20190524Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
DATE: MAY 23,2019
SUBJECT:IN THE MATTER OF THE 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; CASE NO.
IPC-E-19-14.
On April 4,2019,ldaho Power Company ("ldaho Power" or "Company") filed an
Application seeking approval of a Power Purchase Agreement ("PPA" or "Agreement") with
Jackpot Holdings LLC, ("Jackpot Solar") for energy generated by the Jackpot Solar Facility
("Facility").
On April 25, 2019, the Commission issued a Notice of Application and Notice of
Intervention Deadline. Order No. 34321. No parties intervened.
Following the intervention deadline, the Commission issued a Notice of Parties. Staff
and the Company conferred informally regarding the schedule and processing of the case and
reached agreement on those matters.
THE APPLICATION
The Facility is between Twin Falls and the Nevada border. Under the PPA, Idaho
Power will purchase 120 megawatts ("MW") of energy from the Facility with an option to
purchase an additional 100 MW of energy from the adjacent Franklin Solar Facility ("Option
Facility"). Application at 1-2. The scheduled commercial operation date for the Facility is
December 1,2022, and December 1,2023, forthe Option Facility. Id. at5. The Agreement is
for a twenty year term, contains non-levelized fixed pricing that escalates at. l.5oh annually
during the term of the Agreement . Id. at 4. If the Company does not exercise its option on the
DECISION MEMORANDUM I
additional 100 MW, pricing for the first year of the Agreement is $21.75 per MW hour
("MWh"). If the Company does exercise its option on the additional 100 MW, pricing for the
first year of the Agreement is $23.11 per MWh. 1d The pricing of the PPA is dependent upon
the developer being able to maximize the value of the federal Investment Tax Credit, which
declines at the end of December 2019. Id. at 10. Therefore, the Company requests an
expeditious proceeding resulting in a Commission Order by no later than December 2019.
STAFF RECOMMENDATION
Staff recommends the Commission process the case by modified procedure. Staff
recommends the Commission set a July 23,2019 comment deadline and an August 6,2019 reply
comment deadline.
COMMISSION DECISION
Does the Commission wish to process the case by modified procedure and set a
comment deadline of July 23,2019 and a reply comment deadline of August 6,2019?
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2DECISION MEMORANDUM