20050317Comments.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OF A FIRM ENERGY SALES AGREEMENT
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY BETWEEN IDAHO
POWER COMPANY AND PILGRIM STAGE
STATION WIND PARK LLC.
CASE NO. IPC-O5- 7
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice
of Application, Notice of Modified Procedure and Notice on Comment Deadline issued on
March 15 2005, submits the following comments.
BACKGROUND
On February 24 2005, Idaho Power Company (Idaho Power; Company) filed an
Application with the Idaho Public Utilities Commission (Commission) requesting approval of a
Firm Energy Sales Agreement (Agreement) between Idaho Power and Pilgrim Stage Station
Wind Park, LLC (Pilgrim Stage Station) dated February 18, 2005. Under the Agreement
Pilgrim Stage Station will sell and Idaho Power will purchase electric energy generated by the
Pilgrim Stage Station Project located near Hagerman, Idaho in an area more particularly
STAFF COMMENTS MARCH 17, 2005
described as Sections 19, 24, 25 and 31 , Township 7 South, Range 12 East, Boise Meridian
Twin Falls County, Idaho. The Project consists of seven (7) 1.5 MW GE wind turbines. The
nameplate rating of the project is 10.5 MW. Under normal and/or average conditions the project
will not exceed 10 aMW on a monthly basis. If energy in excess of this amount (Inadvertent
Energy) is accidentally generated, Idaho Power will accept Inadvertent Energy that does not
exceed the 10.5 MW maximum capacity amount but will not purchase or pay for it. Agreement
~ 7.
The Pilgrim Stage Station Project will be a qualified small power production facility (QF)
under the applicable provisions of the Public Utility Regulatory Policies Act of 1978 (PURP A).
Pilgrim Stage Station has selected December 31 , 2005 as the scheduled operation date and
January 15 , 2006 as the first energy date. As reflected in Section 24 of the Agreement, the
Agreement will not become effective until the Commission has approved all the Agreement's
terms and conditions and declares that all payments that Idaho Power makes to Pilgrim Stage
Station for purchases of energy will be allowed as prudently incurred expenses for ratemaking
purposes.
ST AFF ANALYSIS
The Pilgrim Stage Station Project is one of four nearly identical projects with contracts
now pending before the Commission. All four proj ects are located in the Bell Rapids area west
of the city of Hagerman. Attachment A shows the location of these four projects. In addition to
these four projects, the Fossil Gulch Project is also located in the same vicinity. The
Commission on November 12 2004 in Order No. 29630 approved a power sales agreement for
Fossil Gulch. Construction of the Fossil Gulch Project is nearly complete. These four projects
in addition to the Fossil Gulch Project, bring the total installed capacity in the vicinity to 50 MW.
Staff has reviewed the Agreement between Idaho Power and Pilgrim Stage Station and
finds that it comports with the terms and conditions of Commission Order No. 29632 (V.
Geothermal et. al v. Idaho Power) and avoided cost Order No. 29646. The contract is for a 20-
year term and contains the published non-levelized avoided cost rates set forth in Order
No. 29646.
STAFF COMMENTS MARCH 17, 2005
RECOMMENDATION
Staff recommends approval of the Agreement with an effective date of February 2005.
RE S PECTFULL Y suhmi tted this 14 day 0 f March 2005.
Scott D. Woodbury
Deputy Attorney General
i :umisc :commentslipceO5. 7 swrps
STAFF COMMENTS MARCH 2005
Attachment A
IPC-05-ase
Staff Comments
3/17/05
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF MARCH 2005
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-05-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
BARTON L KLINE
MONICA MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
RANDY ALLPHIN
CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
JAMES CARCULIS
PILGRIM STAGE STATION WIND PARK
LLC
1424 DODGE
HELENAMT 59601
,--
SECRETARY
CERTIFICATE OF SERVICE