20240612Staff Comments.pdf

RECEIVED
Wednesday, June 12, 2024 10:52:58 AM
IDAHO PUBLIC
UTILITIES COMMISSION
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
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 UPDATE THE ) CASE NO. IPC-E-24-19
COLSTRIP-RELATED ADJUSTABLE )
PORTION OF ITS AVOIDED COST RATES )
FOR EXISTING PURPA CONTRACTS ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Michael Duval, Deputy Attorney General, submits the following
comments.
BACKGROUND
On May 9, 2024, Idaho Power Company ("Company") petitioned the Idaho Public
Utilities Commission ("Commission) for an order implementing the annual update to the
Colstrip-related adjustable portion of the published avoided cost rates for certain qualifying
facilities ("QF") under the Public Utility Regulatory Policies Act of 1978 ("Petition"). The
annual update to the Colstrip Method is proposed to be effective from July 1, 2024.
In 1999, the Commission established a method for the annual adjustable-rate portion of
avoided costs for those QF contracts using variable costs associated with Colstrip—a coal-fired
generating facility in southeast Montana. Order No. 28708, Case No. GNR-E-99-01.
STAFF COMMENTS 1 JUNE 12, 2024

Beginning in 2024, Order No. 35841 required the Company, instead of Staff, to file the
annual updates to the Colstrip-related adjustable portion of avoided cost rates. The Company
filed the Petition to comply with the Commission's Order.
STAFF ANALYSIS
The Company proposes that the Colstrip-related adjustable-rate change from 21.67
mills/kilowatt hour("kWh") to 22.74 mills/kWh effective July 1, 2024. Staff has reviewed the
methodology used to determine the rate and believes that it complies with Order No. 28708 and
that the resulting rate is correct. Staff recommends the Commission approve this request
effective July 1, 2024.
STAFF RECOMMENDATION
Staff recommends the Commission approve the Colstrip-related adjustable rate of 22.74
mills/kWh with an effective date of July 1, 2024.
Respectfully submitted this 121h day of June 2024.
e '
Michael Duval
Deputy Attorney General
Technical Staff. Yao Yin
1:AUtility\UMISC\COMMENTS\IPC-E-24-19 Comments.docx
STAFF COMMENTS 2 JUNE 12, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1� DAY OF JUNE 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN CASE
NO. IPC-E-24-19, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER CAMILLE CHRISTEN
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: cchristengidahopower.com
E-MAIL: dwalkergidahopower.com
mgoico echeaal l engidahopower.com
docketsgidahopower.com
PATRICIA JORDAN SECRETARY
CERTIFICATE OF SERVICE