20180220Comments.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. t0t77
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH DOUG AND NANCY
HULL FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE CURRY
CATTLE COMPANY HYDRO PROJECT
RECEIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-59T8
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.18.O1
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Camille Christen, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 33977 on January 30, 2018,
in Case No. IPC-E-18-01, submits the following comments.
BACKGROUND
On January 10,2018, Idaho Power Company applied to the Commission for an Order
approving or rejecting its Energy Sales Agreement (ESA) with Doug and Nancy Hull (Hull).
Under the proposed ESA, Hull would sell and Idaho Power would purchase electric energy
generated by the Curry Cattle Company hydro project located near Twin Falls, Idaho.
Application at 1. The Curry Cattle Company hydro project is a 250 kilowatt (kW) "qualiffing
facility" (QF) under the Public Utility Regulatory Policies Act (PURP 1t^). Id. at 4.
The parties have an existing ESA for the facility that expires on June 16, 2018; the
proposed ESA is a replacement contract with a new term and updated published avoided cost
ISTAFF COMMENTS FEBRUARY 2O,2OI8
rates. Id. at 2. Hull elected for the ESA to have a l5-year term with non-levelized rates for
seasonal hydro projects smaller than 10 average megawatts. Id. at 4. The ESA uses the rates
established by the Commission in Order No. 33773 dated June 1,2017. 1d. Because the ESA is
a replacement contract, its rates contain capacity payments for the entire term. Id. at 3. The ESA
also provides that all applicable interconnection charges and monthly operational or maintenance
charges under Schedule 72 will be assessed to Hull. Id. at 5.
STAFF REVIEW
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.
STAFF 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 Doug and Nancy Hull for
purchase of energy from the Curry Cattle hydro project will be allowed as prudently incurred
expenses for ratemaking purposes.
Respectfully submitted this L\n day of February 2018
Camille Christen
Deputy Attorney General
Technical Staff: Rachelle Farnsworth
Yao Yin
i :umisc/comments/ipce I 8. I ccrfoy comments
2STAFF COMMENTS FEBRUARY 2O,2OI8
U*ilJ^[Ld"^
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF FEBRUARY 2018,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-I8-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail : dwalker@idahopower. com
dockets@idahopower. com
DOUG & NANCY HULL
CURRY CATTLE CO HYDRO
PO BOX2424
TWIN FALLS ID 83303
E-mail: nhl [e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE