20200623Notice_of_Modified_Procedure_Order_No_34699.pdf

NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34699 1

Office of the Secretary
Service Date
June 23, 2020
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER’S
PETITION TO DETERMINE THE
PROJECT ELIGIBILITY CAP FOR
PUBLISHED AVOIDED COST RATES AND
THE APPROPRIATE CONTRACT
LENGTH FOR ENERGY STORAGE
QUALIFYING FACILITIES
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CASE NO. IPC-E-20-02

NOTICE OF
MODIFIED PROCEDURE

ORDER NO. 34699

On January 21, 2020, Idaho Power Company (“Idaho Power” or “Company”) filed a
Petition with the Idaho Public Utilities Commission (“Idaho PUC”) requesting the Idaho PUC
determine the appropriate project eligibility cap and contract term for energy storage qualifying
facilities (“QF” or “QFs”) under the Public Utility Regulatory Policies Act of 1978 (“PURPA”).
Petition at 11.
On February 10, 2020, the Idaho PUC issued a Notice of Application and Notice of
Intervention Deadline. Order No. 34552. No parties intervened.
The Commission now sets: 1) a deadline for the parties to file initial comments and
requests for public input, 2) a period for the public to respond to the initial comments and requests
for public input, and 3) a deadline for the parties to file follow-up comments that take into
consideration any public comments that may have been filed. This procedure is designed to solicit
and incorporate information and perspectives from interested persons—including but not limited
to QF developers—despite no parties intervening.
BACKGROUND
The project eligibility cap is the project size threshold below which QFs are entitled to
published avoided cost prices. Federal Energy Regulatory Commission (“FERC”) rules
implementing PURPA require states to set project eligibility caps at a minimum of 100 kilowatts
and allow states to set higher project eligibility caps. 18 C.F.R. § 292.304(c)(1), (2). Minimum
contract duration is not specifically established in PURPA or FERC regulations. See Order No.
33357 at 12.
The Company requests the Idaho PUC determine that energy storage QFs up to a
maximum nameplate capacity of 100 kW are eligible for published avoided cost rates and a 20-
year contract while energy storage QFs over 100 kW are eligible for avoided cost rates determined
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34699 2

using the incremental cost Integrated Resource Plan method (“IRP method”) and a maximum
contract term of two years. Petition at 11.
NOTICE OF MODIFIED PROCEDURE
YOU ARE HEREBY NOTIFIED that the Commission has determined that the public
interest may not require a formal hearing in this matter, and that it will proceed under Modified
Procedure pursuant to Rules 201 through 204 of the Commission’s Rules of Procedure, IDAPA
31.01.01.201 through .204. The Commission notes that Modified Procedure and written comments
have proven to be an effective means for obtaining public input and participation.
YOU ARE FURTHER NOTIFIED that parties to the case must file initial comments
and requests for public input with the Commission by July 16, 2020. The initial comments
should state the parties’ initial position on the Petition and solicit additional information regarding
energy storage technologies, costs, characteristics, and other information the party might require
to inform its analysis. Interested persons will have until August 6, 2020 to respond to the
initial comments and requests for public input. The parties will have until August 27, 2020
to file follow-up comments that take into consideration any public comments that may have been
filed. Persons desiring a hearing must specifically request a hearing in their written comments.
Written comments concerning this Petition should be sent electronically, unless email is not
available, to the Commission and the Applicant at the email addresses reflected below:
For the Idaho Public Utilities
Commission:

Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

Street Address for Express Mail:

11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, Idaho 83714

For Idaho Power:

Donovan E. Walker
Idaho Power Company
1221 West Idaho Street 83702
P.O. Box 70
Boise, ID 83707-0070
Email: [e-mail]
[e-mail]

Comments should contain the case caption and case number shown on the first page of this
document. Persons desiring to submit comments via email may do so by accessing the
Commission’s home page located at www.puc.idaho.gov. Click the “Case Comment Form” under
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34699 3

“Consumers,” and complete the comment form using the case number as it appears on the front of
this document. These comments must also be sent to the Petitioner.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are received
within the time limit set, the Commission will consider this matter on its merits and enter its Order
without a formal hearing. If written comments are received within the time limit set, the
Commission will consider them and, in its discretion, may set the same for formal hearing.
ORDER
IT IS HEREBY ORDERED that Idaho Power’s Petition be processed by Modified
Procedure, Rule 201-204 (IDAPA 31.01.01.201-.204). Parties must submit initial comments and
requests for public input by July 16, 2020. Interested persons may submit responses to the initial
comments and requests for public input by August 6, 2020. The parties must submit follow-up
comments by August 27, 2020. Interested persons may submit comments until August 27, 2020.
IT IS FURTHER ORDERED that parties should continue to comply with Order No.
34602, issued March 17, 2020. All pleadings should be filed with the Commission electronically
and shall be deemed timely filed when received by the Commission Secretary. See Rule 14.02.
Service between parties should also be accomplished electronically. Voluminous discovery-related
documents may be filed and served on CD-ROM or a USB flash drive.
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NOTICE OF MODIFIED PROCEDURE
ORDER NO. 34699 4

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 23rd
day of June, 2020.

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Diane M. Hanian
Commission Secretary

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