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Home My WebLink About20250407APPLICATION.pdf RECEIVED April 07, 2025 IDAHO PUBLIC UTILITIES COMMISSION CHRIS BURDIN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208)334-0314 IDAHO BAR NO. 9810 Street Address for Express Mail: 11331 W CHINDEN BVLD,BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF COMMISSION STAFF'S ) CASE NO. IPC-E-25-18 APPLICATION TO UPDATE INPUTS TO THE ) SURROGATE AVOIDED RESOURCE ("SAR") ) APPLICATION MODEL AND SAR-BASED AVOIDED COST ) RATES ) Commission Staff("Staff'),pursuant to Commission Rule of Procedure 52,the applicable provisions of the Public Utility Regulatory Policies Act of 1978 ("PURPA"), and as directed by Order No. 34628, respectfully applies to the Idaho Public Utilities Commission("Commission") for an order updating inputs to the Surrogate Avoided Resource ("SAW') Model and approving the SAR-based avoided cost rates attached to this Application. I. BACKGROUND The Commission calculates and publishes SAR-based avoided cost rates for qualifying facilities("QF")that are under the applicable resource type project eligibility cap. In Order No. 32697, the Commission found it was appropriate to annually update the SAR Model with the most recent gas forecast provided by U.S.Energy Information Administration's("EIA")Annual Energy Outlook, specifically the Mountain Region Reference Case forecast. Subsequently, the Commission issued Order Nos. 32737 and 32802 to clarify that the annual update of the EIA gas forecast should occur on June 1 or within 30 days of the final release of the EIA Annual Energy Outlook, whichever is later. Order No. 32737 at 7 and Order No. 32802 at 3. APPLICATION 1 Since then, Staff has used this data source for the annual natural gas forecast update for the SAR Model. However, EIA did not publish Annual Energy Outlook in 2024, because their modeling system required substantial updates to better model hydrogen, carbon capture, and other emerging technologies. Because that information was not published, in Case No. GNR-E- 24-01, Staff proposed using the average of AECO Hub prices, Stanfield Hub prices, Sumas Hub prices, and Opal Hub prices from the natural gas price forecast published by Northwest Power and Conservation Council ("NWPCC") for the annual update. On December 9, 2024, the Commission issued Order No. 36416 approving Staffs proposal. The Commission explained: [O]ur approval of Staff s Application should not be interpreted as permanently modifying the inputs and method for updating the SAR Model. Rather, this approval shall continue only until the EIA publishes its next Annual Energy Outlook that can be used to update the SAR Model. Additionally,we direct Staff to notify the Commission if the EIA does not issue an Annual Energy Outlook within the next 12 months following the service date of this final order. Order No. 36416 at 3. II. UPDATED MODELS AND AVOIDED COST RATES Staff updated the SAR Model and its avoided cost rates based on the proposed natural gas price forecast as attachments to this Application for Idaho Power Company("Company"): • Avoided Cost Model Order No. XXXXX ver June 1, 2025 Annual Gas Update (IPCO).xlsm; • Attachment A IPCO Avoided Cost Rates for New Contracts • Attachment B IPCO Avoided Cost Rates for Renewal Contracts Natural Gas Price Forecast The updates to the natural gas price forecast use the same method approved in Case No. GNR-E-24-01, the results of which are shown in Table No. 1 below. The method calculates the average of AECO Hub prices, Stanfield Hub prices, Sumas Hub prices, and Opal Hub prices from the 2025 natural gas price forecast published by NWPCC for the annual update in this case.' In Order No. 36416, the Commission authorized the use of this method until the EIA publishes its next Annual Energy Outlook that can be used to update the SAR Model. As of April 1, 2025, the EIA has not released the Annual Energy Outlook for 2025. 1 Data source:"Ninth Plan Natural Gas Price Forecast"located at hgps://www.nwcouncil.oriz/enerlz /�powep2lan/elements-and-inputs/ APPLICATION 2 Table No. 1: Proposed Natural Gas Forecast based on Four Hubs Year AECO Sumas Opal Stanfield Average 2025 2.38 3.51 3.45 3.38 3.18 2026 2.77 4.05 4.04 3.96 3.70 2027 3.00 5.20 5.05 4.86 4.53 2028 3.21 5.55 5.41 5.21 4.85 2029 3.38 5.81 5.69 5.48 5.09 2030 3.55 5.11 5.21 5.11 4.74 2031 3.55 5.11 5.21 5.11 4.74 2032 3.79 5.44 5.57 5.48 5.07 2033 4.19 5.99 6.18 6.08 5.61 2034 4.27 6.10 6.31 6.20 5.72 2035 4.43 6.33 6.55 6.44 5.94 2036 4.51 6.44 6.67 6.56 6.04 2037 4.68 6.66 6.91 6.80 6.26 2038 5.00 7.10 7.40 7.28 6.70 2039 5.20 7.38 7.71 7.58 6.97 2040 5.42 7.68 8.04 7.91 7.26 2041 5.55 7.86 8.23 8.10 7.43 2042 5.74 8.11 8.51 8.38 7.68 2043 6.02 8.50 8.94 8.80 8.06 2044 6.31 8.90 9.39 9.24 8.46 2045 6.62 9.33 9.85 9.70 8.88 2046 6.89 9.70 10.26 10.10 9.24 2047 7.17 10.08 10.68 10.52 9.61 2048 7.46 10.48 11.12 10.95 10.01 2049 7.77 10.90 11.58 11.40 10.41 2050 8.08 11.33 12.06 11.87 1 10.83 III.MODIFIED PROCEDURE Staff believes that a hearing is not necessary to consider the issues presented herein and respectfully requests that this Application be processed by Modified Procedure; i.e., by written submissions rather than by hearing. RP 201, et seq. If, however, the Commission determines that a technical hearing is required, Staff stands ready to prepare and present its testimony in such a hearing. IV. COMMUNICATIONS AND SERVICE OF PLEADINGS Communications and service of pleadings,exhibits,orders,and other documents relating to this proceeding should be sent to the following: APPLICATION 3 Chris Burdin Yao Yin Deputy Attorney General Idaho Public Utilities Commission P.O. Box 83720 P.O. Box 83720 Boise, ID 83702-0074 Boise,ID 83702-0074 Chris.burdin(a,puc.idaho.gov yao.yin@puc.idaho.gov V. REQUEST FOR RELIEF Staff respectfully requests the Commission issue an order: (1) authorizing this matter to be processed by Modified Procedure; (2) approving the updated SAR Model for Idaho Power Company with an effective date of June 1, 2025; and(3)approving the avoided cost rates shown in the attachments to this Application with an effective date of June 1, 2025. Respectfully submitted this 7th day of April 2025. 0�" )—� A- Chris Burdin Deputy Attorney General APPLICATION 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 7tn day of April 2025, I served the foregoing APPLICATION,in Case No. IPC-E-25-18,Via E-Mail to the following: Donovan Walker Camille Christen Idaho Power Company 1121 W. Idaho Street 83702 P.O. Box 70 Boise, ID 83707-0070 dwalker0)idahopower.com CChristenkidahopower.com dockets(kidahopower.com energycontracts k idahopower.com KERI J. AAWKER Legal Assistant APPLICATION 5