20241010Comments.pdf

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RLM POWER.
An IDACORP Company
RECEIVED
Thursday, October 10, 2024
DONOVAN WALKER IDAHO PUBLIC
Lead Counsel UTILITIES COMMISSION
dwalker(WJdahopower.com
October 10, 2024
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. GNR-E-24-01
Commission Staff's Application to Update Inputs to the "Surrogate Avoided
Resource" Method Avoided Cost Rates
Dear Commission Secretary:
Attached for electronic filing, please find Comments of Idaho Power Company in the
above-entitled matter. If you have any questions about the attached document, please do
not hesitate to contact me.
Sincerely,
Donovan Walker
DEW:cd
Enclosures
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalkerCcDidahopower.com
mgoicoecheaal lenCo�_idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION )
STAFF'S APPLICATION TO UPDATE ) CASE NO. GNR-E-24-01
INPUTS TO THE SURROGATE AVOIDED )
RESOURCE METHOD AVOIDED COST )
RATES ) COMMENTS OF IDAHO POWER
COMPANY
Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho
Public Utilities Commission ("Commission") Rule of Procedure 201 , et seq., and the
applicable provisions of the Public Utility Regulatory Policies Act of 1978 ("PURPA"), as
well as the Commission's Notice of Modified Procedure in this matter, Order No. 36314,
hereby respectfully submits the following Comments regarding Staff's Application to
Update SAR Model and SAR-Based Avoided Cost Rates.
Pursuant to Order No. 32802, Commission Staff ("Staff") annually updates inputs
to the surrogate avoided resource ("SAR") avoided cost methodology. Though the
updates were initially done by letter, in April 2020 the Commission issued Order No.
COMMENTS OF IDAHO POWER COMPANY - 1

34628 wherein it approved Staff's recommendation to formalize the process going
forward though it emphasized that the "... update is still intended to be a simple arithmetic
calculation to an established methodology."'
On August 16, 2024, Staff initiated the instant case with the Commission seeking
an order updating the natural gas price forecast inputs used in the SAR avoided cost
methodology; separating the current SAR model (used to calculate avoided cost rates for
Avista, Idaho Power, and Rocky Mountain Power) into three utility-specific models; and
approving the SAR-based avoided cost rates attached to Staff's Application. Idaho Power
does not object to Staff's proposed administrative changes to the SAR model, as
described in more detail below, and recommends further that the Commission approve
the published avoided cost rates proposed by Staff.
I. Proposed Natural Gas Price Forecast
As Staff explains in its application, historically the U.S. Energy Information
Administration's ("EIA")Annual Energy Outlook gas price forecast was published annually
and used in the SAR model. In 2024, however, EIA did not publish its Annual Energy
Outlook because its modeling system required updates to better model certain emerging
technologies. As an alternative gas price forecast for 2024, and until the EIA resumes
publishing its Annual Energy Outlook, Staff proposes to use the average of four hub gas
price forecasts published by the Northwest Power and Conservation Council.
Specifically, Staff proposes to use an average of prices for AECO Hub, Stanfield Hub,
Sumas Hub, and Opal Hub, published in December 2023. Idaho Power believes this
approach is reasonable and agrees with Staff's analysis regarding the criteria that were
In the Matter of the Annual Update to "Surrogate Avoided Resource"Avoided Cost Rates, Case No.
GNR-E-20-01, Order No. 34628 at 1 (Apr. 16, 2020).
COMMENTS OF IDAHO POWER COMPANY - 2

considered.
II. Separation of the SAR Model into Individual Utility-Specific Models
Idaho Power agrees with Staff's recommendation to separate the SAR model into
individual utility-specific models. As Staff describes, this separation will mitigate the risk
of outdated data and mismatches of the timing of approval of utility-specific updates.
Further, Idaho Power believes that utility-specific SAR models may also be clearer for
stakeholders and may allow each model to be more streamlined. For these reasons,
Idaho Power does not object to Staff's proposal in this regard.
III. Updated Models and Avoided Cost Rates
Finally, the Company reviewed the Idaho Power-specific SAR model provided by
Staff, which includes Staff's proposed natural gas price forecast, and finds that the
resulting SAR-based avoided cost rates for Idaho Power are accurate. As such, Idaho
Power recommends the Commission approve the updated published avoided cost rates
as proposed in the attachment to Staff's Application.
Respectfully submitted this loth day of October, 2024.
DONOVAN E. WALKER
Attorney for Idaho Power Company
COMMENTS OF IDAHO POWER COMPANY - 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this loth day of October, 2024, 1 served a true and
correct copy of the within and foregoing COMMENTS OF IDAHO POWER COMPANY
upon the following named parties by the method indicated below, and addressed to the
following:
Adam Triplett Hand Delivered
Deputy Attorney General U.S. Mail
Idaho Public Utilities Commission Overnight Mail
P.O. Box 83720 FAX
Boise, ID 83720-0074 X Email - adam.triplett(c)_puc.idaho.gov
Mike Louis Hand Delivered
Idaho Public Utilities Commission U.S. Mail
P.O. Box 83720 Overnight Mail
Boise, ID 83720-0074 FAX
X Email - mike.louis(a-).puc.idaho.gov
Vl
Christy Davenport, Legal Assistant
COMMENTS OF IDAHO POWER COMPANY - 4