20240822Staff Comments.pdf

RECEIVED
Thursday, August 22, 2024 10.47:14 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 THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-24-29
APPROVAL OF A SECOND AMENDMENT )
TO THE ENERGY SALES AGREEMENT FOR )
THE SALE AND PURCHASE OF ELECTRIC ) COMMENTS OF THE
ENERGY FROM THE NORTH GOODING ) COMMISSION STAFF
MAIN HYDRO PROJECT )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Michael Duval, 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 North Gooding Main Hydro
LLC ("Seller") for electric energy generated by the Seller's North Gooding Main Hydro Project
("Facility").
The Company and the Seller entered into an ESA for the purchase and sale of energy
produced by the Facility on July 29, 2015, which was approved by the Commission in Order No.
STAFF COMMENTS 1 AUGUST 22, 2024

33404. Later, the Company and the Seller entered into a First Amendment to the ESA on July 9,
2020, which was approved by the Commission in Order No. 34782.
STAFF ANALYSIS
Staff s review focused on the evaluation timeframe for seasonal hydro rates and Article
XXIII Modification. 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 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 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.
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 North Gooding Main
Hydro Project.
STAFF COMMENTS 2 AUGUST 22, 2024

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.
Michael Duval
Deputy Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\IPC-E-24-29 Comments.docx
STAFF COMMENTS 3 AUGUST 22, 2024

CERTIFICATE OF SERVICE
-1'ak�
I HEREBY CERTIFY THAT I HAVE THIS � DAY OF AUGUST 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF , IN CASE
NO. IPC-E-24-29, 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(cr�idahopower.com
E-MAIL: mgoicoecheaallengidahopower.com
dwalkergidahopower.com
dockets gidahopower.com
TEDSORENSON
E-MAIL: ted(cr�,tsorenson.net
van
PA RICIA JORDA
CERTIFICATE OF SERVICE