20200401Comments.pdf

STAFF COMMENTS 1 APRIL 1, 2020
MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655

Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR APPROVAL
OF THE SECOND AMENDMENT TO THE
ENERGY SALES AGREEMENT FOR THE
HAZELTON A HYDRO PROJECT

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CASE NO. IPC-E-20-07

COMMENTS OF THE
COMMISSION STAFF

STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of record,
Matt Hunter, Deputy Attorney General, submits the following comments.

BACKGROUND
On February 20, 2020, Idaho Power Company applied for approval of the second
amendment (“Amendment”) to its energy sales agreement (“ESA”) with North Side Energy
Company, Inc. (“Seller”). The ESA falls under the Public Utility Regulatory Policies Act of 1978
(“PURPA”) and is a contract for the sale and purchase of electric energy generated by the
Hazelton A hydro project—a PURPA qualifying facility (“QF”). The Amendment addresses
when the Seller must notify the Company in order to revise future monthly Estimated Net Energy
Amounts.
The Commission originally approved Idaho Power’s ESA with the Seller in 2011. Order
No. 32181. The Commission then approved a first amendment to the ESA in 2014. See Order
No. 33053.
RECEIVED
2020 April 1,PM12:51
IDAHO PUBLIC
UTILITIES COMMISSION

STAFF COMMENTS 2 APRIL 1, 2020
With this Application, Idaho Power asks the Commission to approve a second Amendment
to the ESA, which the parties agreed to on February 13, 2020.
The Amendment changes when the Seller must notify Idaho Power in order to revise future
monthly Estimated Net Energy Amounts. Currently, Section 6.2.3 of the ESA requires the Seller
to notify Idaho Power at least three months before the Seller revises a given month’s Estimated Net
Energy Amount. The proposed Amendment states that “[a]fter the Operation Date, the Seller must
revise any future monthly Estimated Net Energy Amounts by providing written notice no later than
5 PM Mountain Standard time on the 25th day of the month that is prior to the month to be revised.”
Application, Attachment 1. If the 25th day falls on a weekend or holiday, Idaho Power must receive
written notice no later than the last business day prior to the 25th day of the month.

STAFF ANALYSIS
Staff recommends approval of the proposed Amended Energy Sales Agreement between
Idaho Power and the Seller. Section 6.2.3 of the existing ESA will be replaced to allow the Seller
to adjust Estimated Net Energy Amounts (which are provided to Idaho Power to comply with
90/110 firmness requirements) with a five-day advanced notice instead of a three-month advanced
notification in the currently approved ESA.
The Commission has approved a five-day revision to monthly generation estimates in
previous cases, recognizing that Estimated Net Energy Amounts that are closer to the time of
delivery can improve the accuracy of input used by the Company for short-term operational
planning. See, e.g., Case Nos. IPC-E-19-01, IPC-E-19-03, IPC-E-19-04, IPC-E-19-07, and
IPC-E-19-12. With an Operation Date that occurred February 28, 1991, Staff believes a five-
day advanced notice for generation estimate adjustments is sufficient because the Company has
a well-established generation history for the QF.

STAFF RECOMMENDATION
Staff recommends the Commission approve the Amendment to the Energy Sales
Agreement for the Hazelton A hydro project, with all other terms and conditions to remain
unchanged.

STAFF COMMENTS 3 APRIL 1, 2020
Respectfully submitted this 1st day of April 2020.

________________________________
Matt Hunter
Deputy Attorney General

Technical Staff: Rachelle Farnsworth
Yao Yin

i:umisc/comments/ipce20.7mhyyrf comments
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 1st DAY OF APRIL 2020,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-20-07, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:

DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]

ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]

/s/ Reyna Quintero __
SECRETARY