20230224IPC to Staff 1-4.pdf

MEGAL GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

February 24, 2023

VIA ELECTRONIC MAIL

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-02
Bypass Hydro Project
Idaho Power Company’s Application re Energy Sales Agreement with
North Side Energy Company, Inc.

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the First
Production Request of the Commission Staff in the above-entitled matter. If you have any
questions about the attached documents, please do not hesitate to contact me.

Very truly yours,

Megan Goicoechea Allen

MGA:cld
Enclosures
RECEIVED
2023 February 24, 1:58PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
NORTH SIDE ENERGY COMPANY, INC.
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE BYPASS
HYDRO PROJECT.

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CASE NO. IPC-E-23-02

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff (“IPUC or
Commission”) dated February 3, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 1: Please respond to the following regarding
Article XXIII Modification under the proposed energy sales agreement:
a. Please confirm that between the time the Seller notifies Idaho Power of an intention
of modifying the Facility and the time the modification actually occurs, the Parties
do not plan to seek Commission approval of the intended modification.
b. Please confirm that the Parties will seek Commission approval of the modification
after the modification actually occurs.
c. Please explain how the language in the contract ensures that the QF is paid the
proper rate as of the first operation date after modifications to the Facility are made
and that the description of the Facility reflected in the final approved amendment
describe the Facility as actually modified.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1:

a. Idaho Power does not generally anticipate filing for Commission approval of a
modification to an energy sales agreement (ESA) prior to a facility modification
occurring. The timing of a filing seeking approval for an ESA modification will
depend on the nature and effect of the proposed facility modification and the
resulting proposed ESA modifications. Please also see the answer to part (c).
b. Yes. Idaho Power anticipates that generally it would seek Commission approval of
an amendment to the ESA to reflect a facility modification after the modification
actually occurs, depending on the nature of the modification.
c. The modification language Idaho Power proposed in Case No. IPC-E-22-28
provides Idaho Power the option to revise the ESA, or terminate it, upon notification
of a facility modification. The nature of the proposed facility modification would
dictate what kind of ESA change (or termination) might be appropriate. Idaho

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
Power would consider the nature of the modification and whether the modification
properly should trigger a change to rates, a different revision to the ESA, or
termination of the ESA. Any actual changes to or termination of the ESA would be
implemented through subsequent contractual documents–not through the existing
language of the ESA. Depending on the circumstances, any subsequent ESA
amendment or termination could be made effective as of the date of the facility
modification and would be submitted to the Commission for approval. By
addressing the possibility of facility modifications and requiring the Seller to provide
information to Idaho Power, the proposed modification language provides flexibility
and a process by which to ensure that the ESA accurately reflects the as-built
facility and contains the appropriate rates and other terms and conditions.
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning, and Coordination Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 2: Please respond to the following regarding
the Facility's nameplate capacity.
a. Please provide evidence that each of the three generators has a nameplate
capacity of 3333 kW as stated in Appendix B.
b. Appendix B states "Facility Nameplate Capacity: 9960 kW." Please confirm that
9960 kW should have been 9999 kW. If not, please explain.
c. According to Appendix B, the station service uses 39 kW out of 9999 kW. Please
provide evidence to support the 39-kW usage.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2:

a. See photos below of the nameplate for each of the 3 generators. The photos are
also provided as attachments 1-3.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5
b. The Facility Nameplate Capacity of 9960 kW listed in Appendix B represents the
net generator nameplate capacity amount that can be delivered to Idaho Power
less station service as agreed to by the Seller and consistent with the Schedule 72
Generator Interconnection Agreement and the 1986 Energy Sales Agreement
(ESA). The Company’s forecasting and planning models have been using 9960
kW based on the 1986 ESA, and the parties agreed to continue to use that amount
for both Nameplate Capacity and Maximum Capacity Amount in the replacement
ESA to ensure uniformity and consistency.
c. Please see response to (b). Idaho Power is not in possession of additional
evidence of 39-kW station service usage. As documented in Exhibit B-1, the
parties agreed to use 9960 kW for the net generator nameplate that can be
delivered to Idaho Power less station service for both the Nameplate Capacity and
Maximum Capacity Amount, which is consistent with the current ESA.
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning, and Coordination Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 3: The Application states "should the Facility
exceed 10 aMW on a monthly basis or 2790 kW on an hourly basis, Idaho Power will
accept the energy, defined as Inadvertent Energy, but will not purchase or pay for it."
Please confirm that 2790 kW should have been 9960 kW (or 9999 kW depending on the
actual nameplate capacity), which is the Maximum Capacity Amount.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Yes, please see the
Errata to Idaho Power’s Application filed on February 16, 2023. As noted therein, the
reference to 2,790 kW was in error and should have instead referred to the Maximum
Capacity Amount. The Maximum Capacity Amount, as described in the ESA and in the
response to Staff’s Request No. 2, is 9,960 kW.
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning, and Coordination Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 4: Prices for 2023 in Section E-2 of Appendix
E (Base Energy Light Load Purchase Price) on Page 53 of the Energy Sales Agreement
are not fully shown due to a formatting issue. What are the proposed prices for 2023 in
Section E-2?
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the Errata to
Idaho Power’s Application filed on February 16, 2023, providing a replacement page for
Section E-2 of Appendix E that fully displays the prices for 2023.
The response to this Request is sponsored by Camille Christen, Resource
Acquisition, Planning, and Coordination Manager, Idaho Power Company.

Respectfully submitted this 24th day February 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF - 8
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 24th day of February 2023, I served a true and
correct copy of the within and foregoing Idaho Power Company’s Response to the First
Production Request of the Commission Staff upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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Alan W. Hansten, General Manager
North Side Energy Company
921 N. Lincoln Ave.
Jerome, ID 83338
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________________________________
Christy Davenport, Legal Assistant