20181004Comments.pdf

SEAN COSTELLO
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8743
IN THE MATTER OF THE APPLICATION OF )
rDAHO POWER COMPANY FOR APPROVAL )
OR REJECTION OF AN ENERGY SALES )
AGREEMENT WITH CLEAR SPRINGS FOODS, )
INC., FOR THE SALE AND PURCHASE OF )
ELECTRIC ENERGY FROM THE CLEAR )
SPRINGS TROUT HYDRO PROJECT )
iiiiS0tjT -t+ Pl'l l:51
CASE NO. IPC-E-18-11
i?EC I IVE i]
Street Address for Express Mail
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission comments as follows on Idaho Power
Company' s Application.
BACKGROUND
On August 16,2018, Idaho Power Company applied to the Commission for an Order
approving or rejecting its Energy Sales Agreement (ESA) with Clear Springs Foods, Inc. (Clear
Springs Hydro) for a 564 kilowatt (kW) energy facility located near the city of Buhl, Idaho. The
facility is a qualifying facility (QF) under the Public Utility Regulatory Policies Act.
Under the proposed ESA, Clear Springs Hydro would sell to Idaho Power electric energy
generated by the Clear Springs Trout Hydro Project. The parties have an existing ESA for the
facility that expires on October 31, 2018.
Clear Springs Hydro elected for the ESA to have a 2)-year term using the non-levelized
rates for non-seasonal hydro projects smaller than 10 average megawatts. The ESA uses the
rates established by the Commission in Order No. 34062 dated May 16, 2018. 1d Because the
1STAFF COMMENTS OCTOBER 4,2018
',tcc. l^!l,llu,Ui-vll
COMMENTS OF THE
COMMISSION STAFF
ESA is a replacement contract and is currently receiving capacity payments, its rates contain
capacity payments for the entire term, with no sufficiency period (Commission Order No.
3287r).
Idaho Power asks the Commission to accept or reject the ESA and, if the ESA is
accepted, to declare that Idaho Power's payments under the ESA will be allowed as prudently
incurred expenses for ratemaking purposes.
STAFF REVIEW
Staff has reviewed the proposed rates and confirms they are correct, and that the
proposed ESA is consistent with Commission orders.
RECOMMENDATIONS
Staff recommends that the Commission approve the ESA. Staff also recommends the
Commission declare that Idaho Power's payments to Clear Springs Foods for purchase of energy
from the Clear Springs Trout Hydro Project will be allowed as prudently incurred expenses
under the ESA for ratemaking purposes.
Respectfully submitted this '1+! day of October 2018
$tU / L,-
(', Sean Costello
Deputy Attorney General
Technical Staff: Yao Yin
Rachelle Farnsworth
Umisc/Comments/ipcel 8. I lscyyrf comments
2STAFF COMMENTS OCTOBER 4,2018
CERTIFICATB OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF OCTOBER 2018,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-I8-lI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
-), fle^-ry
CERTIFICATE OF SERVICE