20171109reconsideration_order_no_33933.pdf

Office of the Secretary
Service Date
November 9,2017
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF IDAHO POWER COMPANY FOR )CASE NO.IPC-E-17-12
APPROVAL OF THE CAPACITY )DEFICIENCY TO BE UTILIZED FOR )ORDER NO.33933
AVOIDED COST CALCULATIONS )
On July 26,2017,Idaho Power Company applied to the Commission for an order
approving the capacity deficiency period for the Company's avoided cost calculations under the
Public Utility Regulatory Policies Act (PURPA).The Commission issued a Notice of
Application and Notice of Modified Procedure setting comment and reply deadlines.Order No.
33838.Commission Staff timely submitted comments.After the comment deadline,IdaHydro
submitted comments styled as a "Response to Comments of the Commission Staff."Idaho
Power timely submitted reply comments.No other comments were received.
The Commission issued Final Order No.33898 approving the Company's Application
and capacity deficiency date of July 2026 for the Company's avoided cost calculations.Idaho
Power Company timely petitioned for clarification or reconsideration of a portion of Order No.
33898.The Commission received no cross-petitions or answers.The Commission now enters
this Order clarifying Final Order No.33898.
PETITIONS FOR RECONSIDERATION
Reconsideration provides an opportunity for a party to bring to the Commission's
attention any issue previouslydetermined,and thereby affords the Commission an opportunity to
correct any mistake or omission.Washington Water Power Co.v.Kootenai Environmental
Alliance,99 Idaho 875,591 P.2d 122 (1979).Under Commission Rule 331.01,"Petitions for
reconsiderationmust set forth specifically the ground or grounds why the petitioner contends that
the order or any issue decided in the order is unreasonable,unlawful,erroneous or not in
conformitywith the law...."IDAPA 31.01.01.331.01.
IDAHO POWER'S PETITION FOR CLARIFICATION OR RECONSIDERATION
In Order No.33898,the Commission addressed Staff's comment that,under the
Integrated Resource Plan (IRP)method for calculating avoided cost rates,the capacity deficiency
date may differ from the date authorized by the Commission,depending on the capacity
contributions of qualifying facilities (QF)in the queue.Order No.33898 at 8-9.The
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Commission found that Staff's interpretation was "a divergence from our prior Orders and from
the Company's request in this Application"and that such a divergence would not be just or
reasonable "without a more thorough analysis of reasoning and potential impacts."Id
Idaho Power requested clarification or reconsideration of this finding.Specifically,Idaho
Power asked the Commission to clarify or reconsider and find that
the utilities are to continue to follow the directive from Order No.33357 that
indicative pricing is to be done on an incremental basis with the inclusion of each
proposed project according to its order in the queue.This has the effect of
potentiallymoving the first capacity deficit established at the time of the IRP and
set by this case as July 2026,which is an intended result that acts to protect
customers from an over-estimatedavoided cost rate.
Id at 5.Idaho Power asserted that its requested clarification is supported by the Commission's
decision in Order No.33357 to adopt incremental pricing for QFs according to their respective
positions in a PURPA queue.Id.at 4-5.
COMMISSION FINDINGS
Our prior order erroneously overlooked our findings and reasoning in Order No.33357.
The Commission's adoption of a queueing process for QF projects in Order No.33357 was
intended to allow incremental pricing under the IRP method to reflect the actual impacts of each
project.Order No.33357 at 28.With its adoption of the queueing process,the Commission
eliminated the requirement from Order No.32697 that utilities include only signed contracts in
their IRP method avoided cost calculations.Id.We continue to find the queueing process a
reasonable approach in keeping avoided cost rates accurate.We now clarify that under the IRP
method of calculating avoided cost rates,consistent with Order No.33357,utilities may continue
to use a queue to track the order in which QF projects have entered negotiations with the utility
and to consider the queue in the calculation of incremental pricing.As a result,the capacity
deficiency date for a particular project under the IRP method may be later than the July 2026
date identified in the Company's IRP if that project enters the queue after other QFs.On the
other hand,it may be earlier if earlier-queuedQFs terminate their projects or otherwise drop out
of the queue.For published rates under the Surrogate Avoided Resource (SAR)method,the
capacity deficiency date is fixed as the date approved in Order No.33898-July 2026.
ORDER NO.33933 2
ORDER
IT IS HEREBY ORDERED that Idaho Power's petition for clarification or
reconsideration is granted.Under the IRP method of calculating avoided cost rates,utilities may
continue to use a queue to track the order in which QF projects have entered negotiations with
the utility so that incremental pricing can be calculated to reflect the actual impacts of each
project.
THIS IS A FINAL ORDER ON RECONSIDERATION.Any party aggrieved by this
Order or other final or interlocutoryorders previously issued in this Case No.IPC-E-17-12 may
appeal to the Supreme Court of Idaho pursuant to the Public Utilities Law and the Idaho
Appellate Rules.See Idaho Code §61-627.
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this
day of November 2017.
PAÙÉ KJELLAÑD R,PRESIDENT
KRISTINE RAPER,COMMISSIONER
ERIC ANDERSON,COMMISSIONER
ATTEST:
Diane M.Hanian
Commission Secretary
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ORDER NO.33933 3