20200520Comments.pdf

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i' ,' ig Pli 2: 08EDWARD J. JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
Steet Address for Express Mail:
1133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPAI\Y'S APPLICATION FOR
APPROVAL OF THE FIRST AMENDMENT
TO THE BLIND CAI\ryON HYDRO
PROJECT
CASE NO. IPC.E.2O.18
COMMENTS OF THE
COMMISSION STAFF
The Staffof the ldaho Public Utilities Commission comments as follows on Idaho Power
Company's Application.
BACKGROT]I\D
On April 3,2020,ldaho Power Company ("Idaho Power" or "Company") filed an
Application with the Commission requesting approval of an amendment to its Energy Sales
Agreement with the Blind Canyon hydro project ("Blind Canyon"). Blind Canyon is a quali$ing
facility under the Public Utility Regulatory Policies Act of 1978. The Amendment addresses
when the Seller must notiff the Company in order to revise future monthly Estimated Net Energy
Amounts.
The Commission approved Idaho Power's ESA with Blind Canyon in 2014. Order
No. 33191. Idaho Power asks the Commission to approve the Amendment to the ESA, which the
parties agreed to on March 26,2020.
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ISTAFF COMMENTS MAY 20,2020
The Amendment changes when Blind Canyon must notiff Idaho Power in order to revise
future monthly Estimated Net Energy Amounts. Currently, Section 6.2.3 of the ESA requires
Blind Canyon to noti$ Idaho Power at least one month before the Seller revises a given month's
Estimated Net Energy Amount. The 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 25ft day of the month that is prior to the month
to be revised." Application at 2-3, Att.l. If the 25h day falls on a weekend or holiday, tdaho
Power must receive written notice by the last business day prior to the 25h day of the month.
STAFF ANALYSIS
Staff recommends approval of the proposed Amended Energy Sales Agreement between
Idatro Power and Blind Canyon. 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 one 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-I9-01, IPC-E-19-03, IPC-E-19-04,IPC-E-19-07, and
IPC-E-19-12. With an original operation date of December 14,1994, Staffbelieves a five-day
notice for generation estimate adjustments is sufficient because the Company has a well-
established generation history for the Blind Canyon hydro project.
STAFF RECOMMENDATIONS
Staffrecommends the Commission approve the Amendment to the Energy Sales
Agreement for the Blind Canyon hydro project, with all other terms and conditions to remain
unchanged.
2STAFF COMMENTS MAY 20,2020
Respecttully zubmitted this 2dh day oflvlay 2020.
P&*L(
Edward f. Ewtt
Deputy enoil$ General
Technical Staff: Rachelle Farnsworth
Yao Yin
i:umisc/cmdipoc20.lEojrSy commcm
3STAIIF COMMENTS I\dAY 20,2020
CERTIF'ICATE OF' SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20ft DAY OF MAY 2020,
SERVED THE FOREGOING COMMENTS OF TIrE COMnISSION STAFF, IN
CASE NO. IPC-E-20-I8, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
DONOVAN E WALKER
REGI.JLATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. com
PAT WINDES
BLIND CANYON I{YDRO PROJECT
2757 5.1050 E.
HAGERMAN ID 83332
E-MAIL .com
ENERGY CONTRACTS
IDAHO POWER COMPA}.iY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
rLn l/
SECRETARY
CERTIFICATE OF SERVICE