20210611Idaho Power Comments.pdf

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An IDACORP CompanY
DONOVAN E. WALKER
Lead Counsel
[e-mail]
DEW:cld
Enclosures
June 11,2021
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714
Re Case No. !PC-E-21-14
Staffs Petition to Update Colstrip-Related Adjustable Portion of Avoided
Cost Rates for Existing PRUPA Contracts
Dear Ms. Noriyuki:
Attached for electronic filing please find Comments of ldaho Power Company's in
the above entitled matter. lf you have any questions about the attached document, please
do not hesitate to contact me.
Very truly yours,
2datl<
Donovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF COMMISSION
STAFF'S PETITION TO UPDATE
COLSTRI P.RELATED ADJ USTABLE
PORTION OF AVOIDED COST RATES
FOR EXISTING PURPA CONTRACTS
CASE NO. IPC-E-21-14
COMMENTS OF IDAHO POWER
COMPANY
ldaho Power Company ("ldaho Power" or "Company"), in accordance with RP 201,
ef seg., and the applicable provisions of the Public Utility Regulatory Policies Act of 1978
("PURPA"), as well as the ldaho Public Utilities Commission's ("!PUC" or "Commission")
Notice of Modified Procedure in this matter, Order No. 35050, hereby respectfully submits
the following Comments.
On May 13,2021, Commission Staff filed a Petition requesting a Commission
Order to implement an updated avoided cost based on the Colstrip Method for
determining the adjustable portion of avoided cost rates under PURPA. The Colstrip
Method was established by the Commission in Order No. 28708 and applies to certain
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COMMENTS OF IDAHO POWER COMPANY. 1
contracts with PURPA Qualiffing Facilities ("QFs") executed from 1990 to 1995.
The Company has reviewed Commission Staffs revision to the adjustable portion
of the avoided cost rate for existing PURPA contracts that utilize the Colstrip Method.
ldaho Power agrees that the calculations used by the Staff for ldaho Power Company,
using the FERC Form 1 data from Calendar Year 2020, are consistent with IPUC Order
No. 28708. ldaho Power has 6 contracts that utilize the Colstrip Method, the last of which
will expire in September 2030.
Respectfully submitted this 11th day of June, 2021.
M?dd!4-
DONOVAN E. WALKER
Attorney for Idaho Power Company
COMMENTS OF IDAHO POWER COMPANY.2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1 1th day of June, 2021,1 served a true and correct
copy of the within and foregoing COMMENTS OF IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Commission Secretary
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FA)(X Email [e-mail]
Christy Davenport, Legal Assistant
COMMENTS OF IDAHO POWER COMPANY. 3