20211015Application.pdf

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY’S ANNUAL
COMPLIANCE FILING TO UPDATE THE
LOAD AND GAS FORECASTS IN THE
INCREMENTAL COST INTEGRATED
RESOURCE PLAN AVOIDED COST
MODEL.
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CASE NO. IPC-E-21-35
IDAHO POWER COMPANY’S
ANNUAL COMPLIANCE FILING
Idaho Power Company (“Idaho Power”) hereby respectfully submits to the Idaho
Public Utilities Commission (“Commission”) this filing in compliance with Order Nos.
32697 and 32802 to update the load forecast and natural gas forecast components of the
Incremental Cost Integrated Resource Plan (“ICIRP”) avoided cost methodology.
I. INTRODUCTION
In its final Order No. 32697, the Commission determined that the inputs to the
ICIRP avoided cost methodology, utilized for all proposed Public Utility Regulatory
Policies Act of 1978 (“PURPA”) Qualifying Facility (“QF”) projects that exceed the
published rate eligibility cap, will be updated every two years upon acknowledgement of
RECEIVED
2021 OCT15 PM 12:18

the utility’s Integrated Resource Plan (“IRP”) filing, with the exception of the load forecast
and the natural gas forecast—which is to be updated annually by October 15 of each
year. The Commission stated:
We find that, in order to maintain the most accurate and up-
to-date reflection of a utility’s true avoided cost, utilities must
update fuel price forecasts and load forecasts annually –
between IRP filings. For the sake of consistency, these
annual updates should occur simultaneously with SAR
updates – on June 1 of each year. In addition, it is appropriate
to consider long-term contract commitments because of the
potential effect that such commitments have on a utility’s load
and resource balance. We find it reasonable to include long-
term contract considerations in an IRP Methodology
calculation at such time as the QF and utility have entered into
a signed contract for the sale and purchase of QF power. We
further find it appropriate to consider PURPA contracts that
have terminated or expired in each utility’s load and resource
balance. We find it reasonable that all other variables and
assumptions utilized within the IRP Methodology remain fixed
between IRP filings (every two years).

Order No. 32697, p. 22. The date for the annual update was later changed from June 1
to October 15 of each year. Order No. 32802.
The load forecast, natural gas forecast, and contract information presented below
in compliance with the Commission’s Orders have been incorporated into Idaho Power’s
ICIRP avoided cost methodology. Consistent with the Commission’s prior Orders, this
methodology will be utilized by Idaho Power as the starting point for the negotiation of its
contractual avoided cost rates as of October 15, 2021.
II. LOAD FORECAST
Idaho Power’s most recent load forecast from October 2021 shows, on average
over the remaining period of the 2019 IRP, a slight increase in its customer loads when
compared to the October 2020 load forecast that was provided to the Commission for the

2020 update in Case No. IPC-E-20-35 and approved by the Commission in Order No.
34881.
Table 1 and Graph 1 below show the average annual load forecast for both the
previously approved October 2020 load forecast and the most recent October 2021 load
forecast through 2040.
TABLE 1
Average Annual Load Forecast
Year October 2020 (aMW) October 2021 (aMW)
2021 1,852 1,895
2022 1,890 1,924
2023 1,923 1,953
2024 1,938 1,975
2025 1,960 1,995
2026 1,987 2,019
2027 2,012 2,040
2028 2,021 2,050
2029 2,041 2,069
2030 2,053 2,084
2031 2,067 2,094
2032 2,077 2,102
2033 2,095 2,118
2034 2,112 2,136
2035 2,132 2,155
2036 2,148 2,169
2037 2,197
2038 2,222
2039 2,244
2040 2,262

GRAPH 1

III. NATURAL GAS PRICE FORECAST
As of October 15, 2021, Idaho Power will update the natural gas price forecast
within the ICIRP avoided cost model to reflect the most recent Henry Hub and Sumas
Basis Annuals from S&P Global Platt’s Long-term Forecast, which was published in July
2021. The Commission approved the use of this forecast in Order No. 35158 (Case No.
IPC-E-21-15). Use of this forecast indicates an approximately twenty percent decrease
in the average annual natural gas forecast prices over the remaining period in comparison
to the version of the forecast published in March 2021 and approved in Order No. 35158
for use in the ICIRP avoided cost model. Because the Platts forecast is subscription-
based and proprietary, this information has been included herewith as Confidential
Attachment No. 1. Confidential Attachment No. 1 contains Table 2 which is a comparison
of the yearly (2021-2040) natural gas forecast from the October 2020 update, the Platts
0
500
1,000
1,500
2,000
2,500
2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 203520362037 203820392040
aMW
Annual Load Forecast
October 2020 (aMW)October 2021 (aMW)

forecast approved in Order No. 35158, and the current 2021 updated gas forecast from
Platts. Confidential Attachment No. 1 also contains Graph 2, a graphical representation
of the same numbers.
IV. CONTRACT TERMINATIONS, EXPIRATIONS, AND ADDITIONS
Idaho Power currently has three non-PURPA, long-term power purchase
agreements with projects that are online: Elkhorn Valley Wind (101 megawatts (“MW”)),
Raft River Geothermal (13 MW), and Neal Hot Springs Geothermal (22 MW). In addition,
the long-term power purchase agreement with Jackpot Holdings, LLC (120 MW) is
scheduled to be online in December 2022.
Idaho Power currently has 129 contracts with PURPA QFs with a total nameplate
capacity of 1,137.8 MW. Included in this update for signed Energy Sales Agreements
(“ESA”) are two new Oregon solar QF ESAs totaling approximately 71.3 MW that are not
yet online, and ten replacement ESAs for existing Idaho QF projects totaling 24.95 MW.
Please see Attachment 2 attached hereto for a list of new and terminated contracts since
the last update on October 15, 2020. New ESAs, terminated or expired contracts, as well
as new complete ESA applications, are all included in the ICIRP model on a continuous
basis.
V. CONCLUSION
Idaho Power hereby respectfully submits this updated load forecast, natural gas
forecast, and contract information in compliance with the Commission’s directives in
Order Nos. 32697 and 32802 and asks the Commission to accept the same for filing.

Respectfully submitted this 15th day October 2021.

DONOVAN E. WALKER
Attorney for Idaho Power Company

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-35

IDAHO POWER COMPANY

CONFIDENTIAL ATTACHMENT 1

TABLE 2

Natural Gas Forecast Pricing

Year
October 2020
(nominal
$/MMBtu)[1]
May 2021
(nominal
$/MMBtu) [2]
October 2021
(nominal
$/MMBtu)[3]
2021 2.80 3.60 3.60
2022 2.76 3.45 3.29
2023 2.65 3.09 2.98
2024 2.73 3.16 3.00
2025 2.98 3.31 3.11
2026 3.29 3.39 3.04
2027 3.48 3.44 3.00
2028 3.56 3.63 3.04
2029 3.59 3.82 3.12
2030 3.61 4.00 3.18
2031 3.68 4.20 3.24
2032 3.78 4.34 3.28
2033 3.90 4.43 3.31
2034 3.99 4.52 3.34
2035 4.07 4.61 3.37
2036 4.18 4.70 3.39
2037 4.79 3.38
2038 4.88 3.39
2039 4.97 3.38
2040 5.04 3.38
[1] EIA Natural Gas Henry Hub Spot Price: High Oil and Gas Resource and
Technology (published January 2020).
[2] Henry Hub Annuals from S&P Global Platt’s Long-term Forecast adjusted for
Sumas basis and transport costs for Idaho City Gate delivery (published March
2021).
[3] Henry Hub Annuals from S&P Global Platt’s Long-term Forecast adjusted for
Sumas basis and transport costs for Idaho City Gate delivery (published July 2021).
CONFIDENTIAL

GRAPH 2

BEFORE THE

$-
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 20312032 2033 2034 2035 2036 2037 2038 2039 2040
Nominal $/MMBtu
Natural Gas Forecast Pricing
October 2020 (nominal $/MMBtu)[1]May 2021 (nominal $/MMBtu) [2]
October 2021 (nominal $/MMBtu)[3]
[1] EIA Natural Gas Henry Hub Spot Price: High Oil and Gas Resource and
Technology (published January 2020).
[2] Henry Hub Annuals from S&P Global Platt’s Long-term Forecast adjusted for
Sumas basis and transport costs for Idaho City Gate delivery (published March
2021).
[3] Henry Hub Annuals from S&P Global Platt’s Long-term Forecast adjusted for
Sumas basis and transport costs for Idaho City Gate delivery (published July 2021).
CONFIDENTIAL

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-21-35

IDAHO POWER COMPANY

ATTACHMENT 2

Resource Type Project Name State New or Replacement Contract Date Project Size (MW)
Hydro Crystal Springs ID 1/21/2021 2.55
Hydro Elk Creek Hydro ID 4/5/2021 2.35
Hydro Lemhi Hydro ID 4/14/2021 0.45
Hydro Little Wood River Ranch 1 ID 5/14/2021 1.014
Biomass Pocatello Waste ID 11/9/2020 0.5
Hydro Reynolds Irrigation ID 3/31/2021 0.35
Hydro Sahko Hydro ID 10/23/2020 0.5
Hydro Geo-Bon #2 2021 ID 7/26/2021 1.055
CoGen Simplot - Pocatello 2022 ID 9/30/2021 15.9
Hydro Trout-Co 2021 ID 8/12/2021 0.28
TOTAL 24.95
Resource Type Project Name State Replacement Contract Date Project Size (MW)
Solar Moore's Hollow Solar OR 7/26/2021 42
Solar Prairie City Solar OR 7/26/2021 29.3
TOTAL 71.30
Resource Type Project Name State Contract Termination Date Project Size (MW)
Biomass
Big Sky West Dairy
Digester (DF-AP #1, LLC)ID
11/30/2020
1.5
Biomass Rock Creek Dairy ID 11/3/2020 4
TOTAL 5.50
Projects Active and Online
Projects Not On-Line
Terminated Energy Sales Agreements