20050826Comments.pdf

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SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
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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 TWIN FALLS
ENERGY COMPANY, INC.
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 submits the following
comments in response to the Notice of Application, Notice of Modified Procedure and Notice of
Comment/Protest Deadline issued on August 3, 2005.
BACKGROUND
On July 6, 2005 , Idaho Power Company (Idaho Power; Company) filed an Application
with the Idaho Public Utilities Commission (Commission) requesting approval of a 20-year Firm
Energy Sales Agreement (Agreement) between Idaho Power and Twin Falls Energy Company,
Inc. (Twin Falls) dated June 27, 2005. Under the Agreement, Twin Falls will sell and Idaho
Power will purchase electric energy generated by the Low Line Midway Hydroelectric Project
located approximately one mile downstream from the point of the Low Line Canal origin, in an
STAFF COMMENTS AUGUST 26, 2005
area more particularly described as the NW 1/4, of the NW 1/4 of Section 11 , Township 11 S
Range 10 E, Boise Meridian, Twin Falls County, Idaho. The nameplate rating of the hydro
project is 2.5 MW.
STAFF ANALYSIS
The Twin Falls 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). Twin
Falls has selected March 10, 2007 as the first energy date and April 1 , 2007 as the scheduled
operation date.
Based on its review, Staff believes that the Agreement between Twin Falls and Idaho
Power comports with the terms and conditions of Commission Order No. 29632 (Us.
Geothermal et al v. Idaho Power) and avoided cost Order No. 29646. Twin Falls has elected to
receive the levelized published avoided cost rates set forth in Order No. 29646. This Agreement
is the first one in several years containing levelized rates. The Company represents, and Staff s
review confirms, that the Agreement contains the various security requirements required by the
Commission for levelized agreements.
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 Twin Falls for purchases of energy will be allowed as
prudently incurred expenses for ratemaking purposes. The proposed effective date of the
Agreement is June 27, 2005.
RECOMMENDATION
Staff recommends approval of the Agreement with an effective date of June 27, 2005.
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Respectfully submitted this day of August 2005.
Scott D. Woodbury
Deputy Attorney General
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STAFF COMMENTS AUGUST 26, 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF AUGUST 2005
SERVED THE FOREGOING COMMENTS OF THE COMMISSION ST AFF, 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
VINCE ALBERDI
TWIN FALLS ENERGY CO
PO BOX 326
TWIN FALLS ID 83303
Jo 0/Jo-A
SECRET AR
CERTIFICATE OF SERVICE