20200827Comments.pdf

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, SUME 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
effi;I tV*D
ilil i,ilil ?? PS ?: $i
;1. :_'I i,.'r-, ,:.: i-:..;-iLllt,,'1'-|.- :_; ()O.r,{ LilSSlSfi
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR APPROVAL
OR REJECTION OF A FIRST AMENDMENT
TO THE ENBRGY SALES AGREEMENT FOR
THE SALE AND PURCHASE OF ELECTRIC
ENERGY FROM NORTH GOODING MAIN
HYDRO, LLC
)
)
)
)
)
)
)
CASE NO. IPC.E.2O.3I
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on Idaho Power
Company' s Application.
BACKGROUND
On July 2l,zlzU,Idaho Power Company ("Idaho Power" or "Company") filed an
Application asking the Commission to approve or reject the first amendment ("Amendment") to
Idaho Power's Energy Sales Agreement ("ESA") with North Gooding Main Hydro, LLC
("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 North Gooding
Main Hydro project-a PURPA qualifying facility ("QF"). The Amendment addresses when the
Seller must notify the Company to revise future monthly Estimated Net Energy Amounts.
The Commission approved Idaho Power's ESA with the Seller October 27,2015. Order
No. 33404. Idaho Power asked the Commission to approve or reject the Amendment to the ESA,
which the Company and Seller agreed to on July 9,2020.
STAFF COMMENTS AUGUST 27 ,2020I
The Amendment changes when the Seller must notify Idaho Power 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 25h day of the month that is prior to the month to be revised."
Application, Attachment l. If the25th day falls on a weekend or holiday, Idaho Power must
receive written notice by the last business day before the 25ft of the monthl.
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
90lll} firmness requirements, with a five-day advanced notice instead of a one-month advanced
notification in the currently approved ESA.
One-month advanced notice contained in the current contract can benefit longer term
planning. However, the Company will have at least five years of historical generation data that it
can rely upon instead. Regardless, the Commission has approved a five-day advanced notice to
revise 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 Case Nos. IPC-E-19-01, IPC-E-19-03,
IPC-E-19-04, IPC-E-19-07, and IPC-E-19-12. Even for QFs that lack historical data, the
Company expressed through an August 4,2020 e-mail that the benefits of more accurate monthly
estimates in short-term operations provided by the five-day notice outweigh the need for month-
ahead adjustments from monthly estimates. Staff concurs, and believes a five-day advanced
notice is appropriate for all QF projects regardless of how long a QF has operated.
I The First Amendment provides the following example: "[I]f the Seller[s] would like to revise the Estimated Net
Energy Amount for October, they would need to submit a revised schedule no later than September 25fi, or the last
business day prior to September 25fi."
STAFF COMMENTS AUGUST 27,20202
STAFF RECOMMENDATION
Staff recommends the Commission approve the Amendment to the Energy Sales
Agreement for North Gooding Main Hydro, with all other terms and conditions to remain
unchanged.
Respectfully submitted this L-7fl day of August 2020.
Matt Hunter
Deputy Attorney General
Technical Staff: Rachelle Farnsworth
Yao Yin
i:umisc/commentVipce20.3 lmhr$y comments
JSTAFF COMMENTS AUGUST 27,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27,d^ DAY OF AUGUST 2020,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-20-3I, BY MAILING A COPY TI{EREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: energycontracts @idahopower.comE-MAIL: dwalker@ idahooower.com
dockets @ idahopower.com
TED SORENSON
N GOODING MAIN HYDRO LLC
1032 GRANDVIEW DR
IVINS UT 84738
E-MAIL: [e-mail]
s Y
CERTIFICATE OF SERVICE