20240822Staff Comments .pdf

RECEIVED
Thursday, August 22, 2024 9.41:38 AM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
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 THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-24-25
APPROVAL OF A SECOND AMENDMENT )
TO THE ENERGY SALES AGREEMENT FOR )
THE SALE AND PURCHASE OF ELECTRIC ) COMMENTS OF THE
ENERGY FROM THE BLACK CANYON#3 ) COMMISSION STAFF
HYDRO PROJECT )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Chris Burdin, Deputy Attorney General,
submits the following comments.
BACKGROUND
On July 1, 2024, Idaho Power Company ("Company") filed an application with the
Commission requesting an order approving the Second Amendment("Second Amendment") to
the Energy Sales Agreement("ESA")between the Company and Wood Hydro LLC ("Seller")
for electric energy generated by the Seller's Black Canyon#3 Hydro Project("Facility").
The Company and the Seller entered into an ESA for the purchase and sale of energy
produced by the Facility on January 30, 2019, and a First Amendment to the ESA on March 13,
2019. The amended ESA was approved by the Commission in Order No. 34295.
STAFF COMMENTS 1 AUGUST 22, 2024

STAFF ANALYSIS
Staff s review focused on the evaluation timeframe for seasonal hydro rates, Article
XXIII Modification, the Nameplate Capacity Amount, and Maximum Capacity Amount in the
Second Amendment. Staff recommends approval of the Second Amendment.
Evaluation Timeframe for Seasonal Hydro Rates
The Seller is paid for the energy from the Facility at seasonal hydro avoided cost rates.
To qualify for the seasonal hydro rates, the Facility must produce at least 55% of its annual
generation during the months of June through August per each calendar year. Order No. 32802
at 5 and 6. The Second Amendment proposes that the evaluation timeframe change from each
calendar year to an annual timeframe from June 1 through May 31.
Staff believes the proposed evaluation timeframe from June 1 through May 31 is
acceptable because it has been previously allowed by the Commission for the purpose of
determining whether the 55%requirement is met. Order No. 35908 at 5 and 6.
Article XXIII Modification
Staff reviewed Article XXIII(Modification)proposed in the Second Amendment that
addresses potential modifications to the Facility, and Staff 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 Seller of the modified Facility. This treatment is consistent with the
Commission direction in Order No. 35705.
Nameplate Capacity Amount and Maximum Capacity Amount
The current ESA lists both the Nameplate Capacity Amount and the Maximum Capacity
Amount at 130 kilowatts ('kW"). Appendix B of the ESA. However, the actual Nameplate
Capacity Amount and the Maximum Capacity Amount are both 128.8 W. Therefore, the
Second Amendment corrects the mistake. Because the updated size is smaller, Staff believes that
STAFF COMMENTS 2 AUGUST 22, 2024

it does not create a need to adjust the avoided cost rates paid to the Seller and that no
overpayment will occur.
STAFF RECOMMENDATION
Staff recommends the Commission approve the Second Amendment to the ESA between
the Company and the Seller for electric energy generated by the Seller's Black Canyon#3 Hydro
Project.
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 Seller of the modified Facility.
Respectfully submitted this 22nd day of August 2024.
�k 1-�Jq
Chris Burdin
Deputy Attorney General
Technical Staff: Yao Yin
L•\Utility\UMISC\COMMENTS\IPC-E-24-25 Comments.docx
STAFF COMMENTS 3 AUGUST 22, 2024

CERTIFICATE OF SERVICE
n
I HEREBY CERTIFY THAT I HAVE THIS DAY OF AUGUST 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-24-25, 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: energycontracts(a�idahopower.com
E-MAIL: mgoicoecheaallen&idahopower.com
dwalker&idahopower.com
[e-mail]
TEDSORENSON
E-MAIL: ted(ktsorenson.net
PAT ILIA JORDA
CERTIFICATE OF SERVICE