20141203American Falls Solar Comments.pdf

Wlliams Bradb,rry
ATTORNEYSAT I-AW
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December 3,2014
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
Re: IPC-E-14-32 through IPC-E-14-36
Dear Ms. Jewell:
Please find enclosed an original and seven copies of the Initial Comments of Murphy
Flat Power,LLC, Simco Solar, LLC, American Falls Solar, LLC, American Falls Solar II,
LLC, and Orchard Ranch Solar, LLC in Support of Approval of an Energy Sales Agreement
with Idatro Power Company for filing in the above referenced cases.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerelv-
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Ronald L. Williams
RLWjr
Enclosures
1015 !f. Hays Street - Boise, ID 83702
Phone: [phone] - Fax:. [phone] - www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
l0l5 W. Hays St.
Boise,lD 83702
Telephone : [phone]
Fax: [phone]
ron@williamsbradburv. com
Attorneyfor Murphy Flat Power, LLC, Simco Solar, LLC, Americon Falls Solor, LLC,
American Falls Solar II, LLC, and Orchard Ranch Solar, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPAI\"Y FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
MURPIIY FLAT POWER, LLC F'OR THE
SALE AI\ID PURCHASE OF'ELECTRIC
ENERGY.
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPAIYY FOR
APPROVAL OR REJECTION OF ATI
ENERGY SALES AGREEMENT WITH
SIMCO SOLAR, LLC FOR THE SALE
AND PURCHASE OF ELECTRIC
ENERGY.
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF'AN
ENERGY SALES AGREEMENT WITH
AMERICAN FALLS SOLAR, LLC FOR
THE SALE AND PURCHASE OF
ELECTRIC ENERGY.
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AI\
ENERGY SALES AGREEMENT WITH
AMERICAN FALLS SOLAR II, LLC FOR
THE SALE AND PURCHASE OF
ELECTRIC ENERGY.
) CASE NO. rPC-E-14-32
)) INITIAL COMMENTS OF MURPITY
) FLAT POWE& LLC IN SUPPORT Or'
) APPROVAL OF Ar\ ENERGY SALES
) AGREEMENT WrTH rDAHO POWER
) coMPAr\Y
) cAsE NO. TPC-E-14-33
)) INITIAL COMMENTS OF SIMCO
) SoLAR,LLC IN SUPPORT OF
) APPROVAL OF AI\i ENERGY SALES
) AGREEMENT WrTH rDAHO POWER
) C0MPANY
) cAsE NO. TPC-E-14-34
)) INITIAL COMMENTS OF'
) AMERICAN FALLS SOLAR, LLC IN
) suPPoRT OF APPROVAL OF Ar[
) ENERGY SALES AGREEMENT
) wrTH IDAHO POWER COMPATTY
) CASE NO. TPC-E-14-35
)) INITIAL COMMENTS OF
) AMERICAI\ F'ALLS SOLAR II, LLC
) IN SUPPORT OF APPROVAL OF Ar\
) ENERGYSALESAGREEMENT
) wrTH rDAHO POWER COMPAT\-Y
Comments of Solar Projects In Support of Approval of an Energy Sales Agreement with Idaho Power - I
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
ORCHARD RANCH SOLAR, LLC X'OR
THE SALE AI\D PURCHASE OF
ELECTRIC ENERGY.
) CASE NO. TPC-E-14-36
)) INITIAL COMMENTS OF ORCHARI)
) RANCH SOLAR, LLC IN SUPPORT
) oF APPROVAL OF AN ENERGY
) SALES AGREEMENT WITH IDAHO
) POWER COMPANY
In response to the Notices of Application and Notices of Modified Procedure issued in
Order Numbers 33168 through 33172 in the above referenced dockets, and pursuant to Rule 203
of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), Murphy
Flat Power,LLC, Simco Solar, LLC, American Falls Solar, LLC, American Falls Solar II, LLC,
and Orchard Ranch Solar, LLC (collectively, the "Solar Projects") by and through their attomey
of record, Ronald L. Williams, Williams Bradbury, P.C., hereby submit the following Initial
Comments.
1. On November 20,20l4,Idaho Power Company ("Idaho Power" or the
"Company") filed Initial Comments in the above five dockets stating that each of the Solar
Projects had requested the Company re-run the pricing contained in the Energy Sales
Agreements ("ESAs") for the Solar Projects, to incorporate the two pricing changes proposed by
Idaho PUC Staff in Case No. IPC-E-14-19 (Grand View Solar) and Case No. IPC-E-14-20
(Boise City Solar)r. Attached to the Company's Initial Comments is a revised Appendix E
(*Solor Facility Energ,t Prices and Integration Charges") for each of the Solar Projects that
incorporated the same Staff adjustments recommended in Grand View Solar and Boise City
Solar.
I In the Grand View Solar and Boise City Solar cases Staffrecommended two modifications to the ESA pricing
related to assumptions about fuel forecasts and displaceable resources of the Company.
Comments of Solar Projects In Support of Approval of an Energy Sales Agreement with Idaho Power - 2
2. Each of the Solar Projects has notified Idaho Power that it agrees to adopt the
Replacement Appendix E attached to Idaho Power's Initial Comments, which Appendix E
incorporates Staff s recommended changes in the Company's pricing model. Each of the Solar
Projects consents to the Replacement Appendix E attached to the Initial Comments of the
Company replacing the existing Appendix A, and to the Replacement Appendix E becoming part
of the executed ESA.
3. Wherefore, the Solar Projects request that the Commission approve the ESA's
entered into between Idaho Power and Murphy Flat Power, LLC, Simco Solar, LLC, American
Falls Solar,LLC, American Falls Solar II, LLC, and Orchard Ranch Solar, LLC.
Respectfully submitted this j td
day of December, zol4.
,r, ,R
"'4 "J,r','*Ronald L. Williams
Attorneyfor the Solar Projects
Comments of Solar Projects In Support of Approval of an Energy Sales Agreement with Idaho Power - 3
CERTIFICATE OF SERVICE
I hereby certify that on tt " 3L( aay of December, 2Ol4,I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Sffeet
P.O. Box 83720
Boise,ID 83720-0074
jj ewell@puc. state.id.us
Donovan E. Walker
Randy C. Allphin
Regulatory Dockets
Idaho Power Company
l22l West Idaho Street
P.O. Box 70
Boise,ID 83707
dwalker@ idahopower. com
rallphin@ idahopower. com
dockets@ idahopower. com
Kristine A. Sasser
Deputy attorney general
Idaho Public Utilities Commission
472W. Washington St.
PO Box 83720
Boise, lD 83720-0074
kris. [e-mail]. gov
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Ronald L. Williams
Attorneyfor the Solar Projects
Comments of Solar Projects In Support of Approval of an Energy Sales Agreement with Idaho Power - 4