20200417IPC to Staff 1-5.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

April 17, 2020

VIA ELECTRONIC FILING

Diane Hanian, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-20-02
Idaho Power Company’s Petition to Establish Avoided Cost Rates and Terms
for Energy Storage Qualifying Facilities under PURPA

Dear Ms. Hanian:

Attached for electronic filing in the above matter is Idaho Power Company’s
Response to the First Production Request of the Commission Staff.

If you have any questions about the enclosed documents, please do not hesitate to
contact me.

Very truly yours,

Donovan Walker

DEW/ cld
Enclosures
RECEIVED
2020 April 17,AM9:25
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
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]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S PETITION TO ESTABLISH
AVOIDED COST RATES AND TERMS FOR
ENERGY STORAGE QUALIFYING
FACILITIES UNDER PURPA
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CASE NO. IPC-E-20-02

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated March 27, 2020, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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REQUEST NO. 1: If an energy storage facility is used to time shift generation
output from a dedicated renewable generation source, and if both the generator and the
storage facility are operationally controlled and dispatched by the QF, please explain
the feasibility of a configuration requiring two separate QFs: one QF, contract, and
avoided cost rate for energy taken directly to load from the generation facility; and
another QF, contract, and avoided cost rate for the energy taken directly to load from
the storage facility. In addition, please answer the following for this configuration:
a. Please explain the technical feasibility to separately measure/meter the
amount of energy from the generation QF that is taken directly to load (total generated
energy minus generated energy that is stored in the energy storage QF to be
dispatched later), from the amount of energy from the energy storage QF taken directly
to load (generated energy that was stored in the energy storage QF minus storage
efficiency losses).
b. If technically feasible, please describe the facilities and equipment
required and provide a diagram showing how the facilities, meters, and equipment
would need to be configured for both QFs.
c. Please identify and describe the types of cost that would be avoided for
output taken to load from the generation QF.
d. For each type of cost identified above for the generation QF, please
describe the Company’s preferred method for deriving an accurate avoided cost rate for
published rates and for negotiated rates.
e. Please identify and describe the types of cost that would be avoided for
output taken to load from the energy storage QF.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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f. For each type of cost identified above for the energy storage QF, please
describe the Company’s preferred method for deriving an accurate avoided cost rate for
published rates and for negotiated rates.
g. For this particular configuration, please describe the responsibilities of the
QFs and of the Company for all aspects of operation.
h. Currently, all QF’s are required to adhere to 90/110 firmness
requirements. Would the 90/110 firmness requirements be feasible in its current form
for both the generation QF and the energy QF? If not, how would it need to change?
i. For this particular configuration and the Company’s preferred method of
deriving avoided cost, please identify and describe any contract terms and conditions
that may be necessary for either QF.
RESPONSE TO REQUEST NO. 1: The hypothetical examples described in
Request No. 1 identify two possible configurations of a project with generation and a
storage facility. While either scenario presented in Request No. 1 is possible, neither is
preferable as QFs are incented to deliver as much energy as possible during periods of
time that avoided cost prices are highest to the purchasing utility without regard for the
timing or quantity of deliveries on utility operations. From Idaho Power’s (“the
Company”) perspective as it relates to a battery storage Qualifying Facility (“QF”), a
project could be developed under multiple configurations. These could include: 1. a
stand-alone battery storage QF, 2. a hybrid QF consisting of generation (including wind
or solar) plus battery storage, or 3. a hybrid project consisting of generation (including
wind or solar) plus battery storage operating as a single facility but as two separate
QFs. If a single project was configured as separate QFs, Idaho Power would require the
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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project to be configured, constructed and metered so that the Company doesn’t pay
twice for the same output of generation. If the output from a battery storage QF is
determined based on the same methodology as the wind or solar generation, then the
time shift wouldn’t matter as the price is determined and set based on the time and
amount of energy delivered to the Company and the highest cost displaceable
Company resource running during that same hour.
To be clear, Idaho Power’s petition in Case No. IPC-E-20-02 (“Petition”), is for
the Idaho Public Utilities Commission (“Commission”) to determine that energy storage
QFs over 100 kW are entitled to and eligible for negotiated avoided cost rates
determined by the incremental cost Integrated Resource Plan (“ICIRP”) methodology
and a maximum contract term of two years.
In the ICIRP methodology, the only way to capture the avoided cost of a battery
storage QF, or any other type of QF, is by its own specific generation profile that
identifies the hourly output the QF intends to deliver. Although Staff’s Request No. 1 has
asked about particular configurations, there are many that are possible under the ICIRP
pricing methodology and contract template. The key is that an individual generation
profile from the QF is provided, regardless of the configuration. It would be different if
the methodology was specific to a resource type, but under the ICIRP methodology, its
solely dependent on the hourly generation profile provided by the QF. If a QF obtains an
energy sales agreement (“ESA”) that is based on the ICIRP methodology and is unable
to deliver generation in accordance with its generation profile and the ESA, there are
provisions within the ESA that would result in the QF being paid either a market-based
price or an adjusted contract price.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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a. It is feasible to separately measure the amount of energy from the
generation QF that is taken directly to load and from the energy storage QF taken
directly to load. The system would have to be configured in what is known as a Tightly
Direct Current (“DC”) Coupled system to ensure the energy storage QF is being
charged solely by the generation QF.
b. There are four main types of configurations of storage coupled with
generation. Table 1 described the four types and their main characteristics. This table
and the following examples use solar photovoltaics (“PV”) as the generation resource.
The only configuration that guarantees that the storage system is solely charged by the
generation QF is the DC-Tightly Coupled. An Alternating Current (“AC”)-Coupled
system might be able to prevent the storage system from charging from the grid by
installing a plant controller and allowing the battery to charge only when the net power
(PV output minus auxiliary loads) is positive.
Table 1 Types of Configuration
Type of Coupling Co-located Point of Common
Coupling
Energy Stored
Independent No None Grid (including PV
virtually though
market)
AC-Coupled Yes Transmission/Feeder Grid or PV
DC-Coupled Yes Inverter Grid or PV
DC-Tightly Coupled Yes Inverter Only PV

Independent
In an independent configuration the PV and Storage can be sited in completely
different locations. The PV and the storage system do not share any hardware. The
storage system charges from any grid source.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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PV Modules Utility GridInverter
(DC – AC)
BT1
Bi-
directional
Inverter
and BMS
Utility Grid
Figure 1 Typical Independent Configuration Diagram

AC-Coupled
In an AC-coupled system the generation source and storage system do not share
any significant hardware. The storage system has its own inverter/charge and it is tied
on the AC-side with the generation source in a dedicated AC bus. The storage system
can be charged from the generation source or from the grid.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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++
DC
AC M
Utility GridPV Array
Battery Storage
DC to AC
only
Padmount
Point of
Interconnection
DC
AC
Bi-
directional
converter
Figure 2 Typical AC-Coupled Configuration Diagram

DC-Coupled
A DC-Coupled system is where the generation source and storage system share
a converter. The storage system can be charged from either the generation source or
the grid. The storage system will receive the energy from the generation source if the
output of the generation source is greater than the inverter rating, forcing the excess
energy towards the storage system. The storage maximum discharge rate equals the
converter rating minus the generation output at any given time.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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Figure 3 Typical DC-couple Configuration Diagram

DC-Tightly Coupled
A DC-Tightly Coupled system is where the converter only works as an inverter
(DC to AC only), ensuring the storage system is solely charged from the generation
source. The storage maximum discharge rate equals the inverter rating minus the
generation output at any given time. The measurements of energy delivered by the
generation QF and the storage system QF would have to be performed in the DC side.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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Figure 4 DC-Tightly Coupled Metering Configuration
Independently metering of the generation source and storage system is
complicated due to having to perform the measurements on the DC side, and ANSI
rated DC meters are not currently available. Assuming the DC metering issue can be
resolved, at least three DC meters would be required, represented by the blue circles
above, and two meters on the AC side would still be required to account for the losses
in the DC side, the inverter, the padmount transformers, the collector system and the
step-up transformer. A utility scale PV facility will be made-up of multiple DC-Tightly
Coupled modules as shown in Figure 4. This will multiply the number of meters required
by the number of modules needed to achieve the desired point-of-interconnection
rating. Metering on the DC side will also require that utility personnel have access to the
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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developer’s site and the necessary training and equipment to safely operate at non-
utility voltage levels.
c. Aside from what the Commission approved methodology allocates as an
avoided cost, there are none. Avoided cost methodologies are intended to identify the
incremental cost of generation that is avoided by the utility from purchasing the output
from a QF. Through the ICIRP methodology, the avoided cost would be identified by the
hourly avoided cost, which are the costs of the highest displaceable resources that are
operating during the hours the QF intends to deliver its output.
d. As described in subpart c., the most accurate and preferred method is by
using the ICIRP methodology as it allocates an avoided cost specific to the hour the QF
intends to operate and provide generation output.
e. The types of cost that would be avoided for output taken to load from an
energy storage QF are no different than that the avoided cost described in subpart c.
above.
f. The Company’s preferred method for deriving an accurate avoided cost
rate for published rates and for negotiated rates is no different than subpart d. above.
The preferred method is the ICIRP methodology.
g. Under the scenarios presented in Staff’s Request No. 1, the
responsibilities of the QFs and of the Company for all aspects of operation do not
change as the Company has assumed nothing in its Petition other than the historical
PURPA ESA where the QF generates as many kilowatt-hours (“kWh”) as possible, it
delivers all the generation to the purchasing utility to maximize its payments, and Idaho
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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Power purchases the kWh delivered at avoided cost rates established by methodologies
approved by the Commission.
h. Yes. All resource types currently under PURPA contracts with Idaho
Power that are generation QFs have the ability to adhere to 90/110 eligibility
requirements for contract pricing. Compliance with the 90/110 contractual requirements
for PURPA energy storage QFs should be much more attainable because they have a
greater ability to manage precise estimates and output to meet the 90/110
requirements.
i. Idaho Power generally anticipates that no changes would be required to
the ICIRP contract template that has been used for solar projects in Idaho. These
contract templates contain the 90/110 eligibility requirements for contract pricing, and
other pricing adjustment mechanisms that require a QF to deliver output in accordance
with the generation profile that was used to establish the contract prices under the
ICIRP methodology.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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REQUEST NO. 2: If an energy storage facility is used to time shift generation
output from a dedicated renewable generation source, and if both the generator and the
storage facility are operationally controlled and dispatched by the QF, please explain
the feasibility of a combined QF having different rates depending on the type of
generation that is combined with an energy storage facility (storage + wind, storage +
solar, storage + hydro, storage + biomass, etc.). In addition, please answer the
following for this configuration.
a. Please explain the technical feasibility to measure/meter the amount of
energy taken directly to load from the combined QF and describe the facilities and
equipment that would be needed.
b. Please identify and describe the types of cost that would be avoided for
output taken to load from a combined QF.
c. For each type of avoided cost identified above for the combined QF,
please describe the Company’s preferred method for deriving an accurate avoided cost
rate for published rates and for negotiated rates.
d. For this particular configuration, please describe the responsibilities of the
QF and of the Company for all aspects of operation.
e. Currently, all QF’s are required to adhere to 90/110 firmness
requirements. Would the 90/110 firmness requirements be feasible in its current form
for a combined renewable generation facility and energy storage facility QF? If not, how
would it need to change?
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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f. For this particular configuration and the Company’s preferred method of
deriving avoided cost, please identify and describe any contract terms and conditions
that may be necessary.
RESPONSE TO REQUEST NO. 2: The scenario described in Staff’s Request
No. 2., is a hybrid QF consisting of a generation resource and an energy storage facility.
As it would apply to the incremental cost Integrated Resource Plan (“ICIRP”) avoided
cost methodology, the avoided costs would not change depending on the type of
generation that is combined with energy storage, as the avoided costs are based on the
same displaceable resources that are modeled in the methodology. The input that
would affect the price that is established as the avoided cost is the generation profile
that represents the combined generation and storage facility. The generation from the
QF would be priced on an hourly basis by identifying the highest displaceable resource
operating during each hour the QF delivers energy.
a. It is feasible to measure/meter the amount of energy taken from the combined
QF. As previously shown in Response to Staff’s Request No. 1, the only configuration
that guarantees that the storage system would be charged solely by the renewable
generation is the DC-Tightly Couple configuration. For a combined QF facility the
measurement can be taken by one meter on the utility side of the Point of
Interconnection (“POI”), reference Figure 5 below.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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Figure 5 Typical DC-Coupled Configuration Diagram with Metering Shown on the AC
side of the POI

b. See the Company’s Response to Staff’s Request No. 1(c).
c. See the Company’s Response to Staff’s Request No. 1(d).
d. See the Company’s Response to Staff’s Request No. 1(g).
e. See the Company’s Response to Staff’s Request No. 1(h). Compliance
with the 90/110 contractual requirements for PURPA QFs should be much more
attainable for a combined generation and energy storage QF because it should have a
greater ability to manage precise estimates and output to meet the 90/110
requirements.
f. See the Company’s Response to Staff’s Request No. 1(i).

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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REQUEST NO. 3: Please compare the separate generation and energy storage
QF configuration described in Request No. 1 with the combined QF configuration
described in Request No. 2, by providing the advantages and disadvantages of each.
RESPONSE TO REQUEST NO. 3: As a QF selling generation output to a
purchasing utility, the QF will seek to maximize its output, regardless of configuration, in
order to sell the largest amount of kilowatt hours (“kWh”) it possibly can to increase its
revenue. However, the pricing of a sperate generation and storage facility is problematic
because the output associated with an energy storage QF can be controlled and
delivered at a time to take advantage of highest prices rather than any operational need.
The wind, solar or other renewable QF generation would be priced based on the hour
the project delivers generation.
Under the incremental cost Integrated Resource Planning (“ICIRP”)
methodology, pricing is based on the hourly generation profile provided by the project
and a PURPA contract would require that the project deliver in accordance with the
generation profile that was used to establish the prices. As long as the prices are based
on the actual generation profile of the QF, then an energy storage QF is treated in the
same manner as other renewable resources that can be scaled to large facilities, such
as wind and solar.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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REQUEST NO. 4: In its Application, the Company states that “the potential
benefits and possible promise of economically viable, utility-scale energy storage
facilities is in the unique operational characteristics to, for example: provide ancillary
grid services such as reserve capacity, surge capacity, load-balancing, or voltage
support; firming of variable generation; or time-shifting generation to match load.
However, to realize these benefits, it would first of all be necessary for the project to be
configured and operated in such a manner, and secondly it would be necessary for
operational control and dispatchability of the facility to be with the utility charged with
serving load.” Please answer the following:
a. Please describe in detail how the QF would need to be “configured and
operated,” in order to capture the benefits of a utility-scale energy storage facility, as
described above.
b. Would this QF necessarily need to be configured as a “stand-alone”
storage QF facility? Please explain why or why not.
c. Please describe the responsibilities of the QF and of the Company for the
Company’s described configuration. Please include the responsibilities for
obtaining/procuring the energy, scheduling delivery of energy to the QF to be stored,
and dispatching the energy out of the storage facility.
d. Please identify and describe in detail, the specific types of cost that the
utility would avoid if operated as the Company has described.
e. For each of the types of cost that the utility would avoid for this
configuration, please describe the cost drivers and rate designs that would accurately
compensate the QF.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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f. If an energy storage facility gives operational control and dispatchability to
Idaho Power, how can the facility ensure Idaho Power will operate and dispatch the
facility in a way that can generate a fair and reasonable amount of revenue to the QF?
g. For the configuration and operation as described by the Company, please
discuss the feasibility of a fixed avoided cost rate based on the energy storage facility’s
capabilities (e.g. the QF could be paid a fixed amount each month based on the facility’s
discharge rate, energy storage capacity, or other combinations of capabilities), and why
it may or may not be appropriate.
h. Please explain if it is cost-effective for Idaho Power to manage the
operation and dispatch of storage facilities that are less than 100 kilowatts. If not, what
would the size of the storage facility have to be to make it cost effective?
i. Currently, all QF’s are required to adhere to 90/110 firmness
requirements. Would the 90/110 firmness requirements be feasible in its current form
for the operation and configuration as described by the Company? If not, how would it
need to change?
j. How would the Company ensure that energy input into the battery facility
does not exceed Federal Energy Regulatory Commission’s 25 percent fossil fuel
limitation (See Luz, 51 FERC P 61,172)?
k. For this configuration as described by the Company, please identify and
describe any contract terms and conditions that may be necessary.
RESPONSE TO REQUEST NO. 4:
a. What is meant by Idaho Power’s (“the Company”) statement, “it would be
necessary for the project to be configured and operated in such a manner” is that the
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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Qualifying Facility ("QF") would need to be designed, engineered, sized, configured and
constructed in a manner that would allow for the potential operational benefits of an
energy storage facility to be realized. These potential benefits may include, but are not
limited to, ancillary grid services, surge capacity, load-balancing, voltage support,
firming of variable energy resources, or time-shifting of generation to match load. In
order for these benefits to be utilized, operational control and dispatchability of the
facility would need to be left to the purchasing utility that is required to serve load.
However, the proposed energy storage QF projects that are the subject of Case No.
IPC-E-20-02, appear to be designed and configured for the sole purpose of being
charged and discharged in a manner to deliver as much energy as possible from the
project to Idaho Power in order to maximize payments under the must purchase
obligation of PURPA.
b. The type of energy storage facility that could provide the utility with
numerous benefits described by the Company in subpart a. above is typically a stand-
alone project. As described above, the facility would need to designed, engineered,
configured and built to provide the operational benefits that an energy storage project
could potentially offer. One specific beneficial example of a stand-alone facility is that it
would not require the charging source to be a renewable QF. The energy storage facility
could be charged from any type of generation resource.
c. Idaho Power has not suggested and is not describing that it would have
the ability to hold operational control or dispatchability of an energy storage QF. In fact,
under PURPA, the utility must purchase all of the output made available by the QF;
output that is delivered whenever and in whatever amount the QF is able to provide.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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Idaho Power explained in its Petition in Case No. IPC-E-02, that the potential benefits of
an energy storage facility are lost when the project is forced on the utility as a PURPA
QF, rather than as a utility developed, owned and operated project that has been
acquired through the utility’s planning process.
d. Idaho Power has not described that the utility would operate an energy
storage QF in a manner that would allow for the potential benefits the Company
described in its Petition to be realized.
e. See Idaho Power’s Response to Request No. 4(d.) above.
f. Idaho Power has not described or requested that is would be given
operational control and dispatchability of an energy storage QF. Under PURPA, a QF is
paid based on the amount of kilowatt hours (“kWh”) delivered, regardless of the timing
or quantity. Under a non-PURPA power purchase agreement, the number of cycles
utilized by an energy storage facility, operational control, and dispatchability would
negotiated terms between a willing seller and willing buyer.
g. Idaho Power has not described or requested that is would be given
operational control and dispatchability. Under PURPA, a QF is paid based on the
amount of kilowatt hours (“kWh”) delivered, regardless of the timing or quantity. Under a
non-PURPA power purchase agreement (“PPA”), the number of cycles utilized by an
energy storage facility, operational control, and dispatchability would negotiated terms
between a willing seller and willing buyer. The feasibility of a fixed avoided cost rate
based on the energy storage facility’s capabilities (e.g. the QF could be paid a fixed
amount each month based on the facility’s discharge rate, energy storage capacity, or
other combinations of capabilities), may be a possible pricing structure under a non-
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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PURPA PPA, but that pre-supposes that the acquisition has been determined to be
economical and beneficial to the Company and its customers through the Integrated
Resource Planning (“IRP”) process. Idaho Power does not believe that a fixed price for
the availability of the energy storage facility is a feasible price structure under PURPA,
neither is this price structure something that has been requested in Idaho Power’s
Petition. Idaho Power does not believe that a fixed pricing structure should be
implemented as it would result in making fixed payments for a facility that has not been
identified as an economical or beneficial resource. In addition, this pricing structure
does not work under the must take provisions of PURPA, where the purchasing utility is
required to buy output from a QF whenever and in whatever amount the generation is
delivered.
h. If it is cost-effective and beneficial to the Company’s customers to acquire
or build an energy storage facility, then the project would be identified and pursued
through the IRP process. In the context of PURPA, it simply does not work for the utility
to dispatch or control the QF as described in subparts f. and g. above. It would be
unlikely the QF would be dispatched because it would presumably be a high cost, if not
the highest cost, resource available, that has not been identified as an economical or
beneficial source of generation, and that requires customers to pay a flat amount for a
resource that is not been determined to be cost-effective or needed to serve load on the
Company’s system.
i. Under a utility owned energy storage facility, the Company would have to
meet its requirements and obligation to balance load with generating resources. The
90/110 eligibility requirement for PURPA QFs is required because the Company does
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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not have dispatchable control. The 90/110 contractual requirement provides an
economic incentive for projects to deliver the amount of generation the project estimates
that it can deliver. The contractual requirements to deliver generation within 90/110
percent of a QF’s own estimate is a minimal requirement for QFs that deliver generation
output on an if, as and when available basis.
j. If an energy storage QF is configured as a stand-alone facility, it would
likely be impossible to ensure the amount and source of energy input into the batteries.
Idaho Power’s description of benefits associated with an energy storage project were to
explain that when an energy storage facility is developed as a QF many of the potential
and important benefits associated with energy storage are lost.
k. See Idaho Power’s Response to Request No. 1(i.)

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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REQUEST NO. 5: Currently, generation QFs are paid different avoided energy
cost rates depending on whether the generation is delivered during high or low load
hours because the value of energy is different depending on the time that it is delivered.
Are two levels of rates (high or low load hours) sufficient to differentiate the value of
energy from an energy storage facility to the Company’s system? Please explain.
RESPONSE TO REQUEST NO. 5: The Idaho Public Utilities Commission (“the
Commission”) has determined that PURPA Qualifying Facilities (“QF”) are to be paid for
generation delivered monthly during Heavy Load (“HL”) and Light Load (“LL”) hours
under the Surrogate Avoided Resource (“SAR”) methodology and the incremental cost
Integrated Resources Plan (“ICIRP”) methodology. However, the method and manner
that QFs are paid for generation delivered during HL and LL hours under the ICIRP
methodology is separate and distinct from the models that are used to determine the
avoided cost prices. The ICIRP methodology requires the QF to provide an hourly
generation profile that is used to determine the highest incremental cost resource
operating during the hour the QF will deliver generation. Under the methodology, the
hourly avoided cost is averaged over a given month to determine the applicable HL and
LL avoided cost price. This is why the ICRIP methodology is the preferred approach for
determining an avoided cost for an energy storage QF, it specifically relies on the
generation profile provided by the QF and results in prices that reflect the value the QF
provides during the hours it will deliver energy. Idaho Power would prefer that the ICIRP
methodology be used to establish pricing for all QFs, however, the Company’s Petition
in Case No. IPC-E-20-02 requests this methodology be required for energy storage QFs
over 100 kW.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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DATED at Boise, Idaho, this 17th day of April 2020.

DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 17th day of April 2020 I served a true and
correct copy of IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:

Commission Staff
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

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Christy Davenport, Legal Assistant