20240815Staff Comments.pdf

RECEIVED
Thursday, August 15, 2024 9.08.36 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-24-24
APPROVAL OF A SECOND AMENDMENT )
TO THE POWER PURCHASE SALES )
AGREEMENT BETWEEN IDAHO POWER ) COMMENTS OF THE
AND TELOCASET WIND POWER ) COMMISSION STAFF
PARTNERS )
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 June 21, 2024, Idaho Power Company("Company") applied for approval of a Second
Amendment to a power purchase agreement ("PPA")between itself and Telocaset Wind Power
Partners, LLC ("Seller") for energy generated by the Elkhorn Wind Park("Facility")
("Application"). The Facility is not a qualifying facility under the Public Utility Regulatory
Policies Act of 1978.
The Company and the Seller(collectively, "the Parties") entered into the PPA with a 20-
year term on December 15, 2006, but the 20-year term started when the Facility first became
STAFF COMMENTS 1 AUGUST 15, 2024

operational on December 28, 2007, and did not include pricing for 2027, effectively the last year
of the 20-year contract.
STAFF ANALYSIS
The current PPA contains two pricing options: Post-Operation Date Pricing and Post-
Operation Date Alternative Pricing. Both options contain prices from 2007 through 2026 but do
not include pricing for the last year(i.e. 2027) of the 20-year term. See Appendix A of the PPA.
The Company has been using the Post-Operation Date Alternative Pricing since 2012.
Application at 2.
The Company proposes the Post-Operation Date Alternative Pricing for 2027 in the
Second Amendment to the PPA. Staff confirmed that the proposed 2027 pricing uses the
approved method authorized by the Commission in Order No. 30259.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Second Amendment.
Respectfully submitted this 15th day of August 2024.
Michael Duval
Deputy Attorney General
Technical Staff: Yao Yin
Seungjae Lee
I:\Utility\UMISC\COMMENTS\IPC-E-24-24 Comments.docx
STAFF COMMENTS 2 AUGUST 15, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS _L6 7DAY OF AUGUST 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-24-24, BY &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: energycontracts&idahopower.com
E-MAIL: mgoicoecheaallengidahopower.com
dwalkerkidahopower.com
docketsgidahopower.com
BRUNO SUBIETA
E-MAIL: bruno.subietakedp.com
/v!
PATRICIA JORDAN
CERTIFICATE OF SERVICE