20240711Staff Comments.pdf

RECEIVED
Thursday, July 11, 2024 10.28.09 AM
IDAHO PUBLIC
UTILITIES COMMISSION
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-21
APPROVAL OF A FIRST AMENDMENT TO )
THE ENERGY SALES AGREEMENT FOR )
THE SALE AND PURCHASE OF ELECTRIC ) COMMENTS OF THE
ENERGY FROM THE SHOSHONE HYDRO ) COMMISSION STAFF
PROJECT )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Michael Duval, Deputy Attorney General, submits the following
comments.
BACKGROUND
On May 24, 2024, Idaho Power Company("Company") applied for approval of a First
Amendment("Amendment") to an existing energy sales agreement ("ESA")between itself and
Shoshone Hydro LP ("Seller") for energy generated by the Shoshone Hydro Project("Facility").
The Company and the Seller entered into the original ESA on October 13, 2016, which was
approved in Order No. 33677.
STAFF COMMENTS 1 JULY 11, 2024

STAFF ANALYSIS
Staff has reviewed the Amendment and recommends approval. The Amendment
proposes a five-day advanced notice timeframe for adjusting the monthly estimated Net Energy
Amounts ("NEA") and a revision to Article XXIII Modifications to update provisions related to
any future modifications to the Facility.
Five-Day Advanced Notice
Staff believes it is reasonable to change from a one-month advanced notice to a five-day
advanced notice for adjusting the monthly estimated NEA,because monthly estimates provided
closer to the time of delivery improve the accuracy of input used for short-term operational
planning. In addition, the five-day advanced notice has been authorized in prior Commission
orders.
Article XXIII Modifications
Staff reviewed Article XXIII Modifications in the Amendment that addresses potential
modifications to the Facility and believes the language complies with Order No. 35705.
If the Facility is modified, Staff recommends that only the net power supply expense that
reflects the proper authorized rate for all energy delivered as of the first operation date of the
modified Facility be included in the Company's Power Cost Adjustment, regardless of the
compensation paid to the modified Facility. This treatment is consistent with the Commission
direction in Order No. 35705.
STAFF RECOMMENDATION
Staff recommends the following:
1. Approval of the First Amendment to the ESA; and
2. If the Facility is modified, Staff recommends that only the net power supply expense
that reflects the proper authorized rate for all energy delivered as of the first operation
date of the modified Facility be included in the Company's Power Cost Adjustment,
regardless of the compensation paid to the modified Facility.
STAFF COMMENTS 2 JULY 11, 2024

Respectfully submitted this llth day of July 2024.
Michael Duval
Deputy Attorney General
Technical Staff. Yao Yin
L\Utility\UMISC\COMMENTS\IPC-E-24-21 Comments.docx
STAFF COMMENTS 3 JULY 11, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ' *DAY OF JULY 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-24-21, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN ENERGY CONTRACTS
DONOVAN E WALKER IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-MAIL: energycontractsgidahopower.com
E-MAIL: mgoicoecheaallengidahopower.com
dwalkerkidahopower.com
dockets idahopower.com
JOHN J STRAUBHAR
E-MAIL: jsgwater2wire.com
144,
PATRICIA JORDAN
CERTIFICATE OF SERVICE