20200611Idaho Power Comments.pdf

DONOVAN E. WALKER (1SB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa lker@ idahopower.com
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Attomey for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF COMMISSION
STAFF'S PETITION TO UPDATE INPUTS
TO THE COLSTRIP METHOD AND TO
DISCONTINUE THE SUMAS METHOD
CASE NO. !PC-E-20-24 tMlr,t- e- 2-o- ot
COMMENTS OF IDAHO POWER
COMPANY
ldaho Power Company ("ldaho Powef or "Company"), in accordance with RP 201,
ef seg., and the applicable provisions of the Public Utility Regulatory Policies Act of 1978
("PURPA'), as well as the Idaho Public Utilities Commission's ("lPUC" or "Commission")
Notice of Modified Procedure in this matter, Order No. 34674, hereby respectfully submits
the following Comments.
On May 14, 2020, Commission Staff filed a Petition requesting a Commission
Order to implement an updated avoided cost based on the Colstrip Method for
determining the adjustable portion of avoided cost rates under PURPA. The Colstrip
Method was established by the Commission in Order No. 28708 and applies to certain
ldaho Power Company
Comments - 1
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contracts with PURPA Qualifying Facilities ("QFs") executed from 1990 to 1995.
The Company has reviewed Commission Staffs revision to the adjustable portion of
the avoided cost rate for existing PURPA contracts that utilize the Colstrip Method. ldaho Power
agrees that the calculations used by the Staff for ldaho Power Company are consistent with IPUC
Order No. 28708. ldaho Power has 6 contracts that utilize the Colstrip Method, the last of
which will expire in September 2030.
ldaho Power confirms it has no effective PURPA contracts that utilize the Sumas
Method and agrees the Commission should discontinue pricing requirements specific to
the Sumas Method.
Respectfully submitted this 11th day of June, 2020.
Mzdatt<-
DONOVAN E. WALKER
Attomey for ldaho Power Company
ldaho Power Company
Comments - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1 th day of June,2O2O,l served a true and conect
copy of the within and foregoing COMMENTS upon the following named parties by the
method indicated below, and addressed to the following:
Commission Secretary
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
_Hand Delivered
_U.S. Mail
_Ovemight Mail
_FAXX Email [e-mail]
Christy Davenport, Legal Assistant
ldaho Power Company
Comments - 3