20201117_ej2.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: EDWARD JEWELL
DEPUTY ATTORNEY GENERAL

DATE: NOVEMBER 13, 2020

SUBJECT: IN THE MATTER OF IDAHO POWER’S PETITION TO DETERMINE
THE PROJECT ELIGIBILITY CAP FOR PUBLISHED AVOIDED COST
RATES AND THE APPROPRIATE CONTRACT LENGTH FOR ENERGY
STORAGE QUALIFYING FACILITIES; CASE NO. IPC-E-20-02.

On January 21, 2020, Idaho Power Company (“Idaho Power” or “Company”) filed a
petition with the Idaho Public Utilities Commission (“Idaho PUC”) requesting the Idaho PUC
determine the appropriate project eligibility cap and contract term for energy storage qualifying
facilities (“QF” or “QFs”) under the Public Utility Regulatory Policies Act of 1978 (“PURPA”).
Petition at 11.
On October 2, 2020, the Commission issued a final order approving the Company’s
request. Order No. 34794. The Commission also ordered the Company to submit a compliance
filing implementing a new method to calculate avoided capacity costs. The Commission stated,
To properly compensate QF projects for capacity during the hours
when capacity costs can be avoided, the avoided cost of capacity
should be paid only on production during the hours identified as the
Company’s peak hours. The Duke Energy Method is one method
that will accomplish this objective. It will provide greater
compensation to QF projects during the hours when generation is
needed to actually avoid capacity costs and will replace the
averaging of capacity payments over all hours. We direct the
Company to make a compliance filing within 30 days implementing
this new method. An energy storage QF will continue to lock-in the
first capacity deficit date when it establishes a legally enforceable
obligation or signs a contract with the utility. . . .
Order No. 34794 at 14.
DECISION MEMORANDUM 2
On October 30, 2020, the Company submitted a compliance filing pursuant to Order
No. 34794.
STAFF RECOMMENDATION
Staff recommends the Commission continue to process the case by modified procedure
and establish a comment deadline of December 29, 2020, and a reply comment deadline of January
12, 2021, to review the compliance filing.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Compliance Filing establishing a
comment deadline of December 29, 2020, and a reply comment deadline of January 12, 2021?

__________________________
Edward J. Jewell
Deputy Attorney General

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