20230412Application.pdf

APPLICATION 1
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917

Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

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
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CASE NO. GNR-E-23-02

STAFF’S APPLICATION
TO UPDATE SAR
METHOD RATES

Commission Staff, pursuant to Commission Rule of Procedure 52, the applicable
provisions of the Public Utility Regulatory Policies Act of 1978 (“PURPA”), and as directed by
Order No. 34628, respectfully applies to the Idaho Public Utilities Commission
(“Commission”) for an order updating inputs to the surrogate avoided resource method (“SAR
Method”) model, making administrative changes to the SAR Method model, and approving the
SAR Method avoided cost rates attached to this Application to be effective June 1, 2023.
In support of this Application, Commission Staff represents as follows:
I. BACKGROUND
The Commission calculates and publishes SAR Method rates for qualifying facilities
(“QF(s)”) that are under the applicable resource type project eligibility cap. In Order No.
32697, the Commission found that the final release of U.S. Energy Information
Administration (“EIA”) Annual Energy Outlook automatically triggers a recalculation of
published avoided cost rates. In Order No. 32802, the Commission clarified that an update
should occur on June 1 or within 30 days of the final release of the Annual Energy Outlook,
RECEIVED
2023 April 12, 12:29PM
IDAHO PUBLIC
UTILITIES COMMISSION
CASE NO. GNR-E-23-02
APPLICATION 2
whichever is later. Following the issuance of Orders No. 32697 and 32802, Staff has annually
updated the natural gas forecast in the SAR Method model.
II. THE UPDATES
Staff updated the natural gas forecast in the SAR Method model to the “reference
case” natural gas price forecast for the Mountain Region’s Electric Power sector included in
the EIA Annual Energy Outlook 2023 released on March 16, 2023. A copy of the relevant
natural gas price forecast is included on the AEO2023-EnergyPricesMountain tab in the
attached SAR Method model. Staff has also removed the avoided costs of capacity for 2022
and included the avoided costs of capacity for 2028 for Idaho Power’s Energy Storage QFs on
Tab IPCOStorage(Capacity) of the SAR model.
Attached to this Application are the following:
• An updated SAR model incorporating all the updates mentioned above
• Attachment A (IPCO Avoided Cost Rates for New Contracts)
• Attachment B (IPCO Avoided Cost Rates for Renewal Contracts)
• Attachment C (Avista Avoided Cost Rates for New Contracts)
• Attachment D (Avista Avoided Cost Rates for Renewal Contracts)
• Attachment E (PAC Avoided Cost Rates for New Contracts)
• Attachment F (PAC Avoided Cost Rates for Renewal Contracts)
APPLICATION 3

III. NATURAL GAS PRICE FORECAST COMPARISON
Staff compared the 2022 natural gas forecast and the 2023 natural gas forecast
published by EIA. See Figure No. 1, below.
Figure No. 1: Comparison of 2022 Natural Gas Forecast and 2023 Natural Gas Forecast

As shown from Figure No. 1, the 2023 natural gas forecast is lower than the 2022 natural gas
forecast, starting from year 2026, resulting in lower avoided costs of energy starting then.
IV. MODIFIED PROCEDURE
Commission Staff believes that a hearing is not necessary to consider the issues
presented herein and respectfully requests that this Application be processed by Modified
Procedure; i.e., by written submissions rather than by hearing. RP 201, et seq. If, however, the
Commission determines that a technical hearing is required, the Commission Staff stands
ready to prepare and present its testimony in such hearing.
V. COMMUNICATIONS AND SERVICE OF PLEADINGS
Communications and service of pleadings, exhibits, orders, and other documents
relating to this proceeding should be sent to the following:
APPLICATION 4

VI. REQUEST FOR RELIEF
Commission Staff respectfully requests the Commission issue an order: (1) authorizing
this matter to be processed by Modified Procedure; (2) updating the SAR Method model as
described herein and approving the updated SAR Method avoided cost rates shown in the
attachments to this Application with an effective date of June 1, 2023.

Respectfully submitted this 12th day of April 2023.

Dayn Hardie
Deputy Attorney General

Dayn Hardie
Deputy Attorney General
P.O. Box 83720
Boise, Idaho 83702-0074
[e-mail]
Mike Louis
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83702-0074
[e-mail]
APPLICATION 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 12th day of April 2023, I served the
foregoing APPLICATION, in Case No. GNR-E-23-02, via Electronic Mail to the following:

Donovan Walker
Camille Christen
Idaho Power Company
1121 W. Idaho Street 83702
P.O. Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Mark Alder
Joe Dallas
Rocky Mountain Power
1407 West North Temple, Ste. 330
Salt Lake City, UT 84116
[e-mail]
[e-mail]

David Meyer
Shawn Bonfield
Avista Corporation
P.O. Box 3727
1411 East Mission Avenue
Spokane, WA 99220-3727
[e-mail]
[e-mail]
[e-mail]

______________________________
KERI J. HAWKER
Legal Assistant to Dayn Hardie