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 TUANA GULCH WIND PARK LLC.
CASE NO. IPC-O5-
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 Tuana Gulch Wind Park
LLC (Tuana Gulch) dated February 18 2005. Under the Agreement, Tuana Gulch will sell and
Idaho Power will purchase electric energy generated by the Tuana Gulch Proj ect located near
Hagerman, Idaho in an area more particularly described as Sections 1 , 6, 7 , 12, 18, and 19
STAFF COMMENTS MARCH 17, 2005
Township 7 South, Range 12 East, Boise Meridian, Twin Falls County, Idaho and Sections 19
and 30, Township 6 South, Range 13 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 Tuana Gulch 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). Tuana
Gulch 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 Tuana Gulch for purchases of energy
will be allowed as prudently incurred expenses for ratemaking purposes.
STAFF ANALYSIS
The Tuana Gulch Project is one of four nearly identical projects with contracts now
pending before the Commission. All four projects 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 Tuana Gulch and finds that
it comports with the terms and conditions of Commission Order No. 29632 (V.s. Geothermal et.
a! v. Idaho Power) and avoided cost Order No. 29646. The contract is for a 20-year term and
contains the published non-Ievelized 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 18, 2005.
RES P ECTFULL Y submitted this
/7
~ay 0 f March 2005.
Scott D. Woodbury
Deputy Attorney General
i :umisc: comments/ipceO5. 9swrps
ST AFF COMMENTS MARCH 17, 2005
Attachment A
Case No. IPC-05-
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
TUANA GULCH WIND PARK LLC
1424 DODGE
HELENA MT 59601
SECRETARY
CERTIFICATE OF SERVICE