20210616Notice_of_Application_Order_No_35074.pdf

NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35074 1

Office of the Secretary
Service Date
June 16, 2021
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IDAHO POWER COMPANY’S
APPLICATION TO UPDATE THE GAS
FORECAST IN THE INCREMENTAL COST
INTEGRATED RESOURCE PLAN AVOIDED
COST MODEL
)
)
)
)
)
)
)
)
)
CASE NO. IPC-E-21-15

NOTICE OF APPLICATION

NOTICE OF
MODIFIED PROCEDURE

ORDER NO. 35074

On May 13, 2021, Idaho Power Company (the “Company”) applied to update the
natural gas forecast from the 2019 Integrated Resource Plan (“IRP”) that is utilized in the
Incremental Cost Integrated Resource Plan (“ICIRP”) avoided cost methodology. IRP avoided
cost rates are available to qualifying facilities (“QFs”) able to generate above the resource-specific
project eligibility cap for published avoided cost rates under Idaho’s implementation of the Public
Utility Regulatory Policies Act of 1978 (“PURPA”).
The Commission now sets deadlines for interested persons to comment on the
Application, and for the Company to reply.
NOTICE OF APPLICATION
YOU ARE HEREBY NOTIFIED that because of the delay in finalizing and
acknowledging the 2019 IRP, the October 2020 update of the gas and load forecast for the ICIRP
methodology was based upon the 2017 IRP.
YOU ARE FURTHER NOTIFIED that on December 29, 2020, the Commission
approved an update to the load and natural gas forecast used in the ICIRP avoided cost
methodology which used the Company’s 2017 IRP as the basis of the methodology. The source
of the 2017 IRP forecast was the U.S. Energy Information Administration's (“EIA”) Henry Hub
High Oil and Gas Resource and Technology forecast. See Order No. 34881.
YOU ARE FURTHER NOTIFIED that the Company states the acknowledged 2019
IRP uses a natural gas forecast provided by S&P Global Platts (“Platts”). The Company represents
because of the timing associated with the 2019 IRP review and acknowledgment in relation to the
October update, if the Company were to utilize the gas forecast from the acknowledged 2019 IRP,
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35074 2

it would be utilizing a forecast that uses a different source and is not as current as that approved in
the 2020 October update. The Company believes that an out-of-cycle update to the gas forecast
from the acknowledged 2019 IRP should be approved and utilized in the ICIRP avoided cost
methodology. This would apply the same natural gas forecast acknowledged for resource planning
and acquisition in the 2019 IRP (Platts), as well as using the most up-to-date information available
for that gas forecast (2021 Platts forecast vs. 2018 Platts forecast from the acknowledged 2019
IRP).
YOU ARE FURTHER NOTIFIED that consistent with the Commission’s prior orders,
should this update to the natural gas forecast be approved by the Commission, the updated ICIRP
avoided cost methodology will be utilized by the Company as the starting point for the negotiation
of its contractual avoided cost rates.
YOU ARE FURTHER NOTIFIED that the Company requests the use of the natural
gas forecast from the acknowledged 2019 IRP, the Henry Hub, and Sumas Basis Annuals from
Platts’ long-term Forecast, updated to the published March 4, 2021, forecast. The Company states
the use of this forecast indicates an approximate 3% overall decrease in the average annual natural
gas forecast prices over the remaining period in comparison to the 2018 natural gas price forecast
from the acknowledged 2019 IRP.
YOU ARE FURTHER NOTIFIED that the Company represents that although the
updated Platts’ natural gas forecast shows a slight decrease overall, it contains yearly increases in
2021-2023 and 2039-2040.
NOTICE OF MODIFIED PROCEDURE
YOU ARE FURTHER 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 Rule 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 persons desiring to state a position on this
Application may file a written comment with the Commission explaining why the person supports
or opposes the Application. Persons who would like a hearing must specifically request a hearing
in their written comments. Persons must file written comments by July 6, 2021. Comments must
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35074 3

be filed through the Commission website or by email unless computer access is unavailable. To
comment electronically, please access the Commission’s home page at www.puc.idaho.gov. Click
the “Case Comment Form” and complete the form using the case number as it appears on the front
of this document. To file by e-mail, the customer must e-mail the comments to the e-mail
addresses listed below. In addition to submitting the comments to the Commission Secretary, the
customer must also e-mail the Company at the email addresses listed below. If computer access is
unavailable, then comments may be mailed to the Commission and Company at these addresses:
For the Idaho PUC:

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, ID 83714

For Idaho Power Company:

Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise, ID 83707-0070
[e-mail]

YOU ARE FURTHER NOTIFIED that the Company must file any reply comments by
July 13, 2021.
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.
O R D E R
IT IS HEREBY ORDERED that the Company’s Application be processed by Modified
Procedure, Rule 201-204 (IDAPA 31.01.01.201-.204). Persons interested in submitting written
comments must do so by July 6, 2021. The Company must file any reply comments by July 13,
2021.
IT IS FURTHER ORDERED that parties should continue to comply with Order No.
35058, issued June 3, 2021. All pleadings should be filed with the Commission electronically and
NOTICE OF APPLICATION
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 35074 4

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.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 16th day
of June 2021.

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

I:\Legal\ELECTRIC\IPC-E-21-15\orders\IPCE2115_Ntc App_jh.docx