20220523Idaho Power Company Comments.pdf

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An DACORP ComBny
DONOVAN E. WALKER
Lead Counsel
dwalker@ida hooowe r.com
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Enclosures
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SIOH
May 23,2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331West Chinden Blvd., Building 8
Suite 201-A
Boise, ldaho 83714
Re: Case No. GNR-E-22-01
Commission Staffs 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
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]
[e-mail]
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.22.O1
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 Publlc Utilities Commission's ("lPUC" or "Commission")
Notice of Modified Procedure in this matter, Order No. 35398, hereby respectfully submits
the following Comments to Staffs Application
On April 16, 2020, the Commission issued Order No. 34628 wherein it approved
Staffs recommendation to formalize the annual update to inputs 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'.1
ln accordance with Commission Order No. 34628, on April 21,2022, Commission
Staff applied to the Commission for an order updating the naturalgas price forecast in the
SAR avoided cost methodology with a proposed effective date of June 1 , 2022.2 The
Commission utilizes the SAR methodology as the source of published avoided cost prices
available to PURPA qualiffing facilities ('QF') under the Commission's jurisdiction and
subject to the State of ldaho's implementation of PURPA.
The Company has reviewed the information in the Commission Staffs Application
and the SAR model provided by Staff in the case file, which includes updated inputs to
the SAR model based on the U.S. Energy lnformation Administration's ("ElA") Annual
Energy Outlook 2022, released on March 3,2022, in accordance with Commission Order
Nos. 326973 and 328024.ldaho Power believes the natural gas forecast utilized by Staff
has been correctly updated in the modeland agrees thatthe calculations forthe Company
are consistent with the SAR methodology approved by the Commission. ldaho Power
notes, however, that its capacity deficiency date remains under the Commission's review
in proceeding number IPC-E-21'095, and once a decision is issued in that case, the
Company's SAR avoided cost rates will need to be adiusted accordingly.
ldaho Power recommends the Commission update the SAR modelas proposed in
1 ln the Mafter of the Annual Update to "Sunogate Avoided Resource" Avoided Cost Rafeg Case No.
GNR-E-20-01, Order No. 34628 at 1 (Apr. 16,2020').
2 ln the Matter of Commission Sfaffs Application to Update lnputs to the "Sunogate Avoided Resoltrce"
Method Avoided Cost Rafes, Case No. GNR-E-22-01, Application (Apr. 21,2022).
3 ln the Matter of the Commissions Review ot PURPA QF Contract Provisions lncluding the Sunogate
Avoided Resource (SAR) and lntegrated Resource Planning (IRP) Methodologies for Calculating Avoided
Cosf Rateg Case No. GNR-E-11-03, Order No. 32697 at 52 (Dec. 18,2012).
a Id., Order No. 32802 at 3 (May 6, 2013).
5 ln the Mafter of ldaho Power Company's Application for Approval of the Capacity Deficiency to be
Utilized for Avoided Cost Calculatrbng Case No. IPC-E-21-09, ldaho Power Company's Motion and
Amended Application (Feb. 4, 2022).
COMMENTS OF IDAHO POWER COMPANY - 2
StaffsApplication and approve the updated published avoided cost rates as shswn in the
attachmenb to Staffs Application.
Respectfrrlly submitted this 23d day of May,2O22.
fir,*?.ile14-
DONOVAN E. WALKER
Attomey for ldaho Power Company
COMMENTS OF IDAHO PO\A'ER COMFANY.3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23d day of May,2022, ! 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:
Commission Secretary
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
Mike Louis
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
Dayn Hardie
Deputy Aftorney General
ldaho Public Utilities Commission
P.O. Box 83702
Boise, lD 83720-0074
David Meyer
MichaelAndrea
Avista Corporation
P.O. Box3727
1411 East Mission Avenue
Spokane, WA 99220-3727
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secretarv@puc. ida ho.qov
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mike. louis@puc. idaho.oov
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dayn.hard [e-mail]
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david. [e-mail]
michael.and vistacoro.com
avistadockets@avistacorp. com
COMMENTS OF IDAHO POWER COMPANY - 4
Ted Weston
Emily Wegener
Rochy Mountain Power
1407 West North Temple, Ste.330
Salt Lake City, UT 84116
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[e-mail]
emilv.weqener@pacifi com. com
Christy Davenport, Legal Assistant
COMMENTS OF IDAHO POWER COMPANY. S