20140228Comments.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
BAR NO. 6618
Street Address for Express Mail:
472 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
li. !nI r. ril
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR APPROVAL ) CASE NO. IPC-E-13-21
OF ITS CAPACITY DEFICIENCY PERIOD TO )
BE UTILIZED IN THE COMPANY,S SAR ) coIvTMENTS oF THEMETHODOLOGY. ) coNTMISSION STAr,r
)
)
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, and in response to the Notice
of Modified Procedure and Notice of Scheduling issued in Order No. 32969 on January 24,2014,
in Case No. IPC-E-13-21, submits the following comments.
BACKGROUND
In Order No. 32697, the Commission directed that a case be initiated outside of each
utility's Integrated Resource Plan (IRP) filing to establish a capacity deficiency period to be
utilized in the utility's Surrogate Avoided Resource (SAR) methodology for computing avoided
cost rates to be included in PURPA power purchase agreements. On November 4, 2013,Idaho
Power filed an Application requesting that the Commission approve its updated capacity
deficiency periods to be utilized in the SAR avoided cost methodology.
STAFF COMMENTS FEBRUARY 28,2014
STAFF ANALYSIS
Idaho Power filed its 2013 IRP with the Commission on June 28,2013. The Commission
accepted and acknowledged the Company's 2013 IRP on February 24,2014. (See Order No.
32980). In its 2013 IRP, ldaho Power identifies that the first peak-hour deficit occrurs in July
2016. As described in the 2013 IRP, peak-hour load deficits are determined using the 90th
percentile water and 95th percentile peak-hour load conditions.
On October 15,2013, pursuant to the Commission's directives in Order No. 32697 and
Order No. 32802, Idaho Power filed updated components of the incremental cost IRP avoided
cost methodology consisting of an updated load forecast, updated natural gas forecast, and
updated list of new and terminated PURPA contracts and long-tenn power purchase agreements.
Updating the 2013 IRP peak-hour deficits with the updated load and contract information from
Case No. IPC-E- 13- l 8l results in the deficits shown in the figure below, reproduced from Idaho
Power's Application. As shown in the figure, the first deficit occurs in July 2013.
t The Commission accepted the updated information for purposes of setting avoided costs in Order No. 32941.
STAFF COMMENTS 2 FEBRUARY 28,2014
Peak-Hou r Surplus/Deficit Charts
{g{ih gtrt.ntilr wrti..nd 95th Percfnaile Ioidl
Pcrl-llour Monthly O!ficltr wlth Erlitlnl rnd Co.rrmltted nctou.cGt.rd Erlrtlng En8r3yEfftchncy {1O13 lfiP velth O*ober 2013 {,ord rnd
Se8t€filbcr 2013 eEPf tsrG.ortsl
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Impact of Demand Response Programs on Idaho Power's First Deficit Year
On October 2, 2013,ldaho Power filed a settlement agreement regarding the continuation
of its demand response programs. Case No. IPC-E-13-14. The settlement agreement was
approved by the Commission on November 12,2013. See Order No. 32923. Idaho Power's IRP
states that "demand response programs will be used throughout the planning period to meet
resource needs." 2013 IRP, p. 8. Updating the figure above with 440 MW of Idaho Power
demand response programs results in the peak-hour deficits shown in the figure below,
reproduced from the Company's Application. Based on this information, the first capacity
deficit occurs in July of 2021.
STAFF COMMENTS FEBRUARY 28,2014
Peak-Hsur SurpluslElefi cit Charts
{90th Penrntrl* wrtf.rd 9:{h P.rc.nnlc tied)
Fwl-ltour l6onthh llGfidfr dth Erlrilq rnd Comnlrt*d Rerqrctt a|d &irgm Encny Effdrncy (l$lt tnp *lth O{tobrr lS13 lord ard
S*flcmbrr 20lt CtPp Fsre.ilt! rnd Semrrd Bertonrc up to4ilS MWI
GO6N@6oooeoo ffr8rooo 6 E*8Enng;rRsFERF&88
Inclusion of Demand Response in Idaho Power's Load-Resource Balance
Idaho Power's inclusion of demand response in its load resource balance assumes it can
reliably and immediately provide 440 MW continually throughout the entire 2}-year planning
period. Staff believes this contradicts the basis of the Commission- approved settlement
agreement, the likely effect of the program modifications included in the settlement, and is not
justified by the Company's responses to discovery in this case. Staff maintains that the most
reasonable estimate of the capacity provided by Idaho Power's demand response portfolio is 170
MW.
Basis of the Settlement
The demand response settlement established the value of Idaho Power's demand response
portfolio based on the size of the supply-side resource that it would defer. Before the October
and September 2013 updates,Idaho Power's 2013 IRP forecasted an 89 MW deficitin20l6,a
STAFF COMMENTS FEBRUARY 28,2014
I 3 9 MW deficit in 2017 , and assume d a 2018 on-line date for the Boardman to Hemingway
transmission 1ine.2 Without demand response, the Company would likely build a 170 MW
simple cycle combustion turbine (SCCT) to meet those short-term deficits and remain in the
Company's resource portfolio through the life of the plant to meet future capacity deficits.
Based on those deficits, the value of Idaho Power's demand response was determined to be equal
to the value of the deferred capacity of one 170 MW SCCT decremented by the effective load
carrying capacity (ELCC), and including the value of ancillary energy savings over a 2}-year
planning horizon. The terms of the settlement, including the annual monetized value of demand
response and subsequent incentive payments, were established on the basis of preserving al70
MW demand response resource rather than a 440 MW demand response resource.
The Settlement's Effect on Demand Response Participation
Before the 2013 demand response suspension, Idaho Power reported having 437 MW of
peak demand reduction potential,3 The effect of the October 2013 settlement terms on
participation in the reinstated programs is not known. However, Staff believes that the
combination of reduced incentive payments, three mandatory annual dispatches, and reduced
notification times will shrink the "approximately 400 megawatts ("MW") of potential demand
response capacity" that existed prior to the agreement.a
In particular, irrigators-which since 2011 have provided at least 320 MW of Idaho
Power's total demand response potential- repeatedly voiced concern during the workshops that
the magnitude of the incentive reduction and dramatic reduction in dispatch notification times
would likely lead to decreased participation from their members. Before the suspension and
settlement, irrigation participants received a much higher incentive payment and were not
intemrpted at all in some years, so Staff agrees that the settlement terms will likely induce some
program attrition. Staff supported reducing payments to irrigators in the belief that it is more
important to lower costs for all ratepayers than pay higher incentives in an attempt to maintain
demand response in excess of the supply-side resource it defers. In response to discovery, Idaho
Power confirmed that although the settlement requires the Company to offer participation to all
existing participants, Idaho Power also expects reduced participation.
2 Boardman to Hemingway's expected on-line date has been revised to "2020 or beyond" according to Idaho Power
Company's response to Request for Production number five from the J.R. Simplot Company.
' Idaho Power 2012 Demand Response Annual Report, page 145.
a Demand Response Program Settlement Agreement, page 3. IPC-E-13-14.
STAFF COMMENTS FEBRUARY 28,2014
Because the reduced incentives are based on deferring a 170 MW SCCT and several
parties anticipate program attrition, Staff believes that the demand response portfolio is more
likely to align with the 170 MW avoided resource specified in the settlement than the 440 MW
listed in Idaho Power's Application.s
Idaho Power's Response to Discovery
Because the Company's Application did not provide any evidence to support its claim
regarding 440 MW of existing and ongoing demand response, Staff asked several discovery
questions in an effort to determine the basis for the Company's estimate. In multiple responses,
Idaho Power emphasized that the "Company believes that is a reasonable assumption that it can
satisfy the deficit of 30 Megawatts (ooMW") in2014.. .with its existing demand response
programs if necessary."6
Staff agrees that Idaho Power's demand response can satisfy a 30 MW deficit in20l4,
but does not believe that satisfying a deficit of 30 MW in the first year of a 2}-year planning
period is sufficient evidence to justify including 440 MW of demand response in each year of the
. planning period.
However, Staff also believes that 30 MW underestimates the Company's demand
response portfolio. Even with increased attrition from the 2013 program lapse, the current
participation rates indicate that Idaho Power has approximately 30 MW of demand response
remaining in its A/C Cool Credit Program. Because the settlement requires Idaho Power to offer
a commercial demand response program, Staff believes it is reasonable to include approximately
30 MW of commercial demand response.T Lastly, Idaho Power is currently in its annual process
of contracting with previous participants for irrigation demand response. Because this process
has been in place for several years with existing participants, Staff believes it is reasonable to
assume that irrigation participation will not fall more than two-thirds, or below approximately
I l0 MW, in the first year of the modified program.
Staff acknowledges that the exact size of Idaho Power's demand response resource is not
known. However, the settlement agreement requires Idaho Power to "reevaluate the value
5 Demand Response Programs Settlement Agreement, page 3. IPC-E-13-14.
u Idaho Power Company's response to the first production request from Commission Staff to Idaho Power, page2.
' Idaho Power has not developed a company-administered program or issued a request for proposals (RFP) soliciting
bids from third-party aggregators, so Staff anticipates that Idaho Power will renew or extend its contract with
Enernoc to provide approximately 30 MW of commercial demand response.
STAFF COMMENTS FEBRUARY 28,2014
calculation [of demand response] as the IRP changes."s This means that Idaho Power will have a
year of modified program experience before publishing its next IRP in 2015, which will allow
the Company and stakeholders to determine how the reduced incentives, increased intemrptions,
and shortened notification times affect program capacity and reliability. Until more precise
information is available, Staff believes it is appropriate to include 170 MW of demand response
for the purpose of calculating the Company's first capacity deficit year in this case.
Updating the peak-hour deficits listed in Table 2 of the Company's Application with 170
MW of demand response results in the first capacity deficit occurring in July 2016.
Energy Deficit Position
Idaho Power did not present or discuss its current annual energy position in its
Application. As a result, Staff s review relied on the Company's annual energy positions as
presented in its 2013 IRP. In the 2013 IRP, average energy surpluses and deficits are determined
using 70th percentile water and 70th percentile average load conditions, coupled with Idaho
Power's ability to import energy from firm market purchases using reserved network capacity.
On a monthly basis, including the impacts of the Company's demand-side management
programs, Idaho Power does not expect to be deficit throughout the entire 2}-year planning
period. Idaho Power's energy position does not affect computation of avoided cost rates because
the Company's capacity position is most critical in all years throughout the2D-year planning
period.
Results of Avoided Cost Computations
Based on Staff s inclusion of 170 MW of demand response and Idaho Power's updates to
load and purchase contracts, Staff computed the SAR methodology avoided cost rates. The rates
are shown on Attachment A for wind, solar, non-seasonal hydro, seasonal hydro, and other
project types.
8 Demand Response Programs Settlement Agreement, page2.
STAFF COMMENTS 7 FEBRUARY 28,2014
STAFF RECOMMENDATIONS
Staff recommends approval of a2016 first deficit year assumption for capacity as
discussed above. This deficit year assumption is based on the inclusion of 170 MW of sunmer
demand response throughout the 20-year planning period. Staff further recommends approval of
the SAR methodology avoided cost rates as contained in Attachment A to Staff s comments.
Finally, Staff recommends that the rates be effective as of the date of Commission approval.
Respecttully submitted this /.gS day of Febru ary 2014.
Technical Staff: Rick Sterling
Stacey Donohue
i :umisc:comments/ipoe 13.2 I ksrpssd comments
Deputy Attorney General
STAFF COMMENTS FEBRUARY 28,2014
IDAHO POWER COMPANY
AVOIDED COST RATES FOR WIND PROJECTS
March XX, 2014
$/MWh
New Contracts and Replacement Contracts without Full Capacity Payments
Eligibility for these rates is limited to projects 100 kW or smaller.
LEVELIZED NON.LEVELIZED
}ONTRACT
LENGTH
/YFARS)
ON-LINE YEAR
CONTRACT
YEAR
NON.LEVELIZED
RATES2014 201s 2016 2017 2018 20'19
1
2
3
4
5
6
7
8
9
10
11
12
'13
14
15
'16
17
18
19
20
29.08
29.70
31.41
32.84
34.27
35.54
36.66
38.06
39.43
40.71
41.84
42.83
43.73
44.53
45.28
45.99
46.66
47.32
47.96
48.59
30.37
32.72
34.30
35.84
37.17
38.30
39.80
41.24
42.59
43.75
44.78
45.70
46.51
47.27
47.99
48.67
49.34
50.00
50.65
51.31
35.27
36.s2
37.97
39.23
40.30
41,85
43.35
44.73
45,91
46.94
47.86
48.67
49.43
50.15
50.83
51.51
52.18
52.84
53.52
54.22
37.86
39.49
40.77
41.83
43.51
45.10
46.56
47.78
48.83
49.75
50.56
51.32
52.05
52.74
53.43
54.11
54.79
55.49
56.22
56.98
41.25 43.6442.40 44.5643.37 46.7645.22 48.6446.92 50.2748.45 51.5349.69 52.5850.75 53,5051.67 54.28
52.47 55.02
53.22 55.7453.95 56.4454.64 57.1355.33 57.8456.03 58.5556.72 59.3057.44 60.0958.21 60.92
59.00 61.7859.82 62.67
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
29.08
30.37
35.27
37.86
41.25
43.64
45.55
51 .73
55.25
58.20
59.56
60.99
62.37
63.36
65.12
67.09
69.09
71.58
74.45
77.47
41.47
E6.49
91.75
97.20
103.41
'107.1 0
Note: These rates will be further adjusted with the applicable integration charge.
Note: The rates shown in this table have been computed using the U.S. Energy lnformation Administration (ElA)'s Annual Energy
Outlook 2013 released May 2, 2013. See "Annual Energy Outlook 2013, All Tables, Energy Prices by Sector and Source, Mountain,
Reference case" at http://www.eia. gov/oiaf/aeo/tablebrowser/.
IDAHO POWER COMPANY Page I
Attachment A
Case No. IPC-E-13-21
StaffComments
02128114 Page I of 5
IDAHO POWER COMPANY
AVOIDED COST RATES FOR SOLAR PROJECTS
March XX, 2014
$/MWh
New Contracts and Reolacement Gontracts without Full Gaoacitv Pavments
Eligibitity for these rates is limited to projects 100 kW or smaller.
LEVELIZED NON.LEVELIZED
SONTRACl
LENGTH
/YtrAPS\
ON-LINE YEAR
CONTRACT
YEAR
NON.LEVELIZED
RATES2014 2015 2016 2017 20',t8 2019
1
2
3
4
5
6
7
8I
10
11
12
13
14
15
16
17
'18
19
20
29.08
29.70
40.68
46.82
51.15
54.40
56.97
59.21
61.26
63.1 1
64.71
66.1 3
67.41
68.54
69.59
70.58
71 .51
72.40
73.26
74.09
30.37
47.20
53.73
57.84
60.77
63.04
65.04
66.90
68.60
70.o7
71.37
72.54
73.59
74.56
75.48
76.36
77.20
78.03
78.84
79.65
65.41
66.87
68.53
69.99
71.26
72.58
73.95
75.29
76.47
77.53
78.50
79.37
80.21
81.01
8'1.79
82.55
83.32
84.08
84.85
85.65
68.44
70.28
71.77
73.04
74.38
75.81
77.20
78.41
79.49
80.47
81.35
82.19
83.00
83.79
84.58
85.36
86.15
86.95
87.79
88.65
72.28 75.1273.64 76.26
74.83 77.7176.18 79.30
77.67 80.8379.11 82.0980,33 83.19
81 .42 84. 't8
82.41 85.0683.29 85.91
84.13 86.75
84,95 87.5685.76 88.3886.56 89.21
87.36 90.05E8.17 90.9289.01 9'1.8389.88 92.78
90.78 93.769'1.71 94.77
2014
2015
2016
2017
2018
201 9
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
29.08
30.37
65.4't
68.44
72.28
75.12
77.49
80.96
84.92
88.30
90.09
91.97
93.81
95.25
97.48
99,93
102.41
105.38
108.75
112.27
116.78
122.32
128.11
134.09
140.84
145.09
Note: These rates will be further adjusted with the applicable integration charge.
Note; The rates shown in this table have been computed using the U.S. Energy lnformation Administration (ElA)'s Annual Energy
Outlook 2013 released May 2, 2013. See 'Annual Energy Outlook 2013, All Tables, Energy Prices by Sector and Source, Mountain,
Reference case" at http:/ ^,ww.eia.gov/oiaf/aeo/tablebrowser/.IDAHO POWER COMPANY Page 2
Attachment A
Case No. IPC-E-13-21
StaffComments
02/28/14 Page 2 of 5
IDAHO POWER COMPANY
AVOIDED COST RATES FOR NON-SEASONAL HYDRO PROJECTS
March XX, 2014
$/MWh
New Contracts and Replacement Contracts without Full Capacitv Pavments
Eligibility for these rates is limited to projects smaller than 10 aMW.
LEVELIZED NON.LEVELIZED
CONTRAC'I
LENGTH
ryEARS)
ON-LINE YEAR
CONTRACT
YEAR
NON.LEVELIZED
ElATtrq2014 2015 2016 2017 2018 2019
1
2
3
4
5
6
7
8
I
10
11
12
'13
14
'15
'16
18
19
20
29,08
29.70
39.87
45.60
49.67
52.75
55.19
57.34
59.30
6'1.08
62.63
64.01
65.24
66.33
67.35
68.3'l
69,21
70.07
70.91
71 .72
30.37
45.93
52.O3
55.91
58.71
60.88
62.E0
64.59
66.25
67.6E
68.94
70.08
71.09
72.04
72.94
73.79
74.62
75.43
76.22
77.O1
62.77
64.21
65.85
67.29
68.55
69.85
71.21
72.53
73.69
74.74
75.69
76.55
77.37
78. '16
78.92
79.67
80.42
81.17
8'1.93
82.72
65.76
67.59
69.06
70.30
71.63
73.04
74.42
75.61
76.67
77.63
78.50
79.32
80.12
80.90
81.67
82.44
83.21
84.00
84.83
85.68
69.56 72.3770.9'1 73.4872.07 74.9173.41 76.4974.88 78.0076.30 79.24
77,51 80.32
78 58 81,30
79.55 82.1680.41 82.9981.24 83.8182.05 84.6182.83 85.4283.62 86.23
84.41 87.05
85.21 87.91
86.03 88.8186.89 89.7s87.78 90.7188.70 91.71
2014
20'15
2016
2017
2018
20'19
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
20?4
2035
2036
2037
2036
2039
29.08
30.37
62.77
65.76
69.56
72.37
74.69
78.12
82.04
85.38
87.1 3
88.96
90.76
92.16
94.34
96.74
99.1 I
102.10
105.42
108.89
1 13.35
1 18.84
124.58
130.51
137.21
141.40
Note: The rates shown in this table have been computed using the U.S. Energy lnformation Administration (ElA)'s Annual Energy
Outlook 2013 released May 2,2013. See "Annual Energy Outlook 2013, All Tables, Energy Prices by Sector and Source, Mountain,
Reference case" at http://www.eia.gov/oiaf/aeo/tablebrowser/.
IDAHO POWER COMPANY Page 3
Attachment A
Case No. IPC-E-13-21
StaffComments
02/28/14 Page 3 of 5
IDAHO POWER COMPANY
AVOIDED COST RATES FOR SEASONAL HYDRO PROJECTS
March XX,2014
$/MWh
New Contracts and Replacement Contracts without Full Caoacitv Pavments
Eligibillty for these rates is limited to projecE smaller than 10 aMW.
LEVELIZED NON.LEVELIZED
CONTRACT
LENGTH
/YFAFIQ\
ON.LINE YEAR
CONTMCT
YEAR
NON.LEVELIZED
RATES2014 2015 2016 2017 2018 2019
1
2
4
5
6
7
II
10
11
12
13
14
15
16
17
18
19
20
29.08
29.70
45.56
54.1 8
60.03
64.33
67.67
70.50
73.02
7s.27
77.21
78.92
80.45
81.81
83.07
84.24
85.33
86.38
87.38
88.35
30.37
54.82
63,96
69.41
73.20
76.06
78.51
80.72
82.72
84.44
85.97
87.33
88.55
89.68
90.75
91.76
92.73
93.68
94.60
95.52
81.27
82.84
84.61
86.18
87.56
88.98
90.45
91.89
93.16
94.32
95.38
96.34
97.26
98.'l 5
99.01
99.86
100.70
101.54
102.39
1 03.26
84.53 88.60 91.6986.49 90.08 92.9488.09 91.38 94.5089.46 92.85 96.2190.91 94.44 97.8592.45 95.99 99.2193.94 97.32 100.42
95.25 98.5't 101.5296.42 99.59 102.5097.50 100.57 1 03.4598.47 101.51 104.3899.41 102.42 105.29100.31 103.32 106.20101.19 104.20 107.12
102.06 10s.10 '108.04
102.92 105.99 108.99
103.79 106.90 109.99104.67 107.86 111.02105.58 108.84 112.08106.s2 109.84 113.16
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
29.08
30.37
81.27
84.53
88.60
9 t.69
94.30
98.01
102.22
105.85
'107.90
110.04
112.15
't t3.86
'1 t6.36
1 19.08
121.85
125.10
128.76
132.57
137.38
't43.22
149.32
'155.61
162.68
167.24
Note: A "seasonal hydro project" is deflned as a generation facility which produces at least 55% of its annual generation during the
months ofJune, July, and August. Order 32802.
Note: The rates shown in this table have been computed using the U.S. Energy Information Administration (ElA)'s Annual Energy
Outlook 2013 released May 2,2013. See "Annual Energy Outlook 2013, All Tables, Energy Prices by Sector and Source, Mountain,
Reference case" at http:/Aivww.eia. gov/oiaf/aeo/tablebrowser/.
IDAHO POWER COMPANY Page 4
Attachment A
Case No. IPC-E-13-21
staff comments
02128114 Page 4 of 5
IDAHO POWER COMPANY
AVOIDED COST RATES FOR OTHER PROJECTS
March XX,2014
$/MWh
New Contracts and Replacement Contracts without Full Capacitv Pavments
Eligibility for these rates is limited to proiects smaller than 10 aMW.
LEVELIZED NON.LEVELIZED
CONTRACI
LENGTH
/YtrAFIS\
ON.LINE YEAR
CONTRACT
YtrAP
NON-LEVELIZED
AATtrq2014 2015 2016 2017 2018 2019
1
2
3
4
5
6
7
6I
10
11
12
'13
14
15
16
17
18
19
20
29.08
29.70
37.66
42.28
45.66
48.27
50.37
52.24
53.99
5s.59
56.99
58.23
59.35
60.34
61.27
62.14
62.96
63.75
64.53
65.28
30.37
42.49
47.41
50.68
53.09
55.00
56.71
58.35
59.87
61 .18
62.35
63.40
64.34
65.21
66.04
66.83
67.60
68.36
69.1 0
69.85
55.61
56.99
58.59
59.98
61.19
62.44
63,76
65.04
66.'15
67.16
68.07
68.88
69.66
70.41
71 .14
71.86
72.57
73.28
74.01
74.77
58.50
60.27
61.69
62.89
64.17
55.53
66.86
68.00
69.02
69.94
70.76
71.55
72.31
73.04
73.78
74.51
75.24
76.00
76.79
77.61
62.18 64.8863.48 65.9564.59 67.3265.88 68.85
67.30 70.31
68.68 71.50
69.84 72.54
70.86 73.4771.78 74.2872.60 75.0773.39 75.8574.16 76.6174.90 77.3775.6s 78.14
76.40 78.9377.16 79.7477.94 80.6178.77 81.5179.63 82.4480.51 83.40
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
29.08
30.37
55.61
58.50
62.1 8
64.88
67.10
70.42
74.22
77.45
79.08
80.80
82.48
83.75
85.82
88.09
90.40
93.19
96.39
99.72
104.05
109.40
1 15.00
120.79
127.35
'131.39
Note: "Other projects" refers to projects other than wind, solar, non-seasonal hydro, and seasonal hydro projects. These "Other projects"
may include (but are not limited to): cogeneration, biomass, biogas, landfill gas, or geothermal projects.
Note: The rates shown in this table have been computed using the U.S. Energy lnformation Administration (ElA)'s Annual Energy
Outlook 2013 released May 2,2013. See'Annual Energy Outlook 2013, All Tables, Energy Prices by Sector and Source, Mountain,
Reference case" at http:/ /vww.eia. gov/oiaf/aeo/tablebrowser/.
IDAHO POWER COMPANY Page 5
Attachment A
Case No. IPC-E-13-21
StaffComments
02/28/14 Page 5 of 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY oF FEBRUARY 2014,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-13-21, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707
E-MAIL: [e-mail]
dockets@idahopower. com
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
gre g@richardsonandoleary. com
RANDY ALLPHIN
TESS PARK
IDAHO POWER COMPANY
PO BOX 70
BOISE TD 83707
E-Mail: [e-mail]
tpark2@ idahopower. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE