20230503Petition.pdf

PETITION 1

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917

Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF COMMISSION STAFF’S
PETITION TO UPDATE COLSTRIP-
RELATED ADJUSTABLE PORTION OF
AVOIDED COST RATES FOR EXISTING
PURPA CONTRACTS
)
)
)
)
)
CASE NO. IPC-E-23-16

PETITION

The Staff of the Idaho Public Utilities Commission (“Staff”), in accordance with Idaho
Code §§ 61-501, -502, and -503, and applicable provisions of the Public Utility Regulatory Policies
Act of 1978 (“PURPA”) and pursuant to Commission Rules of Procedure 37 and 53, IDAPA
31.01.01.37 and .53, petitions the Idaho Public Utilities Commission (“Commission”) for an order
updating the Colstrip-related adjustable portion of the published avoided cost rates for existing
PURPA contracts and directing Idaho Power to make filings for future annual updates under the
Colstrip Method (“Petition”). Staff requests the Commission issue a final order by July 1, 2023 to
allow for new rates to be effective on July 1, 2023.
I. BACKGROUND
Each July 1, the Commission updates Qualifying Facility (“QF”) contracts that use
published avoided cost rates calculated under the Colstrip Method. In Order No. 28708, Case No.
GNR-E-99-01, the Commission established a method for the annual adjustable-rate portion of
avoided costs for those QF contracts using variable costs associated with Colstrip, a coal-fired
generating facility in southeast Montana. For those QF contracts with Colstrip-related fuel costs
RECEIVED
Wednesday, May 3, 2023 2:45:18 PM
IDAHO PUBLIC
UTILITIES COMMISSION
PETITION 2

and variable O&M, future Colstrip variable cost adjustments are to be calculated by using Avista’s
FERC Form 1 Colstrip Unit Coal Costs per megawatt hour (“MWh”) and adding $2.00/MWh (the
average variable O&M cost of Colstrip plus $0.20/MWh for generation taxes plus a five percent
adjustment for line loss). Staff attached relevant pages from Avista’s FERC Form 1 as Attachment
A.
As computed by Staff and shown below, the Colstrip-related adjustable rate will change
from 19.13 mill/kilowatt hour (“kWh”) to 21.67 mill/kWh, effective July 1, 2023.

II. Contracts Under Colstrip Method
Among Idaho’s three electric utilities (Avista, Idaho Power, and PacifiCorp), only Idaho
Power has contracts using the Colstrip Method. The last Idaho Power contract will expire in
September 2030. Idaho Power’s Reply Comments at 2 in Case No. IPC-E-22-16. Because of this,
Staff proposes that Idaho Power, instead of Staff, initiate the annual update starting in 2024, using
Avista’s Colstrip data from its FERC Form 1.
III. Colstrip Method after December 31, 2025
On January 16, 2023, Avista entered into an agreement with NorthWestern Corporation
d/b/a Northwestern Energy (“NorthWestern”) and will transfer its 15 percent ownership in Colstrip
Units 3 and 4 to NorthWestern, effective December 31, 2025. After December 31, 2025, Avista
COLSTRIP ADJUSTABLE RATE CALCULATION Updated
For Period 7/1/22-6/30/23
Colstrip Fuel Cost from Avista FERC Form 1 for CY 2022
line 12 Net Generation (kwh)1,619,811,000
line 20 Fuel $31,856,775
Fuel cost per kwh $0.019667
Fuel Cost per MWh $19.6670
Variable O&M, Gen. Tax, 5% line loss per MWh $2.0000
Total Colstrip Adjustable Rate $21.6670
PETITION 3

will no longer include Colstrip data on its FERC Form 1.1 Staff proposes that Idaho Power use
Colstrip data from NorthWestern’s FERC Form 1 for the annual update after Avista stops
including Colstrip data in its FERC Form 1 (therefore making it impossible for Idaho Power to use
Avista’s FERC Form 1 for Colstrip data).2 If data availability becomes an issue or if the Colstrip
plant closes early, Staff requests that Idaho Power work with Staff to develop a new method for
determining the Colstrip-related adjustable rate.
IV. PROCEDURE
Staff believes that a hearing is unnecessary to consider the issues and requests its Petition
be processed under the Commission’s Rules of Modified Procedure; i.e., by written submissions
rather than by hearing. See Commission Rule of Procedure 201, et seq.
V. COMMUNICATIONS AND SERVICE OF PLEADINGS
Communications and service of pleadings, exhibits, orders, and other documents relating
to this proceeding should be sent to:

Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

Mike Louis
Supervisor of Engineering Section
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

VI. REQUEST FOR RELIEF
Staff respectfully requests that the Commission issue an order approving or directing the
following:
1. The updated Colstrip-related adjustable portion of 21.67 mill/kWh, effective July 1,
2023;

1 Staff obtained this information through email communications with Avista on April 27, 2023.
2 Avista will include the Colstrip data in its FERC Form 1 until December 31, 2025. Idaho Power can still use Avista’s
FERC Form 1 for its 2026 filing. Thereafter, Idaho Power would use Northwestern Energy’s FERC Form 1 under
Staff’s proposal.
PETITION 4

2. Idaho Power’s initiation of the annual update of the adjustable portion going forward,
using Avista’s Colstrip data from its FERC Form 1 as long as the data is available to
support its filing;
3. Once Avista stops including Colstrip data in its FERC Form 1, Idaho Power would then
use Colstrip data from NorthWestern Energy’s FERC Form 1 for the annual update;
and
4. If data availability becomes an issue or if the Colstrip plant closes early, Idaho Power
work with Staff to develop a new method for determining the adjustable portion of the
avoided cost rates.

Respectfully submitted this 3rd day of May 2023.

______________________________
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission

I:\Legal\ELECTRIC\IPC-E-23-16_Colstrip\IPCE2316_Staff Ptn.docx
PETITION 5

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have on this 3rd day of May, 2023, served the foregoing
Petition, in Case No. IPC-E-23-16, by electronically mailing a copy thereof to the following:

DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
[e-mail]
[e-mail]

CAMILLE CHRISTEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707
[e-mail]

_______________________________
Keri J. Hawker
Assistant to Dayn Hardie








 

 

   
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Attachment A to Petition
Case No. IPC-E-23-16
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Attachment A to Petition
Case No. IPC-E-23-16
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