20251110Staff Comments.pdf

RECEIVED
November 10, 2025
ADAM TRIPLETT IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 10221
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-25-30
APPROVAL OR REJECTION OF AN )
ENERGY SALES AGREEMENT WITH )
NORTH SIDE ENERGY COMPANY,INC. ) COMMENTS OF THE
FOR THE SALE AND PURCHASE OF ) COMMISSION STAFF
ELECTRIC ENERGY FROM THE )
HAZELTON A HYDRO PROJECT )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Adam Triplett, Deputy Attorney General,
submits the following comments.
BACKGROUND
On September 24, 2025, Idaho Power Company("Company"), applied for approval of an
Energy Sales Agreement ("ESA")between the Company and North Side Energy Company, Inc.
("Seller"). Under the proposed ESA, the Seller would provide, and the Company would
purchase, electricity generated by the Hazelton A Hydro Project, a qualified facility ("QF")
under the Public Utility Regulatory Policies Act located in Jerome County, Idaho.
The QF is an 8.694-megawatt("MW') irrigation canal hydro facility currently delivering
energy to the Company under a contract executed in 2010 ("2010 Agreement"), which will
STAFF COMMENTS 1 NOVEMBER 10, 2025

expire on February 28, 2026.1 The proposed ESA is a new 20-year contract that will replace the
2010 Agreement. Under the proposed ESA, the Company will purchase energy from the QF at
non-levelized, seasonal-hydro published avoided cost rates, calculated using the SAR avoided
cost methodology established in Order No. 36416, with full capacity payments throughout the
term.
STAFF ANALYSIS
Staff s review focused on eligibility for and the amount of capacity payments, avoided
cost rates, Article XXIII (Modification), and the timeframe for seasonal-hydro evaluations. Staff
recommends that the Commission approve the proposed ESA and declare all payments for
purchases of energy under the ESA be allowed as prudently incurred expenses for ratemaking
purposes.
Capacity Pam
The ESA allows immediate capacity payments, and Staff believes this treatment is
reasonable. During the contract term of the 2010 Agreement, the Company has acquired
significant amounts of capacity to meet its capacity needs. For example, the Company has
acquired resources in 2023,2 2024,3 and 20254 to address the system's capacity deficiency in
these years. Staff believes that the facility has contributed to meeting the Company's need for
capacity and should be granted immediate capacity payments under the proposed ESA.
The nameplate capacity size and the Maximum Capacity Amount under the proposed
ESA remain the same as in the current contract. Therefore, Staff believes the QF should be
granted immediate capacity payments for its entire generation capacity amount over the full term
of the ESA.
Avoided Cost Rates
Staff has verified that the avoided cost rates contained in the proposed ESA are correct.
1 The 2010 Agreement listed both the nameplate capacity and the Maximum Capacity Amount at 8.1 MW. The
Third Amendment of the ESA modified the nameplate capacity to 8.694 MW and modified the Maximum Capacity
Amount to 7.7 MW,which was approved in Order No.36040.
2 Case No.IPC-E-22-13.
3 Case Nos.IPC-E-23-05 and IPC-E-23-20.
4 Case No.IPC-E-23-20.
STAFF COMMENTS 2 NOVEMBER 10, 2025

Article XXIII (Modification)
Staff reviewed Article XXIII(Modification) in the ESA that addresses potential
modifications to the Facility and believes the language complies with Order No. 35705.
Timeframe for Seasonal-Hydro Evaluations
To qualify for the seasonal hydro rates, QFs must produce at least 55% of its annual
generation during the months of June through August each calendar year. Order No. 32802 at 5
and 6. Subsequently, the Commission allowed the annual evaluation timeframe to be from June
1 through May 31 of the following year. Order No. 35908 at 5 and 6. The proposed ESA uses a
timeframe from June I through May 31, which is allowed under Order No. 35908.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the proposed ESA and declare all
payments for purchases of energy under the ESA be allowed as prudently incurred expenses for
ratemaking purposes.
Respectfully submitted this I Oth day of November 2025.
0(
ZA
Adam Triplett
Deputy Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\IPC-E-25-30 Comments.docx
STAFF COMMENTS 3 NOVEMBER 10, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1 OTH DAY OF NOVEMBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN CASE
NO. IPC-E-25-30, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
Idaho Power Company:
DONOVAN E. WALKER
LISA C. LANCE
IDAHO POWER COMPANY
1221 WEST IDAHO STREET (83702)
PO BOX 70
BOISE ID 83707-0070
E-MAIL:
dwalker(&Jdahopower.com
llance&idahopower.com
Energycontracts&idahopower.com
PATRICIA JORD , SECRETARY
CERTIFICATE OF SERVICE