20171201Comments.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 10177
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
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IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER TO UPDATE
THE LOAD AND GAS FORECASTS USED IN
THE INTEGRATED RESOURCE PLAN
AVOIDED COST MODEL.
CASE NO. PAC.E.I7.I3
COMMENTS OF THE
COMMISSION STAFF
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COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Camille Christen, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 33924 on October 31,2017,
submits the following comments.
BACKGROUND
On October 13,2077, Rocky Mountain Power, a division of PacifiCorp, filed its annual
update to certain components of its avoided cost rate calculation for qualifying facilities (QF)
under the Public Utility Regulatory Policies Act of 1978 (PURPA).r Specifically, Rocky
Mountain Power updated the load forecast, natural gas forecast, and contract information
components that it uses to calculate avoided cost rates under the incremental cost Integrated
Resource Plan (IRP) method. Rocky Mountain Power asks the Commission to issue an Order
I Rocky Mountain Power filed an errata updating certain information in the Application on November 29, 2017
STAFF COMMENTS DECEMBER 1, 20171
approving the updated information for inclusion in the Company's IRP avoided cost calculations
with an October 15,2017 effective date.
The Commission requires utilities to update fuel price forecasts and load forecasts each
year on October I 5. Order No. 32802 at 3. If the Commission approves the updates, the
Company will incorporate them into its IRP avoided cost model and use the model to begin
negotiating contractual avoided cost rates as of October 15, 2017 . Application at 2.
STAFF ANALYSIS
Staff recommends approval of the updated load forecast, natural gas forecast, and
long-term PURPA contracts to be used in the IRP methodology.
Load Forecast
Staff compared Rocky Mountain Power's proposed system load forecast from 2017
through 2037 to last year's filing in Case No. PAC-E-16-15. The analysis shows a slight
decrease in load in the proposed forecast load, which is driven by reduced industrial class loads,
due in large part to lower commodity prices, and continued gains in energy conservation as
evidenced by a drop in the average use per customer. Staff believes the new forecast is
reasonable and acceptable.
Natural Gas Forecast
Staff also compared Rocky Mountain Power's proposed natural gas price forecast from
2018 through2036 to last year's filing in Case No. PAC-E-16-15. The Company provides
forecasts for several indices: the Opal Gas Index, Henry Hub Index, Sumas Index, Stanfield
Index, San Juan Index, AECO Index, and SOCALBOR Index. The2017 natural gas forecast has
decreased from the 2016 natural gas forecast for the same period of time, which is consistent
with the drop in EIA Henry Hub Reference forecasts from 2016 to 2017. Staff believes the
proposed natural gas forecast is reasonable and acceptable.
2STAFF COMMENTS DECEMBERI,2OIT
Contract Terminations. Expirations. and Additions
Since filing Case No. PAC-E-16-15, the Company has signed 19 long-term contracts
including l8 long-term contracts with qualifying facilities for a total nameplate capacity of 672.2
megawatts. Two long-term contracts with a combined nameplate capacity of 4.8 megawatts
have terminated. New contracts, terminated or expired contracts, as well as new contract pricing
are all included in the IRP model on a continuous basis.
STAFF RECOMMENDATIONS
Staff believes the load and gas price forecasts submitted by Rocky Mountain Power
reflect their most current estimates, and were prepared with the methods used in its IRP. Staff
believes the load and gas price forecasts and the long-term contract changes submitted by the
Company comply with the requirements of Order Nos. 32697 and32802. Staff recommends that
the Commission approve the forecasts and contract changes.
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Respectfully submitted this I day of December 2017 .
Camille Christen
Deputy Attorney General
Technical Staff: Yao Yin
Bentley Erdwurm
Kevin Keyt
i:umisc/comments/pacel 7. l3ccyybeksk comments
JSTAFF COMMENTS DECEMBER 1, 2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF DECEMBER 2017,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-8.17-13, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ROCKY MOTINTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@.pacifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareque st@,pac i fi c orp. com
DANIEL E SOLANDER
SENIOR COLINSEL
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 841 16
E-MAIL: [e-mail]
SECRET
CERTIFICATE OF SERVICE
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