20200507Idaho Power Comments.pdf

Idaho Power Company
Comments - 1

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
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[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE ANNUAL
UPDATE TO “SURROGATE AVOIDED
RESOURCE” AVOIDED COST RATES

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CASE NO. GNR-E-20-01

COMMENTS OF IDAHO POWER
COMPANY

Idaho Power Company (“Idaho Power” or “Company”), in accordance with RP 201,
et seq., and the applicable provisions of the Public Utility Regulatory Policies Act of 1978
(“PURPA”), as well as the Idaho Public Utilities Commission’s (“IPUC” or “Commission”)
Notice of Modified Procedure in this matter, Order No. 34628, hereby respectfully submits
the following Comments.
On April 14, 2020, Commission Staff presented a Decision Memo at the
Commission’s regular Decision Meeting recommending the Commission utilize a more
formal process to update natural gas price forecasts for the Surrogate Avoided Resource
(“SAR”) avoided cost methodology. The Commission utilizes the SAR methodology as
RECEIVED
2020 May 7AM9:40
IDAHO PUBLIC
UTILITIES COMMISSION
Idaho Power Company
Comments - 2

the source of published avoided cost prices available to PURPA qualifying facilities under
the Commission’s jurisdiction and subject to the State of Idaho’s implementation of
PURPA.
The Commission approved Staff’s recommendation to formalize the annual update
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”. See
Order No. 34628.
The Company has reviewed the information and the SAR model provided by Staff
in the case file including Staff’s updates to the methodology in accordance with
Commission Order No. 32697 and 32802, specifically the update to include the Energy
Information Administration’s (“EIA”) natural gas forecast published on January 29, 2020.
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, 2020.

DONOVAN E. WALKER
Attorney for Idaho Power Company

Idaho Power Company
Comments - 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 7th day of May, 2020, I served a true and correct
copy of the within and foregoing COMMENTS upon the following named parties by the
method indicated below, and addressed to the following:

Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

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Michael Andrea
Clint Kalich
Avista Utilities
1411 East Mission
P.O. Box 3727
Spokane, Washington, 99220

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Ted Weston
Daniel MacNeil
PacifiCorp dba Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
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Christy Davenport, Legal Assistant