20191126Boise City Comments.pdf

\,,E0
n..,25 LiJt,
JAYME B. SULLIVAN
BOISE CITY ATTORNEY
Attomey for Boise City
IN THE MATTER OF APPLICATION OF
IDAHO POWER FOR APPROVAL OF A
POWER PURCHASE AGREEMENT WITH
JACKPOT HOLDINGS, LLC, FOR THE SALE
AND PURCHASE OF UP TO 220
MEGAWATTS OF RENEWABLE SOLAR
GENERATION
- ,r...f..,,]
BEFORE TIIE
IDAHO PUBLIC UTILITIES COMIVINSION
Case No. IPC-E-19-14
CITY OF BOISE CITY'S
COMI\TENTS IN RESPONSE
TO CONTMENTS OF IDAHO
POWER REGARDINC PPA
ELECTIONS
CITY OF BOISE CITY'S COMMENTS IN RESPONSE TO COMMENTS OF IDAHO POWER REGARDING
PPA ELECTIONS - 1
ABIGAIL R. GERMAINE (lSB No.9231)
Deputy City Attorney
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email : [e-mail]
COMES NOW, the city of Boise City, herein referred to as "Boise City'' and pursuant to
Rule 203 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA 31.01.01.203)
and, pursuant to that Notice ofComment Deadlines, Order No. 34479, filed on November 7, 2019,
hereby submits these written comments and states as follows:
l. Boise City is generally supportive of Idaho Power Company's Application for
Approval of a Power Purchase Agreement ("PPA" or "Agreement") with Jackpot Holdings LLC,
("Jackpot Solar") for solar energy generated by the Jackpot Solar Facility.
2. Boise City understands Idaho Power Company ("ldaho Power") notified the Idaho
Public Utilities Commission ("Commission") that pursuant to the PPA, Idaho Power is electing to
decline its option to purchase an additional 100 MW output from the Option Facility, otherwise
known as Franklin Solar Project.
3. Considering the renewable nature ofthe resource, the price point, and the location,
Boise City believes Idaho Power should continue to study the purchase ofthe additional 100 MW
from the Franklin Solar Project.
4. Idaho Power's Comments state, "[a]lthough the preliminary supplemental analysis
regarding the additional 100 MW fiom Franklin Solar in the IRP shows some incremental benefit
to customers beyond inclusion ofthe 120 MW from Jackpot Solar, several factors contribute to
the Company's decision to not puchase the additional 100 MW of solar generation." Boise City
agrees that Franklin Solar Project appears to be a benefit to customers.
5. ldaho Power lists several reasons for not electing to purchase the additional 100
MW fiom Franklin Solar Project. Among them is the lack of a claim of "additionality'' among
customers interested in purchasing the renewable power from Franklin Solar Project.
6. Boise City would like to clarify that as it relates to the issue of"additionality" Boise
City supports projects like Franklin Solar Project which fall in line with the notion of "material
impact", the gauge Boise City believes is more important than additionality to measure the benefit
of the resource to the environment and the system. Boise City would view the Franklin Solar
Project as a renewable resource providing a material impact.
CITY OF BOISE CITY'S COMMENTS IN RESPONSE TO COMMENTS OF IDAHO POWER REGARDING
PPA EI-ECTIONS . 2
7. ln addition to Boise City recently adopting the goal of 100% clean electricity for
the City ofBoise by 2035,Idaho Power has also announced its goal of 100% clean energyby 2045.
Achieving these goals will be reliant on bringing on additional clean and renewable resources. The
ability to bring on 100 MW of renewable energy at such a low price to the customers seems to
warrant further studies to address the technical challenges in bringing on such a project to help
meet these goals.
8. Boise City requests that the Commission require Idaho Power to continue studying
the ability to purchase an additional 100 MW from the Franklin Solar Project based on the fact
that the price is so much lower than the current embedded costs for many of Idaho Power's other
resources which are not renewable. Requiring ldaho Power to continue studlng the purchase of
this low-cost resource appears to be in line with the requirement to provide the rate paying
customer the lowest cost resource available.
DATED this 2L day of November 2019.
Germainc
Depu City Attomey
CITY OF BOISE CITY'S COMMENTS IN RESPONSE TO COMMENTS OF IDAHO POWER REGARDING
PPA ELECTIONS - 3
I hereby ceftiry that I have on this 16 day of November 2019, served the foregoing
documents on all parties ofcounsel as follows:
Donovan Walker
Matt Larkin
Idaho Power Company
PO Box 70
Boise, ID 83707
tlwal kerldridahopowor. corn
tr
tr
ala
o
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other:
dockets(ati dahopo wcr.co11l
mlarkin(ajidahonorver.com
Edward Jewell
Deputy Attomey General
Idaho Public Utilities Commission
l33l I W. Chinden Blvd Bldg 8 Ste 201-A
Boise, ID 83714
edr.vard.icrvcll(arnuc. idaho. e,ov
tr
otr,d
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other:tr
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
l33l I W. Chinden Blvd Bldg 8 Ste 201-A
Boise, ID 83714
d iane. holt(arouc, idaho. sov
?
tr
tr
o
U.S. Mail
Personal Delivery
Facsimile
Electronic Means w/ Consent
Other:
Abi
City Attorncy
CITY OF BOISE CITY'S COMMENTS IN RESPONSE TO COMMENTS OF IDAHO POWER REGARDING
PPA ELECTIONS - 4
CERTIFICATE OF SERVICE