20241015Annual Compliance Filing.pdf

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POWER®
An IDACORP Company
RECEIVED
MEGAN GOICOECHEA ALLEN
Tuesday, October 15, 2024
Corporate Counsel IDAHO PUBLIC
mgoicoecheaallen(�i_)idahopower.com UTILITIES COMMISSION
October 15, 2024
VIA ELECTRONIC MAIL
Commission Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714
Re: Case No. I PC-E-24-40
Idaho Power Company's Annual Compliance Filing to Update the Load and
Gas Forecast in the Incremental Cost Integrated Resource Plan Avoided
Cost Model
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Annual Compliance Filing
in the above-entitled matter. If you have any questions about the attached documents,
please do not hesitate to contact me.
Attachment No. 1 to the Annual Compliance Filing is confidential. Please handle
the confidential information in accordance with the Protective Agreement to be executed
in this matter.
Very truly yours,
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Megan Goicoechea-Allen
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Enclosures

MEGAN GOICOECHEA 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]
mgoicoecheaallen(a-),idahopower.com
dwalker(a-)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY'S ANNUAL )
COMPLIANCE FILING TO UPDATE THE ) CASE NO. IPC-E-24-40
LOAD AND GAS FORECASTS IN THE )
INCREMENTAL COST INTEGRATED ) IDAHO POWER COMPANY'S
RESOURCE PLAN AVOIDED COST ) ANNUAL COMPLIANCE FILING
MODEL. )
Idaho Power Company ("Idaho Power" or "Company") hereby respectfully submits
to the Idaho Public Utilities Commission ("Commission") this filing in compliance with
Order Nos. 32697 and 32802 to update the load forecast, natural gas forecast, and long-
term contract changes used in the Incremental Cost Integrated Resource Plan ("ICIRP")
avoided cost methodology. Additionally, in compliance with Order No. 34913, this filing
confirms the Peak Hours and Premium Peak Hours used to calculate capacity payments
for energy storage qualifying facilities ("QF").
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 1

I. INTRODUCTION
In its final Order No. 32697, the Commission determined that the inputs to the
ICIRP avoided cost methodology, utilized for all proposed Public Utility Regulatory
Policies Act of 1978 ("PURPA") QF projects that exceed the published rate eligibility cap,
will be updated every two years upon acknowledgement of the utility's Integrated
Resource Plan ("IRP") filing, with the exception of the load forecast and the natural gas
forecast, which should be updated annually. Discussing the timetable for updates to the
ICIRP Methodology the Commission explained:
We find that, in order to maintain the most accurate and up-
to-date reflection of a utility's true avoided cost, utilities must
update fuel price forecasts and load forecasts annually —
between IRP filings . . . In addition, it is appropriate to consider
long-term contract commitments because of the potential
effect that such commitments have on a utility's load and
resource balance . . . We further find it appropriate to consider
PURPA contracts that have terminated or expired in each
utility's load and resource balance. We find it reasonable that
all other variables and assumptions utilized within the IRP
Methodology remain fixed between IRP filings (every two
years).
Order No. 32697, p. 22. Though the Commission originally set June 1 as the annual filing
date, it agreed on reconsideration that updates to gas and load forecasts used in the
ICIRP methodologies should occur on October 15 of each year. Order No. 32802, p. 3.
In considering implementation of PURPA with respect to energy storage QFs, the
Commission determined that the avoided cost of capacity should be paid only on
production during the hours identified as the Company's Peak Hours and Premium Peak
Hours. Order No. 34794, p. 14. The Commission also agreed that the updates to Peak
and Premium Peak Hours should be included in the annual October 15 update to the
other ICIRP method inputs. Order No. 34913, p. 6.
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 2

The load forecast, natural gas forecast, contract information, and Peak Hours and
Premium Peak Hours designations for battery storage capacity payments that are set
forth below are presented in compliance with the pertinent Commission Orders and will
be incorporated into Idaho Power's ICIRP avoided cost methodology. Consistent with the
Commission's directives, this methodology will be used by Idaho Power as the starting
point for the negotiation of its contractual avoided cost rates as of January 1, 2025.
II. LOAD FORECAST
Consistent with prior updates, Idaho Power is updating its load forecast to the most
recent available 50th percentile forecast. Idaho Power's most recent load forecast from
September 2024 shows an increase in customer loads over the 20-year period, as
compared with the September 2023 load forecast used in the Company's previous annual
update approved in December 2023.' The increase is due to the Company's re-estimation
of all major retail customer class usage and growth as well as updates related to electric
service agreements and special contracts to include the most recent assessment of load
and energy requirements by those customers. The updated load forecast and a
comparison to the September 2023 load forecast is included in Confidential Attachment
1. This information is being marked and treated as confidential because it is confidential
and proprietary Company information that has not yet been shared publicly.
III. NATURAL GAS PRICE FORECAST
Consistent with the methodology used in the Company's previous annual update
and approved by the Commission in Order No. 36037, the Company intends to use the
'See In the Matter of Idaho Power Company's Filing to Update the Load and Gas Forecasts in the
Incremental Cost Integrated Resource Plan Avoided Cost Model, Case No. IPC-E-23-25, Order No.
36037 (Dec. 26, 2023).
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 3

most recent S&P Platts long-term natural gas forecast, including Henry Hub and Sumas
Basis Annuals (the "Platts long-term forecast"), which was published in September 2024,
to update the natural gas price forecast in ICIRP avoided cost calculations. This is also a
continuation of the methodology employed by the Company for IRP planning case natural
gas prices forecast in its 2023 IRP,2 which was acknowledged by the Commission in
Order No. 36233. The Company continues to believe the Platts long-term forecast is the
most appropriate forecast to use in the inputs to Idaho Power's ICIRP avoided cost model
as more fully explained by the Company in the 2022 load and gas forecast filing, Case
No. IPC-E-22-26.
Because the Platts long-term forecast is subscription-based and proprietary, this
information has been included in Confidential Attachment No. 1, which contains a table
and a graph setting forth information from the Platts long-term forecast published
September 2024 compared with the Company's September 2023 natural gas forecast,
which was included in last year's load and gas forecast filing, Case No. IPC-E-23-25. The
most recent Platts long-term forecast reflects an approximate average two percent
increase in natural gas prices compared to the Company's last update.
IV. CONTRACT TERMINATIONS, EXPIRATIONS, AND ADDITIONS
Idaho Power currently has six non-PURPA, long-term power purchase agreements
with projects that are online: Elkhorn Valley Wind (101 megawatts ("MW")), Raft River
Geothermal (13 MW), Neal Hot Springs Geothermal (22 MW), Jackpot Solar (120 MW),
Black Mesa Energy Solar (40 MW), and Franklin Solar (100 MW). Franklin Solar came
online in June 2024.
2 In the Matter of Idaho Power Company's 2023 Integrated Resource Plan, Case No. IPC-E-23-23,
Application (filed Sep. 29, 2023).
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING -4

Idaho Power currently has 129 contracts with online PURPA QFs with a total
nameplate capacity of 1,128.58 MW.3 Included in this update are two replacement Energy
Sales Agreements ("ESA") for existing Idaho QF projects totaling 17.8 MW.
Table 1 below provides a list of new and terminated contracts since the last update
in October 2023. New ESAs and terminated or expired contracts, as well as new complete
ESA applications, are all included in the ICIRP model on a continuous basis. New and
Commission-approved non-PURPA power purchase agreements or resource
acquisitions are also included in the model on a continuous basis.
Table 1: Contract Updates
Projects Active and Online'
Resource
Tvpe Project Name State Contract Date Project Size(MW) IPUC Case Number
Hydro Rock Creek II ID 6/15/2024 1.9 IPC-E-24-09
15.9(10 a MW
CoGen Simplot Pocatello ID 9/17/2024 energy or less) not yet submitted
TOTAL 17.8
Note 1:This section lists new contracts with existing facilities(i.e.,PURPA replacement contracts)that have been
entered into since last year's update.The title of this section may be changed from"Projects Active and Online"to
something more specific in future updates.
Projects Not On-Linen
Resource Contract
Type Project Name State Type Contract Date Project Size(MW) IPUC Case Number
Solar PVS2 ID Non-PURPA 12/8/2023 125 IPC-E-24-01
TOTAL 125
Note 2:This section lists new PURPA contracts with projects that are not yet online that have been entered into since
last year's update,as well as new non-PURPA contracts that have been executed and Commission-approved since
last year's update.
Terminated/Expired Agreements3
Contract
Resource Contract Termination
Type Project Name State Type Date Project Size WWI IPUC Case Number
Solar Prairie City OR PURPA 1/29/2024 29.3 N/A
Solar Moores Hollow OR PURPA 1/29/2024 42 N/A
Hydro Tiber Dam MT PURPA 6/1/2024 7.5 IPC-E-03-01
TOTAL 78.8
Note 3:This section lists PURPA and non-PURPA contracts that have expired orterminated since last year's update.
s Since last year's update, one operating QF's contract expired and was not renewed (Tiber Dam,shown in Table
1),and one QF with a signed contract achieved commercial operation (Coleman Hydro, .8 MW,shown as a new
signed contract in the contract update in Case No. IPC-E-20-35).
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 5

V. PEAK AND PREMIUM PEAK HOURS
Idaho Power has refreshed its analysis of Peak Hours and Premium Peak Hours
for 2024, using the same methodology as directed by the Commission in Order No. 34913
and the same data sources as used in prior analyses of these hours. Specifically, Idaho
Power has identified the forecasted peak hours in 2025 using the updated average hourly
load forecast, and additionally, it has also refreshed its analysis of load from 2024, net of
solar generation, and Western Energy Imbalance Market ("WEIM") prices from 2024. This
updated information is included in Confidential Attachment 1. This information is being
treated as confidential because it contains the latest load forecast information, which is
non-public, confidential, and proprietary as described above for the load forecast update.
The updated data illustrates that the Peak and Premium Peak Hours remain the
same as identified in last year's update. More specifically, an analysis of the most recent
data including the updated underlying load forecast, current year actual load net of solar,
and current WEIM pricing, highlights generally the same hours as last year's analysis and
no change was made as a result. The Peak Hours for 2025 for July are 1:00 pm through
the 9:00 pm hour (to 10:00 pm). For August, the Peak Hours are 3:00 pm through the
7:00 pm hour (to 8:00 pm). The Premium Peak Hours for July are 5:00 pm through the
9:00 pm hour (to 10:00 pm. The Premium Peak Hours for August are 5:00 pm through
the 7:00 pm hour (to 8:00 pm).
As in last year's update, Idaho Power also evaluated Loss of Load Probability
("LOLP") data from the 2023 IRP's Preferred Portfolio. The Company's internally
developed Reliability & Capacity Assessment Tool ("RCAT") calculates the probability of
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 6

demand exceeding generation for every hour in the IRP planning horizon (20 years).4 The
RCAT short-term analysis used in the 2023 IRP shows that the hours with the highest
LOLP values are concentrated over the summer in the late afternoon/evening hours.5
Idaho Power uses the LOLP results in this context to validate the reasonableness of the
Peak Hours and Premium Peak Hours that are identified by looking at forecasted load,
current year load net of solar, and current year WEIM pricing. The fact that the highest
LOLP values occur in the summer late afternoon/evening hours supports the Peak Hours
and Premium Peak Hours that have been identified here.
As a result, Idaho Power's Peak and Premium Peak Hour definitions for battery
storage capacity payments remain as follows:
Peak Hours: Hours that occur in July starting at 1:00 PM and
ending at 9:59:59 PM, and hours that occur in August starting
at 3:00 PM and ending at 7:59:59. Peak Hours are subject to
change annually.
Premium Peak Hours: Hours that occur in July, starting at 5:00
PM and ending at 9:59:59 PM, and hours in that occur in
August, starting at 5:00 PM and ending at 7:59:59 PM.
Premium Peak Hours are subject to change annually.
Finally, in a number of other proceedings, Idaho Power has applied the LOLP
methodology to identify the capacity-based timing of risk for application to pricing,
performance, program parameters, etc.6 As mentioned in last year's update, Idaho Power
previously discussed with Staff the possibility of shifting from the methodology described
above for determining Peak and Premium Peak Hours to the capacity based LOLP
4 An in-depth discussion of the LOLP calculation method, process, and results can be found in the Loss of
Load Expectation section of the 2023 IRP's Appendix C—Technical Report filed in Case No. IPC-E-23-
23.
5 Id.
6 See, e.g., Case Nos. IPC-E-21-32, IPC-E-22-22, IPC-E-23-11, and IPC-E-23-14.
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 7

methodology, and the Company continues to evaluate whether such a change would be
appropriate. If the Company determines that shifting the methodology for identifying Peak
and Premium Peak Hours is advisable, it will seek Commission approval via a stand-
alone application.
VI. CONCLUSION
Idaho Power hereby respectfully submits this updated load forecast, natural gas
forecast, contract information, and Peak and Premium Peak Hours in compliance with the
Commission's directives in Order Nos. 32697, 32802, and 34913 and requests that the
Commission accept and approve the same.
Respectfully submitted this 15th day of October 2024.
a
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 8

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-40
IDAHO POWER COMPANY
CONFIDENTIAL ATTACHMENT 1
Load Forecast, Natural Gas Price Forecast, and
Updated Analysis Regarding Peak and Premium
Peak Hours

ATTACHMENT 1
IS CONFIDENTIAL AND WILL BE PROVIDED TO THOSE PARTIES THAT EXECUTE
THE PROTECTIVE AGREEMENT IN THIS MATTER