20210204Comments.pdf

EDWARD J. JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 33+0314
IDAHO BAR NO. rc446
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUME 2OI.A
BOISE,ID 837t4
Attorney for the Commission Staff
BEFORE TI{E IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OR REJECTION OT A SECOND
AMNNDMENT TO TITE ENERGY SALES
AGRBEMENT WITH ID SOLAR \,LLC
cAsE NO. IPC-E-20-38
COMMDNTS OF THE
COMNfiSSION STAFF
The Staff of the ldaho Public Utilities Commission comments as follows on ldaho Power
Company's Application.
BACKGROUND
On December I l, 2020, Idaho Power Company asked the Commission to approve or
reject an amendment to its Energy Sales Agreement ("ESA") with ID Solar l, LLC ("ID Solar
l-)" [D Solar I is a 40 MW nameplate capacity qualifying tacility ("QF') under the Public Utility
Regulatory Policies Act of 1978.
The proposed amendment would allow ID Solar I to adjust its monthly estimated net
energy amount by the 25th day of each month, whereas the current provision requires ID Solar I
to provide its monthly estimated nel energy amount one month in advance.
In July 2014, Idaho Power entered an ESA to buy energy and capacity from the QF.
Order No. 33180, IPC-E- l4-ZA. The QF was later transferred from Boi.se City Solnr, LLC to
Idaho Solar l. Order No.33596, [PC-E-16-20.
STAFF COMMENTS FEBRUARY 4,2021
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STAFF ANALYSIS
Staff recommends approval of the proposed Amended ESA between Idaho Power and ID
Solar l. If approved by the Commission, Section 6.2.2 of the existing ESA would be replaced to
allow the Seller to adjust its monthly estimated net energy amount with at least five-day advanced
notice instead of at least one-month advanced notice contained in the currently approved ESA.
The Commission has allowed five-day advanced notice to revise monthly generation
estimates in previous cases for both existing projects (such as in Case Nos. IPC-E-19-01, IPC-E-
19-03, IPC-E-19-04, IPC-E-19-07, and IPC-E-19-12) and new projects (such as in Case No. IPC-
E-20-27).
All of these previously approved projects are surrogate avoided resource method ("SAR
Method") projects; however, this case is the first Integrated Resource Planning method ("[RP
Method") project requesting the same amendment. Updating monthly generation estimates for
SAR Method projects closer to the time of delivery can improve the accuracy of input used by the
Company for short-term operational planning, which in turn could lower operational costs. Staff
believes it is a reasonable assumption that increased accuracy from larger IRP Method projects
can provide at least the same benefit.
STAFF RECOMMENDATIONS
Staff recommends the Commission approve the Amendment to the Energy Sales
Agreement between Idaho Power and ID Solar l, with all other terms and conditions to remain
unchanged.
Respectfully submitted this qG day of February 2021.
Edward J
General
Technical Staff: Yao Yin
i:umisc/commentVipce20.3Sejyy comments
2STAFF COMMENTS
Deputy A
FEBRUARY 4,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF FEBRUARY 2021,
SERVED TI{E FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-2O-38, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets @ idahopower.com
YUTAKA YANASE
S POWER
ID SOLAR l LLC
2180s 1300ESTE600
SALT LAKE CMY UT 84106
E-MAIL: [e-mail]
ARY
CERTIFICATE OF SERVICE