20220525Idaho Power Company Comments.pdf

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DONOVAN E. WALKER
Lead Counsel
dwalker@ida hooower.com
May 25, 2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden BIvd., Building 8
Suite 2O1-A
Boise, ldaho 83714
Re Case No. IPC-E-22-16
Staffs Petition to Update Colstrip-Related Adjustable Portion of Avoided
Cost Rates for Existing PURPA Contracts
Dear Ms. Noriyuki:
Attached for electronic filing, please find the Comments of the ldaho Power
Company in the above entitled matter. lf you have any questions about the attached
documents, please do not hesitate to contact me.
Very truly yours,
Zde!/<-
Donovan E. Walker
DEW:cld
Enclosures
DONOVAN E. WALKER (lSB No. 5921)
MEGAN GOICOECHEA-ALLEN (lSB No. 7623)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 837OT
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION
STAFF'S PETITION TO UPDATE
COLSTRI P.RELATE D ADJ USTABLE
PORTION OF AVOIDED COST RATES
FOR EXISTING PURPA CONTRACTS
CASE NO. rPC-E-22-16
COMMENTS OF IDAHO POWER
COMPANY
ldaho Power Company ("ldaho Power" or "Gompany"), 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 ("lPUC" or "Commission")
Notice of Modified Procedure in this mafter, Order No, 35402, hereby respectfully submits
the following Comments to Staffs Petition.
On May 5,2022, Commission Staff filed a Petition requesting thatthe Commission
approve the annual revision to update the Colstrip-related adjustable portion of avoided
cost rates for existing PURPA contracts. Staffs request is made pursuant to Commission
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COMMENTS OF IDAHO POWER COMPANY - 1
Order No. 287081 ,which established the method, known as the Colstrip Method, to be
used for determining the annual adjustable-rate portion of avoided costs for those
Qualiffing Facility CQF') contracts, executed between 1990 to 1995, that use variable
costs associated with Colstrip, a coal-fired generating facility in southeast Montana. ldaho
Power has six contracts that utilize the Colstrip Method, the last of which will expire in
September 2030. 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 Colstrip adjustable rate calculation
employed by Staff, using data from Avista's FERC Form 1 from Calendar Year 2021, is
consistent with the method established in IPUC Order No. 28708.
Respectfully submitted this 25th day of May, 2022.
h,*ZdalQ-
DONOVAN E. WALKER
Aftorney for ldaho Power Company
'l ln the Mafter of the lnvestigation of the Continued Reasonab/eness of Using Variable Costs Assocaafed
with the Operation of Colstrip for Annual Adjustable Rate Calculafions as Previously Authoized in
Commission Oder Nos. 23449, 26080, and 23738, Case No. GNR-E-99-01, Order No. 28708 (Apr. 17,
2001).
COMMENTS OF IDAHO POWER COMPANY.2
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 25th day of May,2022. I 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:
Mike Louis
Supervisor of Engineering Section
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
P.O. Box 83702
Boise, lD 83720-0074
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Emai!
mike. louis@puc. idaho.qov
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX
-L Email
davn. hard ie@puc. idaho.qov
Christy Davenport, Legal Assistant
COMMENTS OF IDAHO POWER COMPANY.3