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HomeMy WebLinkAbout20170524IPC Response and Objection.pdf3Iffi*. . '] L-* r'r rli l' i l: {-l; i l --'.-'.-. I ri l- l,J ":il i.:r'l ii+ PI.t l+: i j DONOVAN E. WALKER Lead Counse! dwalker@idahopower.com May 24,2017 VIA HAND DELIVERY Diane M. Hanian, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, ldaho 83702 Re Case No. IPC-E-17-07 Update to Published Avoided Cost Rates to Reflect an Updated Natural Gas Price Forecast of the U.S. Energy lnformation Administration (ElA) ldaho Power Company's Response and Objection Dear Ms. Hanian Enclosed for filing in the above matter please find an original and seven (7) copies of the Response and Objection of ldaho Power Company. Very truly yours, E. Walker DEW:csb Enclosures 1221 W. ldaho st. (83702) PO. Box 70 Boise, lD 83707 An IDACORP Company , , l_,,,_l'illl''1ii..'.i..Ii);-:l ".rI. DONOVAN E. WALKER (lSB No. 5921) ldaho Power Company 1221West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker@ id ahopower. com IN THE MATTER OF THE ANNUAL UPDATE TO PUBLISHED AVOIDED COST RATES TO REFLECT AN UPDATED NATURAL GAS PRICE FORECAST OF THE U.S. ENERGY TNFORMATTON ADMrN TSTRATTON (ErA) CASE NO. IPC-E-17-07 RESPONSE AND OBJECTION OF IDAHO POWER COMPANY li,--'l:j,/;n_ _.. LiJ ',;' ii Pi{ rr: I i -, I r-\ r- 1,^, '. I. r+l\. I Attorney for ldaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION ) ) ) ) ) ) ) ldaho Power Company ("ldaho Power" or "Company"), pursuant to ldaho Public Utilities Commission Staffs ("Staff') May 16, 2017, letter with attached gas price forecast and proposed rate tables, hereby respectfully submits the following response and objection to the subset of Energy Information Administration's ("ElA') natural gas forecast selected by Staff, and the resulting published avoided cost rates proposed thereby. I. INTRODUCTION AND BACKGROUND Prior to the ldaho Public Utilities Commission's ("Commission") Order No. 32697 (December 18, 2012), the surrogate avoided resource (.SAR') avoided cost methodology utilized the natural gas forecast published by the Northwest Power and RESPONSE AND OBJECTION OF IDAHO POWER COMPANY - 1 Conservation Council ("NPCC'). However, because updates to NPCC's forecast were relatively infrequent in a volatile natural gas price market, the Commission, with Order No. 32697, moved to annual natural gas forecast updates using the EIA natural gas forecast. The Commission directed, "lT !S FURTHER ORDERED that natural gas prices utilized in the SAR Methodology be updated annually, on June 1 of each year, with the most recent natural gas forecasts provided by EIA's Annual Energy Outlook." Order No. 32697 , p. 52; See a/so, Order No. 32697, pp.7-11, 16. EIA's Annual Energy Outlook contains several subsets of natural gas forecasts. Subsequent to Order No. 32697, Staff has utilized the EIA forecast as an input to the SAR methodology, and specifically applied the Mountain Region natural gas forecast under the table titled, Electric Prices: Energy Prices by Sector and Source. Staff has similarly proposed use of EIA's Electric Prices: Energy Prices by Sector and Source, Mountain Region subset for the natural gas forecast update in this case. However, for ldaho Power's lntegrated Resource Plan ("lRP") process as well as for avoided cost rates based upon the lncremental Cost IRP ('lCIRP") methodology, ldaho Power utilizes EIA's Annual Energy Outlook from a different EIA subset: the Henry Hub: High Oil and Gas Resource and Technology (nom $/MMBtu) forecast, adjusted for pricing at Sumas and ldaho City Gate. Use of the Mountain Region EIA forecast proposed by Staff results in published avoided cost rates that are over $8/megawatt-hour ("MWh") higher than use of the adjusted Henry Hub EIA forecast used by ldaho Power in its IRP and the ICIRP methodology. ldaho Power hereby objects to the use of the proposed Mountain Region EIA natural gas forecast for this annual update to avoided cost rates, which will be locked in for 2O-year term, published rate contracts. Idaho Power proposes the use of the adjusted Henry Hub EIA natural gas forecast. RESPONSE AND OBJECTION OF IDAHO POWER COMPANY - 2 II. COMMENTS Order No. 32697 generically requires the use of the EIA's Annual Energy Outlook natural gas forecast as an input to the SAR methodology, but that order and subsequent errata orders do not specify the data series, or subset, within EIA's Annual Energy Outlook that is to be applied to the SAR methodology. The continued use of the Mountain Region forecast is not a representative forecast for natural gas prices for ldaho Power as it represents pricing in a higher priced supply basin than where ldaho Power holds firm pipeline capacity and performs natural gas transactions, does not represent or track with actual natural gas trading prices from the lntercontinental Exchange ('lCE'), and is higher than prices occurring in the market. lts continued use unreasonably inflates the avoided cost prices calculated under the SAR methodology. ln accordance with Commission orders, the ICIRP methodology used for larger projects subject to negotiated rates and contracts, utilizes the natural gas price forecast that ldaho Power uses in its IRP process. The Company's IRP model and process use the EIA natural gas price forecast from EIA's Annua! Energy Outlook for Henry Hub, adjusted for pricing at Sumas and ldaho City Gate, where ldaho Power holds firm pipeline capacity and actually performs natural gas transactions. Specifically, in the development of the 2017 lRP, ldaho Power is using EIA's Natural Gas Spot Price at Henry Hub: High Oil and Gas Resource and Technology (nom $/MMBtu) forecast. ldaho Power has presented this forecast at the IRP Advisory Council ("IRPAC") meetings, and believes the forecast consists of a more accurate expectation of long- term natural gas prices that are accessible to ldaho Power. The EIA Annual Energy Outlook is published every year with multiple gas price scenarios. ln the past, the Company has used the reference case forecast for its IRP; however, for the 2017 lRP, the Company compared the reference case forecast with RESPONSE AND OBJECTION OF IDAHO POWER COMPANY - 3 actua! future trading prices from lCE. Through that analysis, it was determined that the reference case natural gas prices were higher than what was occurring in the market. The Company looked at the other EIA scenarios and chose the High Oil and Gas Resource and Technology, which tracks much closer to actual future trading prices from lCE. The Company uses the Henry Hub index from the High Oil and Gas Resource and Technology and adjusts the Henry Hub price to geographically deliver the natural gas to its service territory. This adjustment reflects the price that the Company will pay for natural gas delivered to its production plants. As presented at the January 12, 2017, IRPAC meeting, and included below, analysis of this forecast demonstrates it follows recent history and is in close alignment with ICE settled transactions, which are based on actual willing buyer/willing seller transactions. Henry Hub Natural6as Prices (Nominal$/mmbtul :.i. 1'.', -. '., i!,'1. @ r\.-_:. ldaho Power recommends that pursuant to the required annua! avoided cost update to the SAR methodology in accordance with Order No. 32697, the Natural Gas RESPONSE AND OBJECTION OF IDAHO POWER COMPANY - 4 Spot Price at Henry Hub: High Oil and Gas Resource and Technology (nom $/MMBtu) forecast from EIA's Annual Energy Outlook be utilized, adjusted for pricing at Sumas and ldaho City Gate. This forecast is relevant and applicable to prices that are based on real and expected natural gas prices for actual transactions utilized by ldaho Power. Using this forecast will result in the determination of a far more accurate approximation of and appropriate published avoided cost pricing. The following table includes the recommended forecast: Year EA HenryHubForecast Annual Energy Outlmk (Nominal $/mmBtu) 2017 Sumes Basis (Nominal S/mmBtu) 2017 Transport Cost (Nominal $/mmBtu) Updated lhliwred NG Cost (Idaho City Gate Price) (Nominal $/mmBtu) (a)(b)(c)(d) ++ ($0.243) ($0.263) ($0.480) ($,0.000; ($0.650) ($0.533) ($0.3e0) ($0.28s) ($0.3 r 5) ($0.3 r s) ($0.3 r s) ($0.3 r s) ($0.3 l5) ($0.3 r5) ($0.3 r5) ($o.3l s) ($0.3 r s) ($0.3 l5) ($0.3 15) ($0.3r5) ($0.3rs) ($0.3 r5) ($0.315) ($0.3 rs) ($0.3 r5) ($0.3 1s) (S,0.3 15) ($0.3 rs) ($0.3 r5) ($0.3 15) (s0.3 1s) $0.473 $0.473 $0.47r $0.4s7 $0.461 $0.468 $0.471 $0.475 $0.481 $0.488 $0.495 s0.502 $0.s09 $0.518 $0.523 $0.527 $0.530 $0.534 s0.539 $0.545 $0.551 $0.s56 $0.562 $0.568 $0.s74 $0.580 $0.s84 $0.592 $0.598 $0.604 s0.610 $2.85 $2.63 $2.82 $3.10 $3.56 $3.79 $3.70 $3.75 $3.88 y.12 $4.32 $4.56 $4.82 $5. 16 $5.29 $5.24 $5.1 1 $5.12 $s. l9 $5.30 $5.38 $5.45 $5.52 $5.6s $s.7e $5.83 $5.83 $6.03 $6. 14 $6.25 $6.33 2015 20t6 2017 2018 2019 2020 2Al 2022 2023 2024 2As 2026 2c27 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2W 2Mt 2M2 20/.3 2044 2Ms s2.620 $2.419 $2.827 $3.240 $3.750 $3.860 $3.617 $3.556 $3.7r4 $3.%5 $4.138 $4.375 M.630 M.958 $5.080 $s.028 $4.895 M.900 M.%5 $5.065 $s.149 $s.213 $5.271 $5.3% $5.531 $5.565 $s.s6l $5.752 $5.861 $5.957 $6.039 Notes: l. Henry Hub Forecast is from EIA's 2017 Annual Energy Outlook, High Oil and C-as Resource and Technology Case, Table 13, Natural Cas Suppty, Disposition and Prices, published January 5,2017. 2. SunasBasisisMarketQuotedBasisthrough2023perthelCEe>ahangeandthenheldstaticfrom2024-2041. 3. Transportation Costs include Pipeline Fuel Rate at 1.28% nultiplied by the connndity price, Pipeline conrrndity charge of $.0313, and Pipeline reservation charges of$.4l0through 2017,$.3924through October20l8, and $.3903 forNovember20lSthrough 2019per current Tarriff, then escalated at lo/o per y ear 2020 - 2Ml. RESPONSE AND OBJECTION OF IDAHO POWER COMPANY.5 As stated above, this forecast is currently utilized in both ldaho Power's 2017 IRP process, as well as in avoided cost pricing based upon the ICIRP methodology. Additionally, this same forecast (and table above) is utilized in the present annual update to standard avoided cost pricing (Oregon's equivalent of published rate, SAR- based avoided costs) for Public Utility Regulatory Policies Act of 1978 ('PURPA") qualifying facilities ('QF') in the Company's Oregon jurisdiction. Public Utility Commission of Oregon Docket No. UM 1730. ldaho Power has applied the adjusted 2017 Natural Gas Spot Price at Henry Hub forecast to the SAR model and compared the resulting avoided cost prices to the prices determined by Staff and contained in Staff's May 16, 2017, letter. Please see Attachment 1 for the Avoided Cost Pricing Tables utilizing the EIA Henry Hub forecast adjusted for Sumas and ldaho City Gate. When the Natural Gas Spot Price at Henry Hub forecast is applied as the basis in the SAR methodology, the approximate decrease in 20-year, levelized avoided cost prices across all resource types, assuming an on-line year of 2017, is about $8.36/MWh. Customers are harmed by an avoided cost methodology that results in inflated prices based on natural gas forecasts that are not applicable to the utility. ldaho Power has experienced continued development of new QF projects that are eligible for published avoided cost rates which are locked-in for 2}-year terms. Several projects have recently entered into replacement Energy Sales Agreements ("ESAs") for existing projects, and several more have or are expected to request replacement ESAs this year and over the next several years. Since Order No. 32697 was issued on December 18, 2012, ldaho Power has entered into eight new ESAs and seven replacement ESAs containing published avoided cost prices that are based on the EIA Mountain Region forecast. lt is anticipated that in 2018, five projects that are eligible for published RESPONSE AND OBJECTION OF IDAHO POWER COMPANY - 6 avoided cost prices will request to implement replacement ESAs for existing projects. ln 2019, that number grows to 10, and in 2020 it is expected that 16 QF projects will request replacement ESAs. The continued use of the Mountain Region natural gas forecast, that does not represent prices that are utilized by ldaho Power, results in an artificially high price that customers should not be required to pay. The mandatory purchase requirement of PURPA already works to undermine the required integrated resource planning of the Company in several ways. Use of EIA's Mountain Region forecast further detaches avoided costs from the Company's integrated resource planning, which is used to plan for the future acquisition of generation resources. The SAR model is set up to recognize different model inputs and variables for each utility, such as capacity rate calculations, seasonalization factors, and load and resource data; therefore, the application of the proper natural gas forecast should be consistent with other utility specific inputs. ilt. coNcLUStoN ldaho Power proposes that the annual update to published avoided cost rates utilize the 2017 EIA Annual Energy Outlook, Natural Gas Spot Price at Henry Hub: High Oil and Gas Resource and Technology (nom $/MMBtu) forecast, adjusted for Sumas and ldaho City Gate. This would align SAR published rates with the current natural gas forecast utilized by the ICIRP avoided cost methodology, the Company's 2017 lRP, and the Company's annual standard avoided cost rates in Oregon. Unlike the use of EIA's Mountain Region forecast, the use of EIA's Henry Hub forecast, adjusted for Sumas and ldaho City Gate, represents pricing in the supply basin in which ldaho Power holds firm pipeline capacity and actually performs natural gas transactions. Use of EIA's Henry Hub forecast would result in a closer approximation of the Company's avoided cost pricing, which for published rates is locked in for 20-year term contracts, and results in a RESPONSE AND OBJECTION OF IDAHO POWER COMPANY - 7 substantial cost savings to ldaho Power customers in the mandatory PURPA purchase requirements of potentially hundreds of millions of dollars. As such, ldaho Power respectfully requests that the Commission direct the use of EIA's Henry Hub forecast, adjusted for Sumas and ldaho City Gate, in the 2017 annual update to published avoided cost rates for ldaho Power, which results in the published avoided cost rates reflected in Attachment t hereto. Respectfully submitted this 24th day of May 2017 DONOVAN E. WALKER Attorney for ldaho Power Company RESPONSE AND OBJECTION OF IDAHO POWER COMPANY - 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24th day of May 2017 t served a true and correct copy of the within and foregoing RESPONSE AND OBJECTION OF IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Daphne J. Huang Deputy Attorney General ldaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, ldaho 83720-007 4 Avista Gorporation MichaelAndrea Avista Utilities 1411 East Mission P.O. Box 3727 Spokane, Wash i n gto n 99220-37 27 Clint Kalich Avista Utilities 1411 East Mission P.O. Box 3727 Spokane, Wash ington 99220-3727 Rocky Mountain Power Yvonne Hogle Ted Weston PacifiCorp dlbla Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake City, Utah 84116 Daniel MacNeil PacifiCorp dbla Rocky Mountain Power 825 NE Multnomah Street Portland, Oregon 97232 X Hand Delivered _U.S. Mail _Overnight Mail _FAXX Email daphne.huano@puc.idaho.qov _Hand DeliveredX U.S. Mail _Overnight Mai! _FAXX Email michael.andrea@avistacorp.com _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email clint.kalich@avistacorp.com _Hand DeliveredX U.S. Mai! _Overnight Mail _FAXX Email vyonne.hoole@pacificorp.com ted.weston@pacificorp. com _Hand DeliveredX U.S. Mail _Overnight Mail _FAXX Email daniel.macnei!@pacificorp.com C-- rry, Legal nt RESPONSE AND OBJECTION OF IDAHO POWER COMPANY - 9 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION GASE NO. !PC-E-17-07 IDAHO POWER COMPANY { ATTACHMENT 1 IDAHO POWER COMPANY AVOIDED COST RATES FORWND PROJECTS June 01,20'17 $/MWh New Contracts and Replacement Contracts without Full Capacity Payments Eligibility for these rates is limited to projects 100 kW or smaller LEVELIZED NON-LEVEL'ZED CONTRACT LENGTH ryEARS'I ON.LINE YEAR CONTRACT YEAR NON-LEVELIZED RATES201720142019202020212022 1 2 3 4 5 6 7 8I 10 '11 12 13 14 15 16 17 18 19 20 22.13 23.10 24.45 25.50 26.01 26.41 25.80 27.57 28.28 28.96 29.64 30.32 30.94 31.46 31.87 32.22 32.55 32.86 33.1 6 33.43 24.15 25.75 26.81 27.19 27.49 27.82 28.62 29.35 30.07 30.77 31.48 32.12 32.65 33.06 33.42 33.75 34.06 34.35 34.62 34.87 27.49 28.30 28.38 28.50 28.74 29.59 30.36 31.10 31.83 32.58 33.25 33.79 34.20 34_55 34.88 35.1 I 35.48 35.75 36.00 36.24 29.19 28.88 28.90 29.13 30.12 30.99 31.80 32.60 33.41 u.12 34.68 35.1 0 35.46 35.79 36.1 0 36.39 36.66 36.92 37.17 37.41 28.55 28.73 29.10 30.40 31.44 32.37 33.25 34.14 34.91 35.50 35.93 36.30 36.63 36.95 37.24 37.52 37.78 38.03 38.28 38.50 28.94 29.41 31.13 32.31 33.33 ?4.28 35.23 36.03 36.62 37.04 37.39 37.71 38.02 38.31 38.58 38.83 39.08 39.33 39,55 39.76 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 203s 2036 2037 2038 2039 2040 2041 2042 22.13 24.15 27.49 29.19 28.55 28.94 29.93 34.98 36.50 38.33 40.29 42.78 43.79 43.55 42.73 42.91 43.53 44.39 45.14 45.75 46.32 47.38 48.50 48.90 49.04 50.58 Note: These rates will be further adjusted with the applicable integration charge. Note: The rates sho^,n in this table have been computed using the U.S.I nformation Administration Annual Energy Outlook 2017 released 201 7. See Annual Energy Outlook 201 7 IDAHO POWER COMPANY Page 1 IDAHO POVVER COi,IPANY AVOIDED COST RATES FOR SOLAR PROJECTS June 01 , 201 7 $/MWh New Contracts and Replacement Contracts without Full Capaciry Payments Eligibility for these rates is limited to projects 100 kW or smaller. LEVELIZED NON-LEVELIZED LENGTH ON.LINE YEAR CONTRACT YEAR NON.LEVELIZED RATES2017 2018 2019 2020 2021 2022 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 22.13 23.10 24.45 25.50 26.01 26.41 26.80 30.42 33.36 35.86 38.02 39.95 41.64 43.08 44.29 45.36 46.32 47.20 48.00 44.73 24.15 25.75 26.81 27.19 27.49 27.82 32.O2 35.33 38.07 40.40 42.47 44.25 45.75 47.01 48.1 0 49.09 49.98 50.79 51.53 52.21 27.49 28.30 28.38 28.50 28.74 33.73 37.50 40.51 43.03 45.22 47.09 48.65 49.93 51.04 52.03 52.93 53.75 54.49 55.17 55.81 29.19 28.88 28.90 29.13 35.31 39.67 43.03 45.75 48.09 50.04 51.64 52.93 54.05 55.04 55.94 56.75 57.49 58.'16 58.79 59.39 28.55 28.73 29.10 37.16 42.31 46.04 48.95 51.40 53.40 55.01 56.29 57.38 58.34 59.21 60.00 60.72 61.38 61.99 62.57 63.1 'l 28.94 29.41 40.52 46.48 50.44 53.39 55.81 57.76 59.28 60.46 61.46 62.33 63.1 3 63.86 64.52 65.1 3 65.70 66.25 66.75 67.21 2017 2018 201 I 2020 202'l 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 22.13 24.15 27.49 29.19 28.55 28.94 29.93 65.52 67.48 69.76 72.18 75.14 76.63 76.87 76.54 77.22 78.33 79.70 80.97 82.11 83.21 84.81 86.49 87.44 88.14 90.26 Note: These rates will be further adjusted with the applicable integration charge. Note: The rates shown in this table have been computed using the U.S.lnfonnation Administration Annual Energy Outlook 2017. released 2017. See Annual Energy Outlook 2017, IDAHO POWER COMPANY Page 2 IOAHO POVT'ER COMPANY AVOIDED COST RATES FOR NON.SEASONAL HYDRO PROJECTS June 01, 2017 $/MWh New Contracts and Replacement Contracts without Full Capacity Payments Eligibility for these rates is limited to projects smaller than 10 aMW LEVELIZED NON.LEVELIZED CONTRACT LENGTH ffEARS) ON-LINE YEAR CONTRACT YEAR NON.LEVELIZED RATES2017 2018 2019 2020 2021 202. 1 2 3 4 5 6 8I 10 11 12 13 14 15 16 17 18 19 20 22.13 23.10 24.45 2s.50 26.O1 26.41 26.80 30_14 32.87 35.1 I 37.20 39.02 40.60 41.95 43.08 44.09 44.98 45.81 46.56 47.24 24.15 25.75 26.81 27.',tg 27.49 27.42 31.69 34.75 37.29 39.47 41.40 43.08 44.48 45.65 46.68 47.60 4A.43 49.20 49.89 50.53 27.49 28.30 28.38 28.50 28.74 33.33 36.80 39,60 41.94 44.00 45.75 47.20 48.40 49.44 50.37 51.21 5'1.97 52.67 53.31 53.91 29.1 I 28.88 28.90 29.13 34.80 38.83 4',t.94 44.47 46.66 48.49 49.99 51.20 52.25 53.1 7 54.01 54.77 55.47 56.10 56.69 57.25 28.55 28.73 29.10 36.5'l 41.26 44.71 47.43 49.72 51.61 53.1 1 54.31 55.33 56.24 57.05 57.80 58.47 59.09 59.67 60.21 60.72 28.94 29.41 39.60 45.11 48.78 51.53 53.81 55.65 57.08 58.18 59.12 59.94 60.70 61.38 62.00 62.58 63.12 63.64 64.11 64.54 20't7 2018 201 9 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 22.13 24.',l5 27.49 29.19 28.55 28.94 29.93 62.55 64.47 66.7'l 69.09 72.00 73.44 73.U 73.26 73.89 74.95 76.28 77.49 78.58 79.63 81.17 82.80 83.70 u.34 86.40 Note: The rates shor/n in this table have been computed using the U.S.lnformation Administration 's Annual Energy Outlook 2017 released 201 7. See Annual Energy Outlook 201 7 IDAHO POWER COMPANY Page 3 IDAHO POWER COMPANY AVOIDED COST RATES FOR SEASONAL HYDRO PROJECTS June 01,2017 $/MWh New Gontracts and Replacement Contracts without Full Caoacitv Pavments Eligibility for these rates is limited to projects smaller than 10 aMW LEVELlzED NON.LEVELIZED LENGTH ON.LINE YEAR CONTRACT YEAR NON-LEVELIZED RATES2017201420'19 2020 2021 2022 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 '17 18 19 20 22.13 23.10 24.45 25.50 26.01 26.41 26.80 32.08 36.33 39.88 42.91 45.57 47.88 49.85 51.54 53.02 54.35 55.56 56.65 57.65 24.15 25.75 26.81 27.19 27.49 27.82 34.01 38.82 42.74 46.03 48.88 51.33 53.40 55.1 4 56.67 58.03 59.27 60.38 61.40 62.33 27.49 28.30 28.38 28.50 28.74 36.1 5 41.66 46.00 49.56 52.60 55.'t7 57.31 59.10 60.66 62.U 63_28 64.40 65.43 65.36 67.22 29.19 28.88 28.90 29.13 38.33 44.74 49.57 53.42 56.65 59.33 61.53 63.34 64.90 66.27 67.51 68.62 69.63 70.56 71_41 72.21 28.55 28.73 29.10 41.10 48.65 54.01 58.1 1 61.46 64.1 I 66.39 68.1 6 69.68 71.01 72.20 73.28 74.26 75.15 75.97 76.75 77.46 28.94 29.41 45,99 54.75 60.41 64.53 67.82 70.43 72.49 74.12 75.49 76.70 77.78 78.76 79.66 80.47 81.23 81.95 82.62 43.22 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 22.13 24,15 27.49 29.19 28.55 28.94 29.93 83.33 85.55 88.1 0 90.79 94.O2 95.78 96.31 96.26 97.22 98.63 100.30 't01.87 103.32 104.73 106.64 108.64 1 09.92 1 1 0.95 113.40 Note: A "seasonal hydro project" is defined as a generation facility which produces at least 550/0 of its annual generation during the months of June, July, and August. Order 32802. Note: The rates shofln in this table have been computed using the U.S.I nformation Administration Annual Energy Outlook 2017 released 201 7. See Annual Energy Outlook 201 7 IDAHO POWER COMPANY Page 4 IDAHO POWER COMPANY AVOIDED COST RATES FOR OTHER PROJECTS June 01,2017 $/MWh New Contracts and Replacement Contracts without Full Capaciw Payments Eligibility for these rates is limited to projects smaller than 10 aMW LEVELlZED NON.LEVELIZED LENGTH ON-LINE YEAR CONTRACT YEAR NON-LEVELIZED RATES201720142019202020212022 1 2 3 4 5 6 7 8 9 10 11 't2 13 14 15 16 17 18 19 20 22.13 23.10 24.45 25.50 26.0'l 26.41 26.80 29.39 31.53 33.37 35.00 36.48 37.78 38.89 39.81 40.62 41.36 42.03 42.65 43.21 24.15 25.75 26.81 27.19 27.49 27.82 30.79 33.18 35.1 8 36.93 38.51 39.88 41.03 41.98 42.8',1 43.56 44.24 44.86 45.43 45.96 27.49 28.30 28.38 28.50 28.74 32.24 u.92 37.12 38.99 40.67 42.10 43.29 44.26 45.1 0 45.85 46.53 47.16 47.73 48.26 48.75 29.19 28.88 28.90 29.13 33.44 36.54 38.98 41.O'l 42.79 44.30 45.52 46.50 47.35 48.10 48.78 49.41 49.98 50.50 51.00 5't.46 28.55 28.73 29.10 34.72 38.39 41.11 43.29 45.1 I 46.74 47.98 48.95 49.78 50.51 51 .19 51,80 52.36 52.87 53.35 53.81 54.24 24.94 29.41 37.13 41.37 44.27 46.50 48.39 49.92 51.11 52.O2 52.78 53.46 54.08 54.65 55.17 55.65 56.'10 56.54 56.95 57.31 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 22.13 24.15 27.49 29.19 28.55 28.94 29.93 54.51 56.31 58.43 60.68 63.47 64.79 64.86 64.35 64.85 65.78 66.97 68.05 69.00 69.91 71.31 72.79 73.55 74.O4 75.95 Note: "Other projects" refers to projects other than wind, solar, non-seasonal hydro, and seasonal hydro projecls. These "Other projects" may include (but are not limited to): cogeneration, biomass, biogas, landfill gas, or geothermal projects. Note: The rates shown in this table have been computed using the U.S. Energy lnformation Adminietration (ElA)'s Annual Energy Outlook 2017. released 201 7. See Annual Energy Outlook 201 7, IDAHO POWER COMPANY Page 5