20230518Comments of Idaho Power.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

May 18, 2023

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. GNR-E-23-02
Commission Staff’s Application to Update Inputs to the “Surrogate Avoided
Resource” Method Avoided Cost Rates

Dear Ms. Noriyuki:

Attached for electronic filing, please find Comments of Idaho Power Company in the
above-entitled matter. If you have any questions about the attached document, please do
not hesitate to contact me.

Sincerely,

Donovan Walker
DEW:cd
Enclosures
RECEIVED
Thursday, May 18, 2023 3:19:32 PM
IDAHO PUBLIC
UTILITIES COMMISSION
COMMENTS OF IDAHO POWER COMPANY - 1

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

Attorney for Idaho 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
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CASE NO. GNR-E-23-02

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. 35758, hereby respectfully submits
the following Comments.
On April 16, 2020, the Commission issued Order No. 34628 wherein it approved
Staff’s 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 - 2

methodology”.1
On April 12, 2023, Commission Staff (“Staff”) applied to the Commission for an
order updating the natural gas price forecasts used in the SAR avoided cost methodology
with a proposed effective date of June 1, 2023. The Company has reviewed the
information in Staff’s 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 Information
Administration’s (“EIA”) Annual Energy Outlook 2023, released on March 16, 2023, in
accordance with Commission Order Nos. 326972 and 328023. 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 18th day of May, 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

1 In the Matter of the Annual Update to “Surrogate Avoided Resource” Avoided Cost Rates, Case No.
GNR-E-20-01, Order No. 34628 at 1 (Apr. 16, 2020).
2 In the Matter of the Commissions Review of PURPA QF Contract Provisions Including the Surrogate
Avoided Resource (SAR) and Integrated Resource Planning (IRP) Methodologies for Calculating Avoided
Cost Rates, Case No. GNR-E-11-03, Order No. 32697 at 52 (Dec. 18, 2012).
3 Id., Order No. 32802 at 3 (May 6, 2013).
COMMENTS OF IDAHO POWER COMPANY - 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 18th day of May, 2023, I 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
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

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

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Christy Davenport, Legal Assistant