20200514Comments.pdf

STAFF COMMENTS 1 MAY 14, 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 A FIRST AMENDMENT TO THE ENERGY
SALES AGREEMENT WITH WILLIAM
ARKOOSH FOR THE SALE AND PURCHASE
OF ELECTRIC ENERGY FROM THE LITTLE
WOOD RIVER RANCH II HYDRO PROJECT
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CASE NO. IPC-E-20-20

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 3, 2020, Idaho Power Company (“Idaho Power”) filed an Application seeking
approval of the first amendment (“Amendment”) to its Energy Sales Agreement (“ESA”) with
William Arkoosh (“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
Little Wood River Ranch II Hydro Project—a PURPA qualifying facility. The Amendment
addresses when the Seller must notify the Company in order to revise future monthly Estimated
Net Energy Amounts.
The Commission approved Idaho Power’s ESA with the Seller in 2014. Order No. 33103.
Idaho Power asks the Commission to approve the Amendment to the ESA, which the parties
agreed to on April 3, 2020.
RECEIVED
2020 May 14PM1:28
IDAHO PUBLIC
UTILITIES COMMISSION

STAFF COMMENTS 2 MAY 14, 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 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 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 by 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 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-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 October 9, 2015, Staff believes a five-day
notice for generation estimate adjustments is sufficient because the Company has an
established generation history for the Little Wood River Ranch II Hydro Project.

STAFF RECOMMENDATIONS
Staff recommends the Commission approve the Amendment to the Energy Sales
Agreement for the Little Wood River Ranch II Hydro Project, with all other terms and conditions
to remain unchanged.

STAFF COMMENTS 3 MAY 14, 2020
Respectfully submitted this 14th day of May 2020.

________________________________
Matt Hunter
Deputy Attorney General

Technical Staff: Rachelle Farnsworth
Yao Yin

i:umisc/comments/ipce20.20mhyyrf comments
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF MAY 2020,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-20-20, 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]

WILLIAM ARKOOSH
LITTLE WOOD RIVER RANCH
2005 HIGHWAY 25
GOODING ID 83330
E-MAIL: [e-mail]

/s/ Reyna Quintero __
SECRETARY