20200306Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KIELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COM1VtrSSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:JOHN R. HAMMOND JR.
DEPUTY ATTORNEY GENERAL
DATE: MARCH 5,2020
STJBJECT:IDAHO POWER COMPANY'S APPLICATION FOR APPROVAL OR
REJECTION OF AN ENERGY SALES AGREEMENT WITH COLLEGE
OF SOUTHERN IDAHO FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE PRISTINE SPRINGS #3 HYDRO
PROJECT; CASE NO. IPC-E-20-05.
On February l4,2020,Idaho Power Company ("Idaho Power" or "Company") applied
for Commission approval of its proposed Energy Sales Agreement ("ESA") with the College of
Southern Idaho ("CSI" or "Seller") for the energy generated by the Pristine Springs #3 hydro
project ("Facility"). The Facility is a qualifying facility ("QF ') under the Public Utility Regulatory
Policies Act of 1978 ("PURPA").
THE APPLICATION
The Facility operated by CSI is a 200 kilowatt ("kW") nameplate capacity hydroelectric
facility near Twin Falls, Idaho. Application at 4. The Facility currently delivers energy to the
Company under a PURPA energy sales agreement dated March 26,2015. Id. The existing energy
sales agreement expires on May 1,2020. Id. The Company and CSI intend the proposed ESA to
replace the expiring energy sales agreement. Id. The Company states the proposed ESA complies
with Commission orders regarding this type of agreement. Id. at 2. The Company asks the
Commission to process the Application by Modified Procedure before the existing energy sales
agreement expires. Id. at 6.
In the proposed ESA, CSI has contracted for nonlevelized, non-seasonal hydro
published avoided cost rates as set by the Commission in Order No. 34350 for a 20-year term. Id.
at 4. Idaho Power states that the output from the Facility has been included in Idaho Power's
DECISION MEMORANDUM 1
capacity planning, and the proposed ESA contains capacity payments for the entire term of the
Agreement, with no sufficiency period. Id. at 3. The Company requests that its Application be
processed by Modified Procedure. Id. at 6.
STAFF RECOMMENDATION
Staff recommends the Commission issue a Notice of Application and Notice of
Modified Procedure. Staff recommends the Notice of Application and Notice of Modified
Procedure provide for a twenty-one (21) day written comment period for itself and any other
interested parties, with a seven (7) day reply comment period for the Company to follow.
COMIVtrSSION DECISION
Does the Commission wish to issue a Notice of Application and Notice of Modified
Procedure that establishes a twenty-one (2I) day written comment period for Staff and any other
interested parties followed by a seven (7) day reply comment period for the Company?
Jr.
Attomey General
I:Ureal\ELECIRICUFC-E-20-O5UPCE2005_dec memo_jrh.ds
2DECISION MEMORANDUM