20231013Application.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

October 13, 2023

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-23-25
Idaho Power Company’s Annual Compliance Filing to Update the Load and
Gas Forecast in the Incremental Cost Integrated Resource Plan Avoided
Cost Model

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Annual Compliance Filing
in the above entitled matter. If you have any questions about the attached documents,
please do not hesitate to contact me.

Attachment No. 1 to the Annual Compliance Filing is confidential. Please handle
the confidential information in accordance with the Protective Agreement to be executed
in this matter.

Very truly yours,
Megan Goicoechea-Allen

MGA:cld
Enclosures
RECEIVED
Friday, October 13, 2023 3:14:27 PM
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

Idaho Power Company’s Annual Compliance Filing to Update the Load and Gas
Forecast in the Incremental Cost Integrated Resource Plan Avoided Cost Model

Case No. IPC-E-23-25

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Attachment No. 1 to Idaho Power Company’s Compliance Filing, dated
October 13, 2023, may contain information that Idaho Power Company and a third party
claims is a confidential trade secrets and business records of a private enterprise required
by law to be submitted to or inspected by a public agency as described in Idaho Code §
74-101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure
and exempt from public inspection, examination, or copying.

DATED this Friday, October 13, 2023.

Megan Goicoechea Allen
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
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]
[e-mail]

Attorneys 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-23-25

IDAHO POWER COMPANY’S
ANNUAL COMPLIANCE FILING

Idaho Power Company (“Idaho Power” or “Company”) 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, natural gas forecast, and long-
term contract changes used in the Incremental Cost Integrated Resource Plan (“ICIRP”)
avoided cost methodology. Additionally, in compliance with Order No. 34913, this filing
updates the Peak Hours and Premium Peak Hours used to calculate capacity payments
for energy storage qualifying facilities (“QF”).

IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 2
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”) QF projects that exceed the published rate eligibility cap,
will be updated every two years upon acknowledgement of the utility’s Integrated
Resource Plan (“IRP”) filing, with the exception of the load forecast and the natural gas
forecast, which should be updated annually. Discussing the timetable for updates to the
ICIRP Methodology the Commission explained:
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 . . . 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 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. Though the Commission originally set June 1 as the annual filing
date, it agreed on reconsideration that updates to gas and load forecasts used in the
ICIRP methodologies should occur on October 15 of each year. Order No. 32802, p. 3.
In considering implementation of PURPA with respect to energy storage QFs, the
Commission determined that the avoided cost of capacity should be paid only on
production during the hours identified as the Company’s Peak Hours and Premium Peak
Hours. Order No. 34794, p. 14. The Commission also agreed that the updates to Peak
and Premium Peak Hours should be included in the annual October 15 update to the
other ICIRP method inputs. Order No. 34913, p. 6.
IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 3
The load forecast, natural gas forecast, contract information, and Peak Hours and
Premium Peak Hours designations for battery storage capacity payments that are set
forth below are presented in compliance with the pertinent Commission Orders and will
be incorporated into Idaho Power’s ICIRP avoided cost methodology. Consistent with the
Commission’s prior directives, this methodology will be used by Idaho Power as the
starting point for the negotiation of its contractual avoided cost rates as of January 1,
2024.
II. LOAD FORECAST
Idaho Power’s most recent load forecast from September 2023 shows a decrease
in customer loads over the 20-year period, as compared with the October 2022 load
forecast used in the Company’s previous annual update approved in December 2022.1
The decrease – which amounts to an approximately 4.86 percent average reduction over
the 20-year term – is based on new assumptions surrounding the Company’s expected
energy service agreements that offer different ramp schedules and total peak
requirements relative to October 2022. In addition, there has been a rebalancing of
commercial, industrial, and irrigation load that slightly brought down expectations of future
load levels, though the growth pattern is similar. These reductions are slightly offset by
an increase in expectations for the residential class.
Table 1 and Graph 1, below, show the annual load forecast in average megawatts
(aMW) for both the previously approved October 2022 load forecast and the most recent
September 2023 load forecast through 2043.

1See In the Matter of Idaho Power Company’s Filing to Update the Load and Gas Forecasts in the
Incremental Cost Integrated Resource Plan Avoided Cost Model, Case No. IPC-E-22-26, Order No.
35644 (Dec. 27, 2022).
IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 4
TABLE 1
Average Annual Load Forecast

IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 5
GRAPH 1

III. NATURAL GAS PRICE FORECAST
Consistent with the methodology used in the Company’s previous annual update
and approved by the Commission in Order No. 35644, the Company intends to use the
most recent S&P Platts long-term natural gas forecast, including Henry Hub and Sumas
Basis Annuals (the “Platts long-term forecast”), which was published in September 2023,
to update the natural gas price forecast in ICIRP avoided cost calculations. This is also a
continuation of the methodology employed by the Company for IRP planning case natural
gas prices forecast in its most recent IRP,2 and as such, the Company continues to

2 In the Matter of Idaho Power Company’s 2023 Integrated Resource Plan, Case No. IPC-E-23-23,
Application (filed Sep. 29, 2023).
0
500
1,000
1,500
2,000
2,500
3,000
3,500
2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043
aMW
Year
Annual Load Forecast
October 2022 (aMW)September 2023 (aMW)
IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 6
believe the Platts long-term forecast is the most appropriate forecast to use in the inputs
to Idaho Power’s ICIRP avoided cost model as more fully explained by the Company in
last year’s load and gas forecast filing, Case No. IPC-E-22-26.
Because the Platts long-term forecast is subscription-based and proprietary, this
information has been included as Confidential Attachment No. 1, which contains a table
and a graph setting forth information from the Platts long-term forecast published
September 2023 compared with the Company’s October 2022 natural gas forecast
update. The most recent Platts long-term forecast reflects an approximate 5 percent
reduction in natural gas prices compared to the Company’s last update. More specifically,
this forecast generally indicates lower prices over the first half of the period and higher
prices over the second half of the period.
IV. CONTRACT TERMINATIONS, EXPIRATIONS, AND ADDITIONS
Idaho Power currently has five non-PURPA, long-term power purchase
agreements with projects that are online: Elkhorn Valley Wind (101 megawatts (“MW”)),
Raft River Geothermal (13 MW), Neal Hot Springs Geothermal (22 MW), Jackpot Solar
(120 MW), and Black Mesa Energy Solar (40 MW). Jackpot Solar and Black Mesa Solar
came online in December 2022 and June 2023, respectively.
Idaho Power currently has 129 contracts with online PURPA QFs with a total
nameplate capacity of 1,134.75 MW.3 Included in this update are three replacement
Energy Sales Agreements (“ESA”) for existing Idaho QF projects totaling 17.52 MW.

3 Though the number of contracts remains the same as last year’s update, there is slight difference in
total nameplate capacity as a result of updates to the maximum capacity amount of two projects as
reflected in Case Nos. IPC-E-22-23 and IPC-E-23-15.
IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 7
Attachment 2, Table 1 provides a list of new and terminated contracts since the
last update on October 14, 2022. New ESAs and terminated or expired contracts, as well
as new complete ESA applications, are all included in the ICIRP model on a continuous
basis. New and Commission-approved non-PURPA power purchase agreements or
resource acquisitions are also included in the model on a continuous basis.
V. PEAK AND PREMIUM PEAK HOURS
Idaho Power has refreshed its analysis of Peak Hours and Premium Peak Hours
for 2024, using the same methodology as directed by the Commission in Order No. 34913
and the same data sources as used in prior analyses of these hours. Specifically, Idaho
Power has identified the forecasted peak hours in 2024 using the updated average hourly
load forecast, and additionally, it has also refreshed its analysis of load from 2023, net of
solar generation, and Western Energy Imbalance Market (“WEIM”) prices from 2023. This
updated information is included in Attachment 2, Tables 2-4.
Based on the updated data, the Peak Hours for 2024 for July are 1:00 pm through
the 9:00 pm hour (to 10:00 pm). This is a reduction of one hour and a shift to start one
hour earlier as compared to last year’s Peak Hours for July. For August, the Peak Hours
are 3:00 pm through the 7:00 pm hour (to 8:00 pm). This is one more hour than last year’s
August Peak Hours. The sum of the July and August Peak Hours is fourteen hours, which
is the same as last year.
The updated Premium Peak Hours for July are 5:00 pm through the 9:00 pm hour
(to 10:00 pm), which is a shift in the start hour to one hour earlier compared with the 2023
Premium Peak Hours. The updated Premium Peak Hours for August are 5:00 pm through
the 7:00 pm hour (to 8:00 pm), which is a reduction of one hour compared to the 2023
IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 8
Premium Peak Hours. The sum of the July and August Premium Peak Hours is eight
hours, which is the same as last year.
Idaho Power also evaluated Loss of Load Probability (“LOLP”) data from the 2023
IRP’s Preferred Portfolio. The Company’s internally developed Reliability & Capacity
Assessment Tool (“RCAT”) calculates the probability of demand exceeding generation
for every hour in the IRP planning horizon (20 years).4 The RCAT short-term analysis
used in the 2023 IRP shows that the hours with the highest LOLP values are concentrated
over the summer in the late afternoon/evening hours. Idaho Power uses the LOLP results
in this context to validate the reasonableness of the Peak Hours and Premium Peak Hours
that are identified by looking at forecasted load, current year load net of solar, and current
year WEIM pricing. The fact that the highest LOLP values occur in the summer late
afternoon/evening hours supports the Peak Hours and Premium Peak Hours that have
been identified here.
As a result, Idaho Power is updating the Peak and Premium Peak Hour definitions
for battery storage capacity payments as follows:
Peak Hours: Hours that occur in July starting at 1:00 PM and
ending at 9:59:59 PM, and hours that occur in August
starting at 3:00 PM and ending at 7:59:59. Peak Hours are
subject to change annually.

Premium Peak Hours: Hours that occur in July, starting at
5:00 PM and ending at 9:59:59 PM, and hours in that occur
in August, starting at 5:00 PM and ending at 7:59:59 PM.
Premium Peak Hours are subject to change annually.

4 An in-depth discussion of the LOLP calculation method, process, and results can be found in the Loss of
Load Expectation section of the 2023 IRP’s Appendix C – Technical Report filed in Case No. IPC-E-23-
23.
IDAHO POWER COMPANY’S ANNUAL COMPLIANCE FILING - 9
Finally, in a number of other proceedings, Idaho Power has applied the LOLP
methodology to identify the capacity-based timing of risk for application to pricing,
performance, program parameters, etc.5 Similarly, Idaho Power intends to request
Commission approval to shift from the methodology described above for determining
Peak and Premium Peak Hours to the capacity based LOLP methodology. Idaho Power
informally discussed this proposal with Staff and understands Staff’s preference to be that
Idaho Power file the request to adopt the LOLP methodology to determine Peak and
Premium Peak Hours as a stand-alone application to the Commission. As a result, Idaho
Power expects to initiate a separate docket on this issue in the future.
VI. CONCLUSION
Idaho Power hereby respectfully submits this updated load forecast, natural gas
forecast, contract information, and Peak and Premium Peak Hours in compliance with the
Commission’s directives in Order Nos. 32697, 32802, and 34913 and requests that the
Commission accept and approve the same.
Respectfully submitted this 13th day of October 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

5 See, e.g., Case Nos. IPC-E-21-32, IPC-E-22-22, IPC-E-23-11, and IPC-E-23-14.

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-25

IDAHO POWER COMPANY

CONFIDENTIAL

ATTACHMENT 1

ATTACHMENT 1
IS CONFIDENTIAL AND WILL BE PROVIDED TO THOSE PARTIES THAT EXECUTE
THE PROTECTIVE AGREEMENT IN THIS MATTER

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-25

IDAHO POWER COMPANY

ATTACHMENT 2