20151013Comments.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
TDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
rN THE MATTER OF IDAHO POWER )
CoMPANY'S APPLTCATION TO APPROVE OR )
REJECT ITS ENERGY SALES AGREEMENT )
wrTH NORTH GOODING MAIN HYDRO LLC )
FORTHE SALE AND PURCHASE OF )
ftfis$fivfr tl
?0l5OCI t3 pH tr28
und$ffi'.&Tf i$*,0*
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E-15-24
COMMENTS OF THE
COMMISSION STAF'F
ELECTRIC ENERGY.
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Daphne Huang, Deputy Attorney General, and responds to the Notice of
Application and Notice of Modified Procedure issued on September 22,2015. The Staff submits
the following comments in this case.
BACKGROUND
On September 8, 2015,Idaho Power Company filed an Application asking the
Commission to accept or reject its Energy Sales Agreement (ESA) with North Gooding Main
Hydro LLC. The ESA is for the sale and purchase of electric energy generated by the North
Gooding Main Hydro Project, a "qualifuing facility" as defined under the Public Utility
Regulatory Policies Act (PURPA), located near Gooding, Idaho.
On July 29,20l5,Idaho Power entered into its ESA with North Gooding - subject to this
Commission's approval - pursuant to the terms and conditions of various Commission Orders and
STAFF COMMENTS ocToBER 13,2015
PURPA. Application at 3. Under PURPA, electric utilities such as Idaho Power must purchase
electric energy from qualifying facilities (QFs) at rates approved by this Commission. 16 U.S.C. $
824a-3; Idaho Power Company v. Idaho PUC, 155 Idaho 780,789,316 P.3d 1278, 1287 (2013),
citing FERC v. Mississippi,456U.S.742,75l (1982). The purchase or "avoided cost" rate must
be 'Just and reasonable to the electric consumers . . . and in the public interest" and "shall not
discriminate against [QFs]." 16 U.S.C. $ 82aa-3(b); l8 C.F.R. 5 292.304.
North Gooding's facility is a seasonal hydro project. Application at 3. Under the terms of
the ESA, North Gooding elected to contract with Idaho Power for a 20-year term using the
levelized published avoided cost ratesl as currently established by Commission Order No. 33305
for energy deliveries less than 10 average megawatts (aMW). Id, The nameplate rating of North
Gooding's facility is 1.3 megawatts (MW). Id. at4.
North Gooding has selected April 1,2017, as the Scheduled Operation Date. Id. The ESA
contains various requirements that North Gooding must satisfy in order for Idaho Power to accept
energy deliveries from the facility. Id. Idaho Power will monitor all ongoing requirements
through the full term of the ESA. 1d
Under the ESA, all interconnection charges and monthly operational or maintenance
charges under Schedule 72will be assessed to North Gooding. Id. Before the facility will deliver
any energy to Idaho Power, all requirements of the Schedule 72 Generator Interconnection
Agreement (GIA) must be complete, and the facility must be designated as a network resource
(DNR) to serve Idaho Power's retail load on its system. Id. at 4-5. In its Application, Idaho
Power states that a GIA is expected to be signed by May 1,2016. Id. at 5.
By its own terms, the ESA will not become effective until the Commission has approved
all of its terms and conditions and declared that all payments made by Idaho Power to North
Gooding for purchases of energy will be allowed as prudently incurred expenses for ratemaking
purposes. 1d
STAFF ANALYSIS
Staff reviewed Idaho Power's original Application and discovered a clerical error of the all
hours energy price for Season 2. On September 15, Idaho Power filed a replacement page
I The Commission uses the Surrogate Avoided Resource (SAR) methodology to calculate and publish rates for QFs
with a design capacity up to a prescribed eligibility cap. See Order No. 32697 at 7-8. For QFs using non-wind, non-
solar resource-types - such as hydro - the published rate eligibility cap is l0 average megawatts (aMW). 1d
STAFF COMMENTS ocroBER 13,2015
containing a correct rate for the all hours energy price for Season 2. Staff has reviewed the
proposed rates and confirms they are correct. All other terms and conditions contained in the
proposed Agreement are consistent with prior Commission orders.
RECOMMENDATIONS
Staff recommends that the Commission approve all of the Agreement's terms and
conditions and declare that all payments made by Idaho Power to North Gooding for purchase of
energy will be allowed as prudently incurred expenses for ratemaking purposes.
Respectfully submitted this I 3 *day of October 2015.
Dap ang
Deputy ttorney General
Technical Staff: Yao Yin
i : umisc:comments/ipce I 5.24djhyy comments
STAFF COMMENTS ocroBER 13,2015
CERTIFICATE OF SER\ICE
I HEREBY CERTIFY THAT I HAVE THIS l3th DAY OF OCTOBER 2015,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF IN
CASE NO. IPC-E.15.24, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
dockets@ idahopower. com
TED SORENSON PE
N GOODING MAIN HYDRO LLC
5203 SOUTH l ITH EAST
IDAHO FALLS ID 83404
RANDY ALLPHIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
CERTIFICATE OF SERVICE