20220210Final_Order_No_35317.pdf

ORDER NO. 35317 1

Office of the Secretary
Service Date
February 10, 2022

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO
UPDATE CONTRACTS, LOAD, AND GAS
FORECASTS USED IN THE INTEGRATED
RESOURCE PLAN AVOIDED COST MODEL
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CASE NO. PAC-E-21-20

ORDER NO. 35317

On October 27, 2021, Rocky Mountain Power, a division of PacifiCorp, (“Company”)
submitted a compliance filing (“Filing”) requesting the Commission issue an order accepting its
updated load forecast, natural gas price forecast, and long-term contract components of the
Integrated Resource Plan (“IRP”) avoided cost model, as required by Order Nos. 32697 and 32802.
The Company requested its Filing be processed by Modified Procedure.
On November 24, 2021, the Commission issued a Notice of Application and
established a December 15, 2021, public comment deadline and a December 22, 2021, Company
reply deadline. Order No. 35232. The Commission Staff (“Staff”) was the only party who
submitted comments. The Company did not file reply comments.
Having reviewed the record in this case, including Staff’s comments, the Commission
approves the Company’s annual update.
BACKGROUND
Under the Public Utilities Regulatory Policy Act of 1978 (“PURPA”) and the Federal
Energy Regulatory Commission’s (“FERC”) implementing regulations, this Commission has
approved the IRP method to calculate avoided cost rates for Qualifying Facilities (“QFs”) that are
above the resource-specific project eligibility cap. QFs below the applicable project eligibility cap
are eligible to receive published avoided cost rates calculated using the surrogate avoided resource
(“SAR Method”). See Order No. 32697 at 7-8. The avoided cost rate is the purchase price paid to
QFs for the energy and capacity that the QF provides to the utility. 18 C.F.R. § 292.101(b)(6)
(defining “avoided cost”). To ensure that avoided costs most accurately reflect the utility’s
marginal cost of energy and capacity, the Commission has directed utilities to “update fuel price
forecasts and load forecasts annually – between IRP filings,” and to update the Commission about
the utility’s “long-term contract commitments because of the potential effect that such
commitments have on a utility’s load and resource balance.” See Order No. 32697 at 22.

ORDER NO. 35317 2
THE FILING
The Company’s August 2021 and June 2020 long-term load forecasts were summarized
in Table 1 of the Company’s Filing by annual gigawatt-hours (“GWh”). Filing at 3. The August
2021 load forecast demonstrated a slight increase in load compared to the June 2020 load forecast
provided in Case No. PAC-E-20-16, which was approved by Commission Order No. 34911. Id. at
2.
The Company’s most recent Official Forward Price Curve (“OFPC”) was prepared on
September 30, 2021 (“2109 OFPC”). The OFPC used in Case No. PAC-E-20-16 was prepared on
September 30, 2020 (“2009 OFPC”).
Table 2 in the Company’s Filing provided the 2109 OFPC natural gas prices
summarized annually by market hub. Id. at 4. The 2009 OFPC was also provided in Table 2 for
reference. The Company indicated that, generally, gas prices in the 2109 OFPC were up slightly
over the next five years, but down slightly thereafter compared to the 2009 OFPC. Id. at 4.
Since filing Case No. PAC-E-20-16, the Company stated it had signed 26 long-term
contracts, including 21 long-term contracts with QFs, for a total nameplate capacity of 460.2
megawatts. Id. at 5. The Company further explained that three long-term contracts expired without
renewal and eleven long-term QF contracts expired or terminated, for a total nameplate capacity
of 706.9 megawatts. Id at 5.
Table 3 in the Company’s Filing provided a list of signed and expired or terminated
contracts since October 8, 2020. Id. at 6. The Company represented that it had 34 non-PURPA,
long-term power purchase agreements with a nameplate capacity of 2,348 megawatts, and 153
PURPA QF project contracts with a nameplate capacity of 2,248 megawatts. Id. at 5. The Company
further stated that new, terminated, or expired contracts, and new contract pricing are continually
updated in the IRP model. Id.
The Company requested that the Commission issue an order approving the updated
load forecast, natural gas forecast, and long-term contract components to include in the Company’s
IRP avoided cost calculations effective October 15, 2021.
STAFF COMMENTS
Staff reviewed the Company’s Filing and attachments and recommended approval of
the proposed load forecast, and the natural gas forecast to be used in the IRP method to determine
avoided cost rates in contracts signed on January 1, 2022, until the effective date of the next annual

ORDER NO. 35317 3
update. Staff also recommended that the contract changes included in the Filing be approved if
the Company kept the long-term, twenty (20) year Sunny Bar Ranch contract but removed the
redundant, one-year Sunny Bar Ranch extension contract.1 Finally, Staff recommended that the
effective date of the load and natural gas forecast, and contract changes should occur on January
1, for this and all future similar compliance filings.
COMMISSION FINDINGS AND DECISION
The Commission has jurisdiction over this matter under Idaho Code §§ 61-501, -502
and -503. The Commission is empowered to investigate rates, charges, rules, regulations, practices,
and contracts of public utilities and to determine whether they are just, reasonable, preferential,
discriminatory, or in violation of any provision of law, and to fix the same by order. Idaho Code §§
61-502 and 61-503. In addition, the Commission has authority under PURPA and FERC
regulations to set avoided costs, to order electric utilities to enter fixed-term obligations for the
purchase of energy from QFs, and to implement FERC rules. The Commission may enter any final
order consistent with its authority under Title 61 and PURPA.
Under this authority, we have reviewed the record, including the Filing and comments.
We find that the Filing complies with our directives in Order Nos. 32697 and 32802. The load
growth and natural gas price forecasts are reasonable as filed given the information available at
this time. The Commission further finds that all contract changes as filed are reasonable except for
the one (1) year Sunny Bar Ranch extension contract, which shall be removed. The long-term,
twenty (20) year Sunny Bar Ranch contract that was filed in Case No. PAC-E-21-10, however,
should remain.
Last, we find it reasonable to have an effective date of January 1, 2022, for the
Company in this filing. We further find it reasonable that all subsequent filings by the Company
to update load forecast, natural gas price forecast, and contracts used as inputs to calculate its IRP
will have an effective date of January 1 of the year following its annual filing. Having an effective
date after the filing deadline will provide more time to review the Company’s filings and prevent
having an identical filing deadline and effective date.

1 The Company ultimately withdrew the Application in Case No. PAC-E-20-17, seeking Commission approval of the
one-year Sunny Bar Ranch extension contract.

ORDER NO. 35317 4
O R D E R
IT IS HEREBY ORDERED that the Company’s annual updates to its energy load and
natural gas price forecasts are reasonable and approved, effective as of January 1, 2022.
IT IS FURTHER ORDERED that the one (1) year Sunny Bar Ranch extension contract
shall be removed while the twenty (20) year, long-term Sunny Bar Ranch contract shall remain.
IT IS FURTHER ORDERED that all subsequent filings by the Company to update load
forecast, natural gas price forecast, and contracts used as inputs to calculate its IRP will have an
effective date of January 1 of the year following its annual filing.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order with regard to any
matter decided in this Order. Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code § 61-
626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 10th day
of February 2022.

_____
ERIC ANDERSON, PRESIDENT

JOHN CHATBURN, COMMISSIONER

//ABSTAIN TO AVOID CONFLICT//

JOHN R. HAMMOND, JR., COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

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