20190723Comments.pdf

EDWARD J. JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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.
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.19.14
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on Idaho Power
Company's Application.
BACKGROUND
On April 4,20l9,Idaho Power Company ("Idaho Power" or "Company") filed an
Application seeking approval of a Power Purchase Agreement ("PPA") with Jackpot Holdings
LLC, ("Jackpot Solar") for energy generated by the Jackpot Solar Facility ("Facility"). Under
the proposed PPA, Idaho Power would purchase 120 megawatts ("MW") of energy with an
option to purchase an additional 100 MW of energy from the adjacent Franklin Solar Facility
("Option Facility"). The Facilities are between Twin Falls and the Nevada border.
The scheduled commercial operation date for the Facility is December I,2022 and
December I,2023 for the Option Facility. Application at 5. The Agreement is for a twenty-year
term and contains non-levelized, fixed pricing that escalates at 1.5o2 annually during the term of
the Agreement. Id. at 4. If the Company does not exercise its option on the additional 100 MW,
STAFF COMMENTS JULY 23,20191
pricing for the first year of the Agreement is $21 .75 per MW hour ("MWh"). If the Company
does exercise its option for the additional 100 MW, pricing for the first year of the Agreement is
$23.11 per MWh. Id. 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 REVIEW
Idaho Power needs additional time to complete supplemental economic modeling of the
Jackpot Solar PPA and respond to Staff Production Requests. This information was known on
July 16, 2019, but too late for the last Decision Meeting. Staff recommends the Commission
vacate the comment deadline in this case to allow these activities to be completed. The
Company has filed a letter supporting this approach and has committed to keeping the
Commission and Staff apprised of its progress. The Company and Staff are the only parties to
the case; there are no intervenors. Staff understands that the Company anticipates completing
the additional modeling by approximately mid-August. Staff recommends the Commission
establish a revised comment deadline after the Company files the supplemental modeling results.
STAFF RECOMMENDATIONS
Staff recommends the Commission vacate the comment deadline in this case and set a
revised comment deadline after the Company files the supplemental economic modeling results.
Respectfully submitted this Zjr>day of July 2019
Edward J
Deputy
(
General
Technical Staff: Stacey Donohue
i :umisc/comments/ipce I 9. I 4ejmerfsdtnc comments
2STAFF COMMENTS JULY 23,2019
CERTIFICATE OF SBRVICB
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF JULY 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-19-14, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
DONOVAN WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : dwalker@ idahopower. com
dockets@idahopower. com
MATT LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
CERTIFICATE OF SERVICE