20191101Decision Memo.pdf

DECISION MEMORANDUM
TO:COM NTISSI ON[,R KJE LLAN DE R
CIONII\{I SSIOn- E R RAPER
COMN{ISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FII,ONI:EDWARD JEWELL
DEPTITY ATToRNf Y GENERAL
DATE: OCT0BER3I,20l9
SUB,IECT: lN THE IIIATTER OP THE APPLICATION OF IDAIIO POWER FOR
APPROVAL OF A POWER PTIRCHASE ACRF],F],NIE,NT WITH.IACKPOT HOLDINGS,
LLC, FOR TIIE SALE AND PTIRCHASE OF T]P TO 220 MECAWATTS OF
REN*EWABLE SOLAR GENERATION; CASE N(). IPC-E-I9-l,l
On April 4,2019,ldaho Porver Company ("Ciompany") filed an Application seeking
approval of a Porver Purchase Agreement ('PPA") with Jackpot Holdings LLC for energy
generated by the Jackpot Solar Facilitl' ("Facility"). lJnder the proposcd PPA, the Company
u,ould purchase 120 megarvatts C'MW') of energl'rvith an option to purchase an additional 100
MW ofenergv from the adjacent Franklin Solar Facility ("Option Facility"). The Facility and
the Option Facility are betw'een Twin Falls and the Ncvada border.
On April 25,2019, the Commission issued a Notice of Application and Notice ol
lnten'ention Deadline. Order No. 3432 1 . No parties inten ened.
On June 5,2019. the Commission issued a Notice of Modified Procedure and sct a
comment deadline ol'.luly 23, 2019. and a reply comment deadline of August 6. 2019. Order No.
343 53.
On July 8. 2019, the Company responded to a Staff production request by stating that
it needed more time to complete the requested economic anall'sis. IDAHO POWER
coMPANY',S RESPONSE TO COMMISSION STAFF REQUEST NO. 25.
On July 19,2019. the Company submitted a letter to the Commission indicating that
the Company supported an adjustment to the commenl deadline because the Company was not
able to provide the requested analysis u-ithin the original comment pcriod.
DECISION MEMORANDTIM
On Jr.rly 23,2019, Staff filed comments recommending the Commission vacate the
commcnt deadline in this case and set a revised comment deadlinc after the Company filed the
supplemental econonric modeling analysis.
On August 5, 201 9. the Commission issued a Notice of Suspended Comment Period.
which ordered "that thc prcviously established comment deadlines are vacated until the
Cornpany files additional analysis and the Commission establishcs new conrment deadlines."
Order No. 34399 at 2. The Commission also notified the public that "the Company expects the
additional analysis to take until the end ofAugust 2019." 1d
On October 23.2019, the Company submitted Comments of Idaho Pow'er Company
Regarding PPA Elections ("Comments Regarding PPA Elections"). In its Comments Rcgarding
PPA Elections, the Company notified the Commission that pursuant to tenns of the PPA thc
Company elected to: I ) decline its option to purchase the I 00 MW outpul from the Option
Facility, and 2) exercise its right, through a non-regulated IDACORP affiliate of ldaho Power
Conrpany. to negotiate for ownership ol the Facility.
The pricing of the Net Output under thc PPA, which contains prices set at
$21.75lMWh escalated at 1.5% for 20 years. assunres that the orvncr of the Facility will be able
to secure the 30% federal Investment Tax Credit, which requires significant action prior tu
Dccember 31,2019. See Id. al6.
The Comments Regarding PPA Elections state that thc Company "is completing and
providing to Stafl through discovery updated portlblio analysis from its 2019 Integrated
Resource Plan ("lRP") relating to the inclusion of Jackpot Solar (120 MW) and Franklin Solar
( 100 MW) as generation resourccs in the IRP." 1d at 3.
STAFF RECOMMENDATION
Statf recommends the Commission set a conment deadline of November 26.2019,
and a reply comment deadline ofDecember 3, 2019.
DEC IS ION MI]MOILA,N DI. J N,I 2
COMMISSION DECISION
Does the Commission wish to set a comment deadline of November 26. 2019. and a
reply comment deadline of December 3,2019?
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.,DLCISION MEMORANDUM