20240118Application.pdf

APPLICATION 1
RECEIVED
Thursday, January 18, 2024
11:34AM
IDAHO PUBLIC
UTILITIES COMMISSION

MICHAEL DUVAL (ISB #11714)
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P.O. BOX 83720
BOISE, ID 83720-0074
[phone]

Street Address for Express Mail:
11331 W. CHINDEN BVLD., 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
APPLICATION TO UPDATE IDAHO POWER
COMPANY’ COST OF CAPITAL INPUTS IN
THE SURROGATE AVOIDED RESOURCE
METHODOLOGY
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CASE NO. IPC-E-24-04

APPLICATION

Pursuant to the Public Utility Regulatory Policies Act of 1978 (“PURPA”) and the
implementing regulations of the Federal Energy Regulatory Commission (“FERC”), the Idaho
Public Utilities Commission (“Commission”) has approved a Surrogate Avoided Resource
(“SAR”) Methodology for calculating published avoided cost rates for qualifying cogeneration
and small power production facilities (“QFs”) under applicable resource-specific eligibility caps.
Idaho Power Company’s (“Company”) latest general rate case (Case No. IPC-E-23-11) has
triggered an update of the cost of capital inputs in the SAR Model.
In support of this Application, Commission Staff represents as follows:
I. BACKGROUND
The Commission calculates published avoided cost rates for QFs under applicable
resource-specific eligibility caps. The SAR Model uses each utility’s approved cost of capital
information from their general rate cases. Currently, the Company’s cost of capital inputs used in
the SAR Model were determined in Case No. IPC-E-08-10.
On December 28, 2023, the Commission issued Order No. 36042 in Case No. IPC-E-23-
11, where a 9.6% return on equity (“ROE”) and a 7.247% overall rate of return (“ROR”) were

APPLICATION 2
approved based on a non-specified cost of debt and a non-specified capital structure, with an
effective date of January 1, 2024.
II. THE UPDATES
Because the cost of debt and the capital structure were not specified in Case No. IPC-E-
23-11, Staff proposes to use the currently authorized capital structure1 in the SAR Model (49.27%
common equity and 50.73% long-term debt) and impute the cost of debt based on the capital
structure. The imputed cost of debt is 4.96%.
Staff first updated the cost of debt of 4.96% and the return on equity of 9.6% on Tab
“IPCoCapCarChg” of the SAR Model, which calculates the Company’s Carrying Charge Rate.
Staff also added a note on Tab “IPCoCapCarChg”, which says the following: “For Cost of Capital
as a result of IPC-E-23-11, the cost of debt is imputed based on the capital structure authorized in
Case No. IPC-E-08-10. The cost of debt will be updated if and when a new capital structure is
authorized in a subsequent case.”
Next, Staff updated Cell D64 (UTILITY WEIGHTED COST OF CAPITAL) and Cell D65
(CAPITAL CARRYING CHARGE) of Tab “AVOID NEW”.
Lastly, Staff updated Tab “IPCOStorage(Capacity)” to ensure that avoided cost of capacity
for energy storage qualifying facilities reflects the updated cost of capital information.
Included with this Application are the following Attachments:
a. An updated SAR Model with all the updates incorporated as mentioned
above;
b. Attachment A (IPCO Avoided Cost Rates for New Contracts); and
c. Attachment B (IPCO Avoided Cost Rates for Renewal Contracts).
III. MODIFIED PROCEDURE
Commission Staff believes that a hearing is not necessary to consider the issues presented
herein and respectfully requests that this Application be processed under Modified Procedure, i.e.,
by written submissions rather than by hearing. Commission Rules of Procedure 201–204. If,
however, the Commission determines that a technical hearing is required, the Commission Staff
stands ready to prepare and present its testimony in such a hearing.

1 The capital structure currently used in the SAR Model was approved in Order No. 30722 in Case No. IPC-E-08-10.

APPLICATION 3
IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
Communications and service of pleadings, exhibits, orders, and other documents relating
to this proceeding should be sent to the following:
Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83702-0074
E-mail: [e-mail]

Mike Louis
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83702-0074
E-Mail: [e-mail]

V. REQUEST FOR RELIEF
Commission Staff respectfully requests the Commission issue an order: (1) authorizing this
matter to be processed by Modified Procedure; and (2) updating the SAR Model as described
herein and approving the updated SAR Methodology avoided cost rates shown in the attachments
to this Application with an effective date of January 1, 2024.

Respectfully submitted this 18th day of January, 2024.

________________________________
Michael Duval
Deputy Attorney General

APPLICATION 4
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 18th day of January 2024, I served the
foregoing APPLICATION, in Case No. IPC-E-24-04, via Electronic Mail to the following:

Donovan E. Walker
Energy Contracts
Idaho Power Company
1121 W. Idaho Street 83702
P.O. Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
[e-mail]

_______________________________
Keri J. Hawker
Legal Assistant to Michael Duval