20220211Petition for Reconsideration.pdf

DONOVAN E. WALKER
Lead Counsel
[e-mail]
February 11, 2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-21-35
Idaho Power Company’s Application to Update the Gas Forecast in the
Incremental Cost Integrated Resource Plan Avoided Cost Model
Dear Ms. Noriyuki:
Attached for electronic filing is Idaho Power Company’s Petition for Clarification
and/or Reconsideration in the above entitled matter. If you have any questions about the
attached documents, please do not hesitate to contact me.
Very truly yours,
Donovan E. Walker
DEW:cld
Enclosures
RECEIVED
2022 FEB 11 PM 1:52
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION - 1
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

IN THE MATTER OF 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
PETITION FOR CLARIFICATION
AND/OR RECONSIDERATION

Idaho Power Company (“Idaho Power” or “Company”), petitioner herein, pursuant
to RP 33, 325, and 331, et seq., and Idaho Code § 61-626, hereby respectfully petitions
the Idaho Public Utilities Commission (“Commission” or “IPUC”) for clarification and/or
reconsideration of Final Order No. 35294, dated January 21, 2022, issued in Case No.
IPC-E-21-35 (“the Order”). Idaho Power seeks clarification regarding that portion of the
Order that directs modifications to the natural gas forecast used in the Incremental Cost
Integrated Resource Plan (“ICIRP”) avoided cost model. This Petition is based upon the
following:
I. LEGAL STANDARD
Any person may petition to clarify any order of the Commission. RP 325. A petition
for clarification of a final order does not toll the time for reconsideration or appeal and may
be combined with a petition for reconsideration or stated in the alternative as a petition
IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION - 2
for clarification and/or reconsideration. Id. The Commission may clarify any order on its
own motion. Id.
A party must seek reconsideration prior to initiating an appeal to the Idaho
Supreme Court. Idaho Code § 61-627. An issue not presented to the Commission on
reconsideration will not be considered on appeal. Key Transp. Inc. v. Trans Magic Airlines
Corp., 96 Idaho 110, 524 P.2d 1338 (1974). “The purpose of an application for rehearing
is to afford an opportunity to the parties to bring to the attention of the Commission in an
orderly manner any question theretofore determined in the matter and thereby afford the
Commission an opportunity to rectify any mistake made by it before presenting the same
to this Court.” Washington Water Power Co., v. Kootenai Environmental Alliance, 99
Idaho 875, 879, 591 P.2d 122, 126 (1979)(citing Idaho Underground Water Users Ass’n
v. Idaho Power Co., 89 Idaho 147, 404 P.2d 859 (1965); Consumers Co. v. Public Utilities
Comm’n, 40 Idaho 772, 236 P. 732 (1925)).
The Commission may grant reconsideration by reviewing the existing record, by
submission of briefs, memoranda, written comments, interrogatories, and statements or
by evidentiary hearing. RP 331, 332.

II. BACKGROUND
On October 15, 2021, Idaho Power filed its annual Compliance Filing pursuant to
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. On November 5, 2021, Idaho Power filed a Supplement to the Annual
Compliance Filing, pursuant to Order No. 34913, to add the first update to the Peak Hours
and Premium Peak Hours used to calculate payment for battery storage resources in the
IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION - 3
ICIRP avoided cost model. On November 22, 2021, Idaho Power filed a Second
Supplement to the Annual Compliance Filing to provide the gas price forecast in nominal
pricing rather than in real pricing. Staff filed Comments on December 21, 2021,
recommending the use of an alternative gas price forecast (the “NYMEX” forecast) for the
first three years of the forecast period. On December 28, 2021, the Company filed Reply
Comments supporting the use of the gas price forecast it had proposed (the “Platts”
forecast) and offering a December vintage of that forecast as an alternative to the NYMEX
forecast.
On January 21, 2022, the Commission issued Final Order No. 35294. The Order
directs Idaho Power to “file a three-year natural gas forecast update as a compliance filing
to this case, utilizing the latest NYMEX forwards prices to determine IRP avoided cost rates
for contracts signed after January 1, 2022, until the effective date of the next natural gas price
forecast annual update.” Order No. 35294 at 11. The Order rejected the December version
of the Platts forecast, finding it “inappropriate for use with this annual load and gas forecast”
because it was generated after the intended October 15 annual update. Id. at 10.

III. PETITION FOR CLARIFICATION AND/OR RECONSIDERATION
Idaho Power respectfully asks the Commission to grant clarification and/or
reconsideration in this matter on two specific issues related to the Order’s direction
regarding the natural gas price forecast.
A. Vintage of NYMEX Forwards for First Three Years – The Order
directed Idaho Power to submit a compliance filing using three years of “the latest NYMEX
forward prices.” Idaho Power requests clarification that the Commission intended for
Idaho Power to use NYMEX forwards as of October 15, 2021, for the compliance filing (in
other words, the NYMEX forwards as of October 15 for 2022, 2023, and 2024). Idaho
IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION - 4
Power believes the Commission’s intent was for the forwards to be as of the October 15,
2021, date of this annual update and not a more recent forecast date, despite the use of
the word “latest” in the ordering paragraph. This interpretation is supported by the
Commission’s rejection of the December 2021 vintage Platt’s forecast, which was
rejected due to being generated after October 15. Idaho Power respectfully requests the
Commission clarify that Idaho Power should use the October 15, 2021, NYMEX forwards,
and not the forwards from some later date, for the first three years of the forecast.
To the extent the Commission declines to provide this clarification, Idaho Power
requests reconsideration based on the inconsistency between the direction to use the
“latest” NYMEX forwards and the Commission’s finding that the December Platt’s forecast
is inappropriate due to it being generated after October 15.
B. Term of Natural Gas Price Forecast – The Order directs the Company to
“file a three-year natural gas forecast update as a compliance filing to this case” and to
reevaluate the forecast methodology prior to the next annual update. Order No. 35294
at 11. Idaho Power respectfully requests confirmation that the Commission intended to
direct the Company to file an updated 20-year gas price forecast, with the first three years
(2022-2024) of the forecast compiled using NYMEX forwards. While the Order could be
read to direct Idaho Power to file only the first three years of a forecast, Idaho Power
believes that was not the Commission’s intent. Idaho Power’s October 15 annual updates
have historically included ten or more years of natural gas price forecasts. Further, while
ICIRP avoided cost methodology contracts are limited to a maximum term of two-years,
a project requesting ICIRP-based pricing could request a term starting one or more years
in the future. The ICIRP model would need gas forecast pricing for at least the full term
requested by the project, which may extend beyond 2024. Additional years of pricing are
necessary to ensure that the ICIRP model functions as intended and can calculate pricing
IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION - 5
for the full term requested by a given project.
To illustrate: a project could enter the queue now seeking a Scheduled Operation
Date of December 1, 2024, in which case avoided cost pricing would need to be
calculated for the period of December 1, 2024 through November 30, 2026. Natural gas
forecast pricing would need to be available at least through 2026 in order for the model
to be able to calculate avoided cost pricing. Thus, Idaho Power believes the Commission
intended for it to file an updated natural gas price forecast using NYMEX for the first three
years and Platt’s for the remainder of the 20-year forecast period. Idaho Power requests
confirmation of this point.
To the extent the Commission directs Idaho Power to file only three years of the
natural gas price forecast, Idaho Power requests reconsideration of this direction based
on the modeling and contract term concerns described above.
C. Transition from NYMEX to Platt’s After Year 3 of the Forecast – If the
Commission provides the confirmation requested by Idaho Power in section B above such
that Idaho Power is directed to file more than three years of natural gas forecast pricing,
Idaho Power requests confirmation that the Commission intended that Idaho Power use
the NYMEX forward pricing as of October 15, 2021, for the first three years, and then
transition to the July vintage of the Platts forecast in year four and for the remainder of
the forecast period. Specifically, Idaho Power proposes to transition to Platts in year four
by averaging the NYMEX and Platts’ prices for that year, and then using the Platt’s prices
exclusively for years five through twenty. Idaho Power believes this is a reasonable
approach and is generally consistent with the forecast method used by Avista and Rocky
Mountain Power, as described by Staff in Staff’s Comments. Thus, Idaho Power
respectfully requests the Commission clarify that Idaho Power is directed to update the
natural gas forecast pricing using this approach.
IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION - 6

IV. NATURE AND EXTENT OF EVIDENCE AND ARGUMENT
TO BE OFFERED ON RECONSIDERATION

RP 331 requires that Idaho Power state the nature and extent of evidence or
argument it will present or offer if reconsideration is granted. Idaho Power respectfully
asks that the Commission grant clarification and/or reconsideration in this matter. Should
the Commission grant reconsideration, Idaho Power stands ready to augment the
evidentiary record by additional comments, legal briefing, testimony, exhibits, and
hearing, any or all of which as determined to be appropriate and at the discretion of the
Commission.
V. CONCLUSION
Idaho Power respectfully requests that the Commission issue an order granting
clarification and/or reconsideration of Final Order No. 35294 as set forth herein.
Respectfully submitted this 11th day of February 2022.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION - 7
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 11th day of February 2022 I served a true and
correct copy of the within and foregoing Idaho Power Company’s Petition for Clarification
and/or Reconsideration upon the following named parties by the method indicated below,
and addressed to the following:

Riley Newton
Idaho Public Utiilities Commisson
P.O. Box 83720
11331 West Chinden Blvd, Bldg 8
Suite 201-A
Boise ID 83714
Emailed to:
[e-mail]

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Christy Davenport, Legal Assistant