20240228Idaho Power Companys Comments.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

February 28, 2024

Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-24-04
Commission Staff’s Application to Update Idaho Power Company’s Cost of
Capital Inputs in the Surrogate Avoided Resource Methodology

Dear Commission Secretary:

Attached for electronic filing, please find Comments of Idaho Power Company in
the above-entitled matter. If you have any questions about the attached document, please
do not hesitate to contact me.

Sincerely,

Donovan Walker
DEW:cd
Enclosures
An IDACORP company
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
RECEIVED
Wednesday, February 28, 2024 2:53PM
IDAHO PUBLIC
UTILITIES COMMISSION
COMMENTS OF IDAHO POWER COMPANY - 1

DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
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Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF COMMISSION
STAFF’S APPLICATION TO UPDATE
IDAHO POWER COMPANY’S COST OF
CAPITAL INPUTS IN THE SURROGATE
AVOIDED RESOURCE METHODOLOGY
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CASE NO. IPC-E-24-04

COMMENTS OF IDAHO POWER
COMPANY

Idaho Power Company (“Idaho Power” or “Company”), in accordance with RP 201,
et seq., and the applicable provisions of the Public Utility Regulatory Policies Act of 1978
(“PURPA”), as well as the Idaho Public Utilities Commission’s (“IPUC” or “Commission”)
Notice of Modified Procedure in this matter, Order No. 36080, hereby respectfully submits
the following Comments.
On January 18, 2024, Commission Staff filed an Application requesting a
Commission Order updating the inputs to the surrogate avoided resource method (“SAR
Method”) model used to calculate Idaho Power’s published avoided cost rates for
qualifying cogeneration and small power production facilities under applicable resource-
COMMENTS OF IDAHO POWER COMPANY - 2

specific caps and approving the SAR Method avoided cost rates attached to the
Application. Staff stated that its proposed update was triggered by a separate update to
the cost of capital in Idaho Power’s most recent general rate case (Case No. IPC-E-23-
11) and requested that the proposed updates be made effective as of January 1, 2024,
the effective date of the rates approved by the Commission in the general rate case.
Idaho Power has reviewed the Application and supporting materials and agrees
that the updates proposed by Staff are reasonable and appropriate.
Regarding Staff’s requested effective date of January 1, 2024, Idaho Power
believes the effective date should coincide with the issuance of the Commission’s final
order in this case. An effective date as of the date of the Commission’s order avoids
complication with any established legally enforceable obligations (“LEO”) prior to the
Commission’s order. Idaho Power notes that one project has requested SAR Method
avoided cost pricing since January 1, 2024, for a replacement Energy Sales Agreement
(“ESA”). Idaho Power provided indicative pricing based on the currently-in-effect SAR
model approved in Case No. GNR-E-23-02. The replacement ESA containing such
pricing was executed by both parties on February 27, 2024, and will be submitted to the
Commission for review this week.
Where a final Commission order approving new SAR Method avoided cost rates
has not yet been issued, Idaho Power believes it is appropriate to continue to use pricing
obtained from the previously approved model for any projects that may establish a LEO
or request and execute an ESAs until such an order is issued. Once a final Commission
order is issued, Idaho Power will revoke any indicative pricing that has been provided for
which an ESA has not yet been signed and will provide new pricing based on the new
COMMENTS OF IDAHO POWER COMPANY - 3

approved model.
Idaho Power thanks Staff for its work on this issue.
Respectfully submitted this 28th day of February, 2024.

DONOVAN E. WALKER
Attorney for Idaho Power Company

COMMENTS OF IDAHO POWER COMPANY - 4

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 28th day of February, 2024, 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:

Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

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Christy Davenport, Legal Assistant