20190802Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
DATE: AUGUST 2,2019
SUBJECT: APPLICATION OF IDAHO POWER FOR APPROVAL OF THE
CAPACITY DEFICIENCY TO BE UTILIZED FOR AVOIDED COST
CALCULATIONS; CASE NO. IPC-E-19-20.
On June 28, 2019, Idaho Power Company ("Company") filed an Application
requesting the Commission approve a first capacity deficit date of July 2029 to be used in
avoided cost calculations under the Public Utility Regulatory Policies Act of 1978 ("PURPA").
On July 19,2019, the Company filed a letter in IPC-E-I9-19 stating that it needed
additional time to perform modeling and analysis for its 2019 Integrated Resource Plan ("lRI)'';.
The revised IRP analysis will potentially impact the first capacity deficit date.
THE APPLICATION
Under PURPA, the Commission has established a surrogate avoided resource
("SAR") methodology and an Integrated Resource Plan ("IIU"') methodology to calculate
avoided cost rates for qualifying facilities ("QFs"). Eligibility for SAR or IRP avoided cost rates
is determined by the QF's resource type and project size. Under both methods, a QF receives
capacity payments only after the applicable capacity deficit date is reached. The capacity deficit
date in effect when the QF establishes a legally enforceable obligation with the Company is the
applicable capacity deficit date for that QF. The capacity deficit date is determined through the
Company's IRP.
STAFF RECOMMENDATION
Staff recommends the Commission issue a Notice of Application. Because this
Application will likely be impacted by the Company's revised 2019 IRP analysis, Staff does not
DECISION MEMORANDUM I
recommend setting procedure or timelines at this time. Once the impact of the revised 2019 IRP
analysis on this case is known, Staff will make further recommendations regarding procedure
and timing.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application?
Edward
Deputy General
I:\Legal\ELECTRIC\lPC-E- I 9-20\IPCE I 920_dec memo_ej
2DECISION MEMORANDUM