20210423Decision Memo.pdf

DECISION MEMORANDUM 1

DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: MATT HUNTER
DEPUTY ATTORNEY GENERAL

DATE: APRIL 21, 2021

SUBJECT: IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION FOR
APPROVAL OF THE CAPACITY DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS; CASE NO. IPC-E-21-09.

On April 9, 2021, Idaho Power Company (“Company”) applied for Commission
approval of its capacity deficiency period determination for use in avoided cost calculations under
the Public Utility Regulatory Policies Act of 1978 (“PURPA”). Application at 1.
BACKGROUND
Under PURPA, the Commission has established a surrogate avoided resource (“SAR”)
methodology and an integrated resource plan (“IRP”) methodology to calculate avoided cost rates
for qualifying facilities (“QFs”). Under both methodologies, a QF receives capacity payments only
after the applicable capacity deficiency period is reached. Order No. 32697. The capacity
deficiency period is determined through the IRP planning process and is submitted to the
Commission in a proceeding separate from the IRP docket. The capacity deficiency period
determined in the IRP process is presumed to be correct as a starting point but will be subject to
the outcome of the capacity deficiency case.
THE APPLICATION
In its Application, the Company anticipates its capacity deficiency period will begin in
August 2028 and explains how this capacity deficiency period was calculated. Application at 3-5.
To calculate its capacity deficiency period for use in PURPA avoided cost calculations, the
Company explains that its “load and resource balance has been determined based on the
[Company’s] system as modeled in the 2019 IRP.” Id. at 3; see Case No. IPC-E-19-19, Order No.
DECISION MEMORANDUM 2

34959 (acknowledging the Company’s 2019 IRP). The Company asks that the Commission
approve the capacity deficiency period. Id. at 6.
STAFF RECOMMENDATION
Staff recommends that the case be processed under Modified Procedure, with
comments due June 23, 2021 and reply comments due June 30, 2021.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application and Modified Procedure,
setting a June 23, 2021 comment deadline and a June 30, 2021 reply comment deadline?

Matt Hunter
Deputy Attorney General

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