

Rate Stability
Staff believes a change in integration rates twice in less than a year, as a result of
complying with Order No. 36048, would impact rate stability. Staff believes changing the rates
twice in one year in combination with a change in the Company's methods and rate design, as
discussed above, could cause confusion for wind and solar PURPA developers.
Regulatory Efficiency
Staff believes that the Company's proposal would prevent the need to review and update
Schedule 87 twice in a year resulting in less cost to the Company and to its customers. As stated
by the Company, by the time a review of updated Schedule 87 is completed based on the 2020
VER Study, another review of the schedule based on the 2024 VER Study would be scheduled to
commence. Petition at 2.
STAFF RECOMMENDATION
Staff recommends that the Commission:
1. Authorize the Company to update Schedule 87 integration rates based on the
forthcoming 2024 VER Study, instead of the 2020 VER Study; and
2. Direct the Company to file both the forthcoming 2024 VER Study and updated
Schedule 87 proposed rates no later than December 31, 2024.
Respectfully submitted this 61h day of May 2024.
Chris Burdin
Deputy Attorney General
Technical Staff: Yao Yin
Jason Talford
I:\Utility\UMISC\COMMENTS\IPC-E-24-08 Comments.doex
STAFF COMMENTS 3 MAY 6, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6th DAY OF MAY 2024, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. IPC-
E-24-08, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER ALISON WILLIAMS
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: dwalker(&idahopower.com E-MAIL: awilliamsaa,idahopower.eom
[e-mail]
14
G
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE