20250507Comments.pdf

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RECEIVED
MEGAN GOICOECHEA ALLEN May 07, 2025
Corporate Counsel IDAHO PUBLIC
mgoicoecheaallenC�idahopower.com UTILITIES COMMISSION
May 7, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-25-18
Commission Staff's Application to Update Inputs to the Surrogate Avoided
Resource ("SAR") Model and SAR-Based Avoided Cost Rates
Dear Commission Secretary:
Attached please find the Comments of Idaho Power Company to be filed in the above-
entitled matter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
TI G���t UkJCIU'�l
Megan Goicoechea Allen
MGA:cd
Attachments
1221 W. Idaho St(83702)
P.O.Box 70
Boise, ID 83707

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
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION )
STAFF'S APPLICATION TO UPDATE ) CASE NO. IPC-E-25-18
INPUTS TO THE SURROGATE AVOIDED )
RESOURCE ("SAR") MODEL AND SAR- ) COMMENTS OF IDAHO POWER
BASED AVOIDED COST RATES ) COMPANY
Idaho Power Company ("Idaho Power" or "Company"), in accordance with
Commission Rule of Procedure 203 and the applicable provisions of the Public Utility
Regulatory Policies Act of 1978 ("PURPA"), as well as the Idaho Public Utilities
Commission's ("Commission") Notice of Modified Procedure in this matter, Order No.
36551 , hereby respectfully submits the following Comments.
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.
34628 wherein it approved Staff's recommendation to formalize the annual update to
COMMENTS OF IDAHO POWER COMPANY - 1

inputs to the SAR avoided cost methodology going forward and clarified that, "...this
update is still intended to be a simple arithmetic calculation to an established
methodology".'
On April 7, 2025, Staff applied to the Commission for an order updating the natural
gas price forecasts used in the SAR avoided cost methodology and approving the
resulting SAR-based avoided cost rates with a proposed effective date of June 1 , 2025.
The Company has reviewed the information in Staff's Application and the SAR model
provided by Staff in the case file, which includes updated gas price forecast inputs to the
SAR model based on the Northwest Power and Conservation Council's forecasts for its
Ninth Power Plan.2 Idaho Power believes the natural gas forecast utilized by Staff has
been correctly updated in the model and agrees that the calculations for the Company
are consistent with the SAR methodology approved by the Commission.
Respectfully submitted this 7th day of May, 2025.
jNr?I W�ict 96
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
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).
2 In the Matter of Commission Staffs Application to Update Inputs to the Surrogate Avoided Resource
("SAR') Model and SAR-Based Avoided Cost Rates, Case No. IPC-E-25-18, Application at fn. 1 (Apr. 7,
2025).
COMMENTS OF IDAHO POWER COMPANY - 2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 7th day of May, 2025, 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:
Chris Burdin 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 chris.burdin(a).puc.idaho.gov
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Christy Davenport, Legal Assistant
COMMENTS OF IDAHO POWER COMPANY - 3