20221213Reply Comments.pdf

i-.ECEIVED
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MEGAN GOICOECHIA.ALLEN
Gorporate Counsel
[e-mail]
December 13,2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, ldaho 83714
Re Case No. IPC-E-22-26
Idaho Power Company's Application to Update the Gas Forecast in the
lncremential Cost lntegrated Resource Plan Avoided Cost Model
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Reply Comments in the
above-entitled matter. !f you have any questions about the attached document, please
do not hesitate to contact me.
3EHH"
Very truly yours,
WT.ur;^r"fillo,,r
Megan Goicoechea-Allen
MGA:cld
Enclosures
MEGAN GOICOECHEA ALLEN (lSB No. 7623
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa I ke r@ i d a h opower. co m
Attomeys for ldaho 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 I NTEGRATED
RESOURCE PLAN AVOIDED COST
MODEL.
CASE NO. |PC-E-22-26
IDAHO POWER COMPANY'S
REPLY COMMENTS
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ldaho Power Company ("ldaho Power" or "Company"), in accordance with the
ldaho Public Utilities Commission's ('Commission" or 'IPUC') Notice of Modified
Procedure, Order No. 35596, hereby respectfully submits the following Reply Comments
in response to the Comments filed by Commission Staff ("Staff') on December 6, 2022.
I. INTRODUCTION
On October 14,2022, ldaho Power filed its Annual Compliance Filing pursuant to
Order Nos. 32697 and 32802 to update the load forecast, natural gas forecast, and long-
term contract changes used in the lncremental Cost lntegrated Resource Plan ("lClRP')
avoided cost methodology. On November 14, 2022,ldaho Power filed an Errata to the
Annual Compliance Filing, to conect a labeling enor reflected in the table and graph
showing the annual load forecast. Staff filed Comments on December 6, 2022, in which
it recommended, in pertinent part, thatthe Commission approve the Company's proposed
IDAHO POWER COMPANY'S REPLY COMMENTS. 1
updates and also set forth a proposal for calculating Non-Premium and Premium Peak
Hour rates moving forward. ldaho Power now respectfully submits these Reply
Comments in support of Staffs recommendations and proposal.
II. STAFF RECOMMENDATIONS
ldaho Power appreciates Staffs detailed and thoughtful review of the Compliance
Filing. The Company agrees with Staffs recommendations for approvalof ldaho Power's
proposed load forecast, natural gas forecast, Peak and Premium Peak Hours used to
calculate and pay capacity payments to energy stor:age qualifying facilities, with an
effective date of January 1, 2023, as well as its re@mmendation for the Company to
continue to include contract updates in future annualfilings.
Additionally, ldaho Power is supportive of Staffs proposed change to the method
used to determine the twenty percent price differential between Non-Premium Peak and
Premium Peak Hour rates. ldaho Power reviewed Staffs calculation methodology and
agrees that it conectly determines the necessary rates.
Idaho Power also notes that the energy storage capacity compensation
methodology used in the ICIRP methodology for capacity contribution was referenced by
the Commission in its Orders from Case No. IPC-E-22-06. Staff and the Company have
discussed capacity compensation methodology on several occasions as directed by the
Commission in relation to IPC-E-22-O6. ldaho Power remains open to the application of
those discussions to the capacity methodologies applied to PURPA avoided cost pricing
and will continue to work with Staff towards any modifications or changes that would make
sense for customers in that context.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
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The Company appreciates and accepts Staffs re@mmendations noted above.
Respectftrlly submitted this 13h day of Deember 2022.
4rryffl*L*00ft,r
MEGAN GOICOECHEA ALLEN
Attomey for ldaho Power Company
lDAllO POWER COMPANY'S REPLY COIvIMENTS - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 13th day of December 2022,1 served a true and
correct copy of the within and foregoing ldaho Powe/s Reply Comments upon the
following named parties by the method indicated below, and addressed to the following:
Michael Duva!
ldaho Public Utilities Commission
P.O. Box 83720
11331West Chinden Blvd, Bldg 8
Suite 2O1-A
Boise lD 83714
Emailed to:
[e-mail]
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 4