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Home My WebLink About20240822Staff Comments.pdf RECEIVED Thursday, August 22, 2024 9:56:22 AM IDAHO PUBLIC UTILITIES COMMISSION CHRIS BURDIN DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 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-24-32 APPROVAL OF A FIRST AMENDMENT TO ) THE ENERGY SALES AGREEMENT FOR ) THE SALE AND PURCHASE OF ELECTRIC ) COMMENTS OF THE ENERGY FROM THE LOW LINE CANAL ) 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 First Amendment("First Amendment")to the Energy Sales Agreement ("ESA")between the Company and South Forks Joint Venture ("Seller") for electric energy generated by the Seller's Low Line Canal Hydro Project ("Facility"). The Company and the Seller entered into an ESA for the purchase and sale of energy produced by the Facility on November 22, 2019, which was approved by the Commission in STAFF COMMENTS 1 AUGUST 22, 2024 Order No. 34574. The First Amendment to the ESA was executed by the parties on May 31, 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 First Amendment. Staff recommends approval of the First 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 First Amendment proposes that the evaluation timeframe change from each calendar year to an annual timeframe from June I through May 31. Staff believes the proposed evaluation timeframe from June I 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 First 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 8.2 megawatts ("MW"). Appendix B of the ESA. However, the actual Nameplate STAFF COMMENTS 2 AUGUST 22, 2024 Capacity Amount and the Maximum Capacity Amount are both 8.0 MW. Therefore, the First Amendment corrects the mistake. Because the updated size is smaller, Staff believes that 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 of the First Amendment to the ESA between the Company and Seller for electric energy generated by the Seller's Low Line Canal 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. kAl Chris Burdin Deputy Attorney General Technical Staff: Yao Yin I:\Utility\UMISC\COMMENTS\IPC-E-24-32 Comments.docx STAFF COMMENTS 3 AUGUST 22, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS �DAY OF AUGUST 2024, SERVED THE FOREGOING COMMENTES OF THE COMMISSION STAFF, IN CASE NO. IPC-E-24-32, 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: energycontractskidahopower.com E-MAIL: mgoicoecheaallen cr,idahopower.com dwalkergidahopower.com dockets(kidahopower.com DOUG DOCKTER E-MAIL: ddockternida-west.com PAT ICIA JORDA CERTIFICATE OF SERVICE