20210513Idaho Power Comments.pdf

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DONOVAN E. WALKER
Lead Counsel
[e-mail]
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Enclosures
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Donovan E. Walker
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An IDACORP Company
May 13,2021
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden BIvd., Building I
Suite 201-A
Boise, ldaho 83714
Re: Case No. GNR-E-21-01
Commission Staff's Application to Update lnputs to the "Surrogate Avoided
Resource" Method Avoided Cost Rates
Dear Ms. Noriyuki:
Attached for electronic filing are Comments of ldaho Power Company in the above
entitled matter. lf you have any questions about the attached documents, please do not
hesitate to contact me.
Very truly yours,
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION
STAFF'S APPLICATION TO UPDATE
INPUTS TO THE "SURROGATE AVOIDED
RESOURCE' METHOD AVOIDED COST
RATES
CASE NO. GNR-E-21-01
COMMENTS OF IDAHO POWER
COMPANY
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ldaho Power Company ("ldaho Powe/' 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 ldaho Public Utilities Commission's ("!PUC" or "Commission')
Notice of Modified Procedure in this matter, Order No. 35020, hereby respectfully submits
the following Comments.
On April 16,2020, the Commission issued Order No. 34628 wherein it approved
Staffs recommendation to formalize the annual update to the Surrogate Avoided
Resource ('SAR") avoided cost methodology going forward, and clarified that, "...this
update is still intended to be a simple arithmetic calculation to an established
COMMENTS OF IDAHO POWER COMPANY. 1
methodology".
ln accordance with Commission Order No. 34628, on April 16,2021, Commission
Staff applied to the Commission to update natural gas price forecasts in the SAR avoided
cost methodology with a proposed effective date of June 1, 2021. The Commission
utilizes the SAR methodology as the source of published avoided cost prices available to
PURPA qualifying facilities ("QF') under the Commission's jurisdiction and subject to the
State of ldaho's implementation of PURPA. ln addition to the inclusion of the updated
naturalgas price forecast, Staffs application proposed making changes to the SAR model
that contain a log to document Commission ordered changes to the SAR methodology
and to deactivate the wind integration charges in the SAR model applicable to QFs
seeking to enter PURPA energy sales agreements with ldaho Power.
The Company has reviewed the information in the application and the SAR model
provided by Staff in the case file including Staffs updates to the methodology in
accordance with Commission Order No. 32697 and 32802, specifically the update to
include the Energy lnformation Administration's ('ElA') natural gas forecast published on
February 3,2021. ldaho 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.
ldaho Power appreciates Staffs addition to the SAR model of a log that documents
Commission orders that update the SAR methodology. ldaho Power believes the log wil!
make it easier to track and reference past modifications to the methodology and agrees
it should be included in the model.
ldaho Power also agrees with Staff to deactivate wind integration charges in the
COMMENTS OF IDAHO POWER COMPANY.2
SAR model. As Staff explains, integration charges applicable to wind QFs seeking
PURPA energy sales agreements with the Company are identified in ldaho Power's tariff
Schedule 87 and are to be included in enetgy sales agreements separately from the
avoided cost price.
ldaho Power recommends the Commission approve the updated published
avoided cost rates as attached to Staffs application and approve the modifications to the
SAR model as proposed in this case.
Respectfully submitted this 13th day of May, 2021.
Mzda!4
DONOVAN E. WALKER
Attorney for ldaho Power Company
COMMENTS OF IDAHO POWER COMPANY.3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of May, 2021 ,l served a true and correct
copy of the within and foregoing COMMENTS OF IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Dayn Hardie
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FA)(X Email - [e-mail]
Christy Davenport, Lega! Assistant
COMMENTS OF IDAHO POWER COMPANY.4