20240522Reply Comments.pdf

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RECEIVED
MEGAN GOICOECHEA ALLEN 2024 May 22, 1:14PM
Corporate Counsel IDAHO PUBLIC
mgoicoecheaallenC�idahopower.com UTILITIES COMMISSION
May 22, 2024
Monica Barrios-Sanchez, 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-24-17
Application of Idaho Power Company for Authority to Implement Power Cost
Adjustment("PCA") Rates for Electric Service from June 1, 2024, through May
31, 2025
Dear Ms. Barrios-Sanchez:
Attached for electronic filing is Idaho Power Company's Reply Comments in the
above-reference matter.
If you have any questions about the attached document, please do not hesitate to
contact me.
Sincerely,
Megan Goicoechea Allen
MGA:sg
Enclosure
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaallen(a).idahopower.com
Inordstrom(aMdahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-24-17
AUTHORITY TO IMPLEMENT POWER )
COST ADJUSTMENT ("PCA") RATES ) IDAHO POWER COMPANY'S
FOR ELECTRIC SERVICE FROM JUNE ) REPLY COMMENTS
1, 2024, THROUGH MAY 31, 2025. )
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and,
pursuant to Idaho Public Utilities Commission's ("Commission") Rule of Procedure' 203
and the Notice of Modified Procedure, Order No. 36158, hereby respectfully submits the
following Reply Comments in response to Comments filed by Commission Staff ("Staff")
in the matter of the Company's application for authority to implement Power Cost
' Hereinafter cited as RP.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

Adjustment ("PCA") rates for electric service from June 1, 2024, through May 31, 2025.
I. BACKGROUND
On April 15, 2024, Idaho Power applied to the Commission for an order approving
an update to Schedule 55 based on the quantification of the 2024-2025 PCA to become
effective June 1, 2024, for the period June 1, 2024, through May 31, 2025. As filed, the
2024-2025 PCA would result in an overall revenue decrease of approximately $35.7
million, or a 2.31 percent decrease over the current billed revenue.
On May 15, 2024, Staff filed comments that recommended the approval of the
Company's Application and Schedule 55 as filed, that the Commission recognize the net
power supply expense ("NPSE") from the 2022-2023 PCA year as prudent, and that the
Company keep the Commission and Staff apprised of any adjustments to the forecast
that may warrant an out-of-cycle PCA adjustment.
In addition, Staff's comments included a discussion of actual versus base-level
expenses associated with natural gas generation and market purchases. Staff
encouraged the Company to search for solutions to mitigate cost risk associated with
these resources in the peak months and to discuss its efforts in next year's PCA filing.
Staff also requested that the Company consider adjusting its annual testimony to focus
more on actual NPSE as opposed to the PCA forecast.
II. REPLY COMMENTS
Idaho Power appreciates and acknowledges Staff's review of the Company's PCA
filing. The Company agrees with Staff's conclusions that the filed PCA components
appropriately calculate the 2024-2025 PCA rates under the currently approved
methodology and that the NPSE incurred in the 2022-2023 PCA year was prudent. In
IDAHO POWER COMPANY'S REPLY COMMENTS -2

addition, Idaho Power supports Staff's recommendation for the Company to keep the
Commission and Staff apprised of changes to the PCA forecast that could warrant an out-
of-cycle PCA adjustment.
Idaho Power also appreciates Staff's analysis and discussion regarding actual
versus base level expenses associated with natural gas generation and market
purchases. Staff expressed concern that "underlying market conditions may be shifting,
and the Company's reliance on gas and market purchases in the peak months may
continue to be exorbitantly expensive."2 As a result, Staff encouraged Idaho Power to
"search for solutions to mitigate the cost risk in the peak months, and to discuss its efforts
in the next PCA filing."3
Idaho Power manages NPSE risk through the Company's Energy Risk
Management Standards ("ERMS"), which set forth guidelines for setting volumetric and
financial exposure limits that dictate the Company's allowed hedging activity. In
recognition that market conditions are changing, Idaho Power agrees to review these
guidelines and discuss potential changes with Staff throughout the 2024-2025 PCA year.
Idaho Power will also include a discussion of these efforts in next year's PCA filing.
Lastly, Idaho Power agrees to adjust its annual PCA testimony to focus more on
actual generation and expenses as opposed to the PCA forecast. The Company will also
include a table that contains actual generation and expenses by resource type.
III. CONCLUSION
Idaho Power acknowledges and appreciates Staff's review of the Company's PCA
filing and its conclusions that the filed PCA components appropriately calculate the 2024-
2 Staff Comments, p. 9.
3 Id.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

2025 PCA rates under the currently approved methodology and that the NPSE incurred
during the 2022-2023 PCA year was prudent. The Company respectfully requests that
the Commission approve its filing to implement PCA rates effective June 1, 2024. In
addition, Idaho Power supports Staff's recommendation for the Company to keep the
Commission and Staff apprised of changes to the PCA forecast that could warrant an out-
of-cycle PCA adjustment. Lastly, the Company is supportive of Staff's requests to: (1)
search for solutions to mitigate NPSE risk and to discuss the related efforts in next year's
PCA filing and (2) adjust its annual testimony to focus more on actual generation and
expenses.
DATED at Boise, Idaho, this 22nd day of May 2024.
�-%r T I
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS -4

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of May 2024, 1 served a true and correct
copy of Idaho Power Company's Reply Comments upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Chris Burdin U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8, FTP Site
Suite 201-A (83714) X Email: Chris.Burdin(a)puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
«unt
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 5