20221020Application.pdf

1407 W. North Temple
Salt Lake City, UT 84116

October 20, 2022 VIA ELECTRONIC FILING

Idaho Public Utilities Commission 11331 W. Chinden Blvd. Building 8 Suite 201A
Boise, ID 83714
Attn: Jan Noriyuki Commission Secretary
RE: CASE NO. PAC-E-22-16 IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER TO UPDATE LOAD AND GAS FORECASTS USED IN THE INTEGRATED RESOURCE PLAN AVOIDED COST MODEL

Dear Ms. Noriyuki: Rocky Mountain Power hereby submits for filing with the Idaho Public Utilities Commission its Application in the above-referenced matter.
Informal questions related to this matter may be directed to Ted Weston, Idaho Regulatory Manager at [phone]. Sincerely,
Joelle Steward SVP, Regulation and Customer/Community Solutions
Enclosures
RECEIVED
2022 October 20, PM 3:03
IDAHO PUBLIC
UTILITIES COMMISSION

APPLICATION OF Page 1 ROCKY MOUNTAIN POWER
Joe Dallas (ISB# 10330) 825 NE Multnomah, Suite 2000 Portland, OR 97232
Telephone: [phone] Email: [e-mail] Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO UPDATE LOAD AND GAS FORECASTS USED IN THE INTEGRATED RESOURCE PLAN AVOIDED COST MODEL
) CASE NO. PAC-E-22-16
) ) APPLICATION OF ) ) ROCKY MOUNTAIN POWER

Rocky Mountain Power, a division of PacifiCorp, (“Company”), hereby respectfully
submits this Application to the Idaho Public Utilities Commission, (“Commission”), in compliance
with Order Nos. 32697 and 32802 to update the load forecast, natural gas forecast, and long-term
contract components of the Integrated Resource Plan (“IRP”) avoided cost model. In support of
this Application, Rocky Mountain Power states as follows:
1. Rocky Mountain Power provides electric service to retail customers in the states of
Idaho, Utah, and Wyoming. Rocky Mountain Power is a public utility in the state of Idaho and is
subject to the Commission's jurisdiction with respect to its prices and terms of electric service to
retail customers pursuant to Idaho Code 61-129. Rocky Mountain Power provides retail electric
service to approximately 86,500 customers in the state of Idaho.
I. BACKGROUND
2. Order No. 32697 specified that the inputs to the IRP methodology calculation,
utilized to determine the avoided cost for all new Public Utility Regulatory Policies Act of 1978
(“PURPA”) qualifying facility (“QF”) projects that exceed the published rate eligibility cap, will

APPLICATION OF Page 2 ROCKY MOUNTAIN POWER
be updated every two years upon acknowledgement of the utility's IRP filing with the exception
of the load and the natural gas forecasts which are to be updated annually by June 1st of each year.
The Commission ruled:
“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. For the sake of consistency, these annual
updates should occur simultaneously with SAR updates - on June 1 of each year. 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 find it reasonable to include long-term contract considerations in an
IRP Methodology calculation at such time as the QF and utility have entered into
a signed contract for the sale and purchase of QF power. 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).”1 3. Order No. 32802 changed the due date of the annual update from June 1st to October
15th of each year. If approved, the load forecast, natural gas forecast, and contract information
presented below will be incorporated into Rocky Mountain Power’s IRP avoided cost model.
Consistent with the Commission’s prior orders, this methodology will be utilized by the Company
as the starting point for negotiation of contractual avoided cost rates as of October 15, 2022.
II. LOAD FORECAST
4. The Company’s May 2022 and May 2021 long-term load forecasts are summarized
in Table 1. The May 2022 load forecast shows overall an increase in load compared to the May
2021 load forecast provided in Case No. PAC-E-21-20, which was subsequently approved by
Commission Order No. 35317. The change in the forecast is primarily due to growth expectations
for industrial and commercial customers.
1 In the matter of the Commission’s review of PURPA QF contract provisions including the Surrogate Avoided
Resources (SAR) and Integrated Resource Planning (IRP) methodologies for calculating avoided cost rates. Case No. GNR-E-11-03, Order No. 32697, p. 22.

APPLICATION OF Page 3 ROCKY MOUNTAIN POWER
Table 1

Year California Idaho Oregon Utah Washington Wyoming FERC Total
2022 882 3,952 15,524 26,990 4,550 9,499 277 61,673
2023 870 4,024 16,729 27,717 4,574 9,570 275 63,760
2024 868 4,004 18,770 28,501 4,577 9,645 274 66,640
2025 862 4,009 19,905 29,160 4,537 9,912 272 68,656
2026 858 4,019 20,252 29,760 4,513 9,906 270 69,577
2027 858 4,025 21,471 30,146 4,501 9,863 141 71,005
2028 859 4,036 23,158 30,611 4,507 9,928 23 73,122
2029 855 4,033 23,676 31,011 4,490 9,892 23 73,980
2030 854 4,035 23,872 31,268 4,486 9,938 23 74,476
2031 854 4,038 24,723 31,574 4,487 9,921 23 75,621
2032 855 4,047 25,167 31,979 4,506 9,985 24 76,563
2033 852 4,044 24,021 32,332 4,504 9,965 24 75,743
2034 853 4,047 24,230 32,823 4,521 9,966 24 76,463
2035 853 4,048 24,464 33,365 4,542 9,966 24 77,262
2036 854 4,059 24,768 34,041 4,584 10,000 25 78,330
2037 848 4,060 25,007 34,612 4,606 9,994 25 79,152
2038 843 4,071 25,290 35,274 4,647 10,012 25 80,162
2039 838 4,084 25,571 35,932 4,688 10,034 25 81,173
2040 834 4,101 25,898 36,662 4,736 10,079 25 82,336
2041 823 4,104 26,149 37,310 4,746 10,073 26 83,230
Load Forecast - May 2021
Year California Idaho Oregon Utah Washington Wyoming FERC Total
2021 864 3,931 15,162 26,824 4,526 9,206 297 60,810
2022 863 3,924 15,310 27,521 4,506 9,427 295 61,846
2023 864 3,908 15,706 28,103 4,489 9,470 294 62,833
2024 860 3,901 15,866 28,408 4,447 9,665 291 63,438
2025 859 3,901 15,798 28,766 4,424 9,674 289 63,712
2026 859 3,902 16,051 29,147 4,412 9,665 151 64,187
2027 860 3,910 16,385 29,632 4,420 9,698 22 64,927
2028 856 3,910 16,640 29,924 4,411 9,684 22 65,447
2029 854 3,909 16,907 30,294 4,417 9,686 22 66,089
2030 851 3,913 17,056 30,603 4,426 9,690 22 66,562
2031 852 3,925 17,273 30,984 4,451 9,720 23 67,228
2032 848 3,929 17,078 31,267 4,451 9,701 23 67,296
2033 847 3,941 17,297 31,673 4,474 9,708 23 67,963
2034 847 3,954 17,525 32,082 4,501 9,718 23 68,649
2035 848 3,974 17,804 32,580 4,547 9,759 23 69,536
2036 842 3,984 18,011 32,968 4,570 9,759 24 70,157
2037 836 4,001 18,269 33,414 4,609 9,783 24 70,936
2038 830 4,021 18,528 33,844 4,648 9,807 24 71,704
2039 825 4,044 18,830 34,327 4,699 9,855 24 72,606
2040 816 4,054 19,034 34,675 4,717 9,852 25 73,173
Loads are net of Demand Side Management

APPLICATION OF Page 4 ROCKY MOUNTAIN POWER
III. NATURAL GAS PRICE FORECAST
5. The Company’s most recent Official Forward Price Curve (“OFPC”) was prepared
on September 30, 2022 (“2209 OFPC”). The price forecast used in Case No. PAC-E-21-20 was
prepared on September 30, 2021 (“2109 OFPC”). Table 2 provides the 2209 OFPC natural gas
prices summarized annually by market hub. The 2109 OFPC is also provided for reference only.
Generally gas prices in the 2209 OFPC are up over all forecast years compared to the 2109 OFPC.
Table 2

Natural Gas Price - $/MMBtu
Offical Forward Price Curve - (2209) - 09/30/2022
Year

APPLICATION OF Page 5 ROCKY MOUNTAIN POWER
Table 2 Continued Natural Gas Price - $/MMBTU

IV. CONTRACT TERMINATIONS, EXPIRATIONS, AND ADDITIONS
6. Since filing Case No. PAC-E-21-20, the Company has signed 19 long-term
contracts, including 12 long-term contracts with qualifying facilities, for a total nameplate capacity
of 1,018.4 megawatts. Two long-term contracts have expired without renewal and nine long-term
contracts expired and were renewed, for a total nameplate capacity of 359.1 megawatts. Table 3
provides a list of signed and expired or terminated contracts since October 1, 2021.
7. Rocky Mountain Power currently has 38 non-PURPA, long-term power purchase
agreements with a nameplate capacity of 3,108 megawatts, and 156 PURPA QF contracts with a
nameplate capacity of 2,265 megawatts. New contracts, terminated or expired contracts, as well
as new contract pricing are all updated in the IRP model on a continuous basis.
Offical Forward Price Curve (2109) - 09/30/2021
Year

APPLICATION OF Page 6 ROCKY MOUNTAIN POWER
Table 3

1 Hayward Paul Luckey QF 0.1 12/1/2021 12/31/2035
2 Sunnyside Solar, LCL QF 5.0 9/30/2023 9/29/2035
3 Tata Chemicals (Soda Ash) Partners QF 30.0 1/1/2023 12/31/20234Amy Family Holdings QF 0.7 1/1/2023 12/31/20425Georgetown Irrigation Company QF 0.5 4/1/2022 3/31/20426Three Sisters Irrigation District QF 0.3 6/15/2022 11/30/2041
7 Cedar Springs Wind IV, LLC 350.4 12/31/2024 12/30/2054
8 Anticline Wind, LLC 100.5 12/31/2024 12/30/2054
9 Commercial Energy Management, Inc.QF 0.9 3/1/2021 11/30/203610Stahlbush Island Farms, Inc.QF 1.6 6/1/2022 5/31/202311United States of America Department of Interior Bureau of Land Mgmt QF 0.1 9/1/2022 8/31/202312Douglas County (Galesville Dam)QF 1.9 8/15/2022 12/31/2034
13 Chopin Wind, LLC QF 10.0 11/15/2022 5/29/2036
14 Boswell Wind, LLC 320.0 1/1/2025 12/31/2054
15 City of Hurricane 0.002 9/1/2022 1/31/2023
16 Oregon State University QF 6.5 10/1/2022 9/30/202717Public Utility District No. 2 of Grant County 21.4 1/1/2023 12/31/202318Public Utility District No. 2 of Grant County 18.4 1/1/2023 12/31/202319Public Utility District No. 2 of Grant County 150.2 1/1/2023 12/31/2023
Total Signed MW 1,018.4
Long Term Contracts Expired or Terminated since the October 2021 Filing
1 Dry Creek QF 3.4 4/30/2022
2 Birch Power Company, Inc QF 2.6 3/31/2022
3 Douglas County (Galesville Dam)QF 1.9 4/15/2022
4 Public Utility District No. 2 of Grant County 18.4 12/31/2021
5 Public Utility District No. 2 of Grant County 150.2 12/31/2021
6 Georgetown Irrigation Company QF 0.5 3/31/2022
7 City of Hurricane 0.002 8/31/2022
8 Middle Fork Irrigation District QF 0.9 12/31/2021
9 Mink Creek Hydro LLC QF 3.0 3/31/2022
10 Oregon Environmental Industries, LLC QF 3.2 9/30/2022
11 Seattle City Light 175.0 2/28/2022
Total Terminated MW 359.1

APPLICATION OF Page 7 ROCKY MOUNTAIN POWER
V. COMMUNICATIONS
8. Communications regarding this filing should be addressed to:
Ted Weston Idaho Regulatory Affairs Manager Rocky Mountain Power 1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone] Email: [e-mail] Joe Dallas
825 NE Multnomah Street, Suite 2000
Portland, OR 97232 Telephone: [phone] Email: [e-mail]
In addition, Rocky Mountain Power requests that all data requests regarding this Application be
sent in Microsoft Word to the following:
By email (preferred): [e-mail]

By regular mail: Data Request Response Center PacifiCorp
825 Multnomah, Suite 2000 Portland, Oregon 97232
Informal questions may be directed to Ted Weston, Idaho Regulatory Affairs Manager at (801)
220-2963.
VI. MODIFIED PROCEDURE
9. The Company 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. RP 201 et seq.

APPLICATION OF Page 8 ROCKY MOUNTAIN POWER
VII. REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power hereby respectfully submits its updated load
forecast, natural gas forecast, and QF contract information in compliance with the Commission's
directives in Order Nos. 32697 and 32802 and requests that the Commission issue an order
approving this updated information for inclusion in the Company’s IRP avoided cost calculations.
DATED this 20th day of October 2022.

Respectfully submitted,
ROCKY MOUNTAIN POWER

______________________________
Joe Dallas 825 NE Multnomah Street, Suite 2000
Portland, OR 97232 Telephone: [phone] Email: [e-mail] Attorney for Rocky Mountain Power