20060616Comments.pdf

CECELIA A. GASSNER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6977
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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 RIVERSIDE HYDROI, L.L.c.
CASE NO. IPC-O6-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through its Attorney of record
Cecelia A. Gassner, Deputy Attorney General, in response to the Notice of Application and Notice of
Modified Procedure in Order No. 30053 issued on May 26, 2006, submits the following comments.
BACKGROUND
On April 27, 2006, 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 Riverside Hydro I, LLc. (Riverside) dated
April 13 , 2006. Under the Agreement, Riverside Hydro I will sell and Idaho Power will purchase
electric energy generated by the Mora Drop small hydroelectric facility, located near Kuna, Idaho. The
nameplate rating of the hydro facility is 1.9 MW. Under normal and/or average conditions, the project
will not exceed 10 aMW on a monthly basis.
STAFF COMMENTS JUNE 16 2006
STAFF ANALYSIS
As represented, the Riverside Hydro I Project will be a qualified small power production
facility (QF) under the applicable provisions of the Public Utility Regulatory Policies Act of 1978
(PURPA). Riverside has selected May 15 , 2006 as the first energy date and July 1 , 2006 as the
scheduled operation date for this facility.
Based on its review, Staff believes that the Agreement between Riverside Hydro I 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. The Agreement is for a 20-year term and contains
the published non-Ievelized avoided cost rates set forth in Order No. 29646.
Section 24 of the Agreement provides that the Agreement will not become effective until the
Commission has approved all the Agreement's terms and conditions and declared that all payments
that Idaho Power makes to Riverside for purchases of energy will be allowed as prudently incurred
expenses for ratemaking purposes. The proposed effective date of the Agreement is April 13 , 2006.
STAFF RECOMMENDATION
Staff recommends approval of the Agreement with an effective date of April 13, 2006.
Respectfully submitted this /6..,L.. day of June 2006.
ceceli
Deputy Attorney General
Technical Staff: Rick Sterling
i :umisc:comments/ipceO6.13cgrps
STAFF COMMENTS JUNE 16 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF JUNE 2006
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-06-, 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
RIVERSIDE HYDRO I LLC
PO BOX 720
PARMA ID 83660
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SECRET
CERTIFICATE OF SERVICE