20140717Northside Comments.pdf

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luJy 17,2014
Marsha H. Smith
Paul Kjellander
Mack A. Redford
Idaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
47 2 W est Washington Street
Boise, lD 83702
RE: Comments regarding Case No. IPC-E-14-07, Order No. 33056
Dear Commissioners SmitlU Kjellander, and Redford,
As you are aware the North Side Energy Company (NSEC, a wholly owned subsidiary ofNorth
Side Canal Company, Ltd.) and Idaho Power Company have negotiated a PURPA Seasonal
Hydro Energy Sales Agreement for the Head of U hydroelectric project and submitted it to the
Idaho Public Utilities Commission (IPUC) for review and approval. IPUC staffhave reviewed
the agreement and issued their comments on July I lm that supported all terms in the agreement
with the exception of the time period allowed for submission of energy production estimates to
Idaho Power Company. Staffdid, however, recognize that the justifications presented by Idaho
Power have merit.
NSEC supports Idaho Power's position to modiir the schedule for submission of energy
estimates by the energy producer to Idaho Power from a quarterly schedule to a monthly
schedule as described in the signed agreement. NSEC believes this to be a better method for the
following reasons:
1. Snow pack and its resulting water supply for irrigation are very seldom known and
quantifiable 3-6 months in advance. This past water year is a good example, when in
January all of us in the inigation water industry were concerned that adequate snowpack
may not be available for irrigation. In February, some large storms passed through the
Teton Mountains and greatly increased the snowpack, improving the water outlook. By
April and May, flood control operations on the Snake River system were being discussed
with the possibility of having to release water from reservoirs to make space for the
runoff During June when the peak runoffoccurred, weather patterns were warm and dry
causing irrigation demands to increase to the point that no additional reservoir space wzm
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needed to be evacuated from the reservoirs to accommodate the runoffwaters. This past
spring serves as a gteat example as to how difficult it can be to forecast irrigation supply,
irrigation demand, and ultimately energy production 3-6 months in advance of actual
energy production.
2. NSEC understands that there has been confusion in the past and issues involved with
Idaho Power trying to obtain accurate estimates for energy planning from independent
energy producers. NSEC believes that the process described in the agreement between
NSEC and Idaho Power Company would allow for more accurate estimates of energy
production to be provided by NSEC and therefore enable more accurate energy planning
activities by Idaho Power.
For the reasons listed above, NSEC respectfully requests that the PUC approve the Seasonal
Hydro Energy Sales Agreement for the Head of U Hydroelectric project in its present form.
Sincerely, /zb4.%*{
Alan W. Hansten,
Manager,
North Side Energy Company and
North Side Canal Company