20210818Comments.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 5214
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO APPROVE
2O2I SERVICE AGREEMENT WITH THE
UNITED STATES DEPARTMENT OF
ENERGY
CASE NO.IPC.E.2I-20
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its attorney of record,
Erick Shaner, Deputy Attomey General, submits the following comments.
BACKGROUND
On June 23,202l,Idaho Power Company ("Company") filed an Application for approval
of its new service agreement (*2021Agreement") with the United States Department of Energy
("DOE") for service at the Idaho National Laboratory ("fNL"). The Company requests the
Commission issue an order approving the202l Agreement prior to September 14,2021. The
current agreement (*2016 Agreement"), approved in Order No. 33621, expires on September 14,
2021, and the new agreement is set to become effective on September 15, 2021.
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1STAFF COMMENTS AUGUST 18,2021
STAFF ANALYSIS
Staff believes the 2021 Agreement is reasonable and recommends Commission approval.
This recommendation is based on Staff s review of the Application, previous DOE agreement
cases, and past updates to Electric Service Rate Schedule 30. Staff concludes from the review
that the 2021 Agreement is reasonable because most of the terms remain consistent with the
Commission-approved 2016 Agreement. The changes in the 2021 Agreement are minor or
provide additional layers of protection for the Company to ensure the Company can continue to
recover its costs to serve the DOE in the future and maintain reliability of the system.
Staff identified the following changes between the 2016 and202l Agreements:
o The length of the Agreement term was increased from five to ten years;
. Updated estimates for the annual energy and demand usage, and an updated
maximum monthly demand;
o lncreased the time requirement for written notice for changes in power
requirements or termination of the 2021 Agreement;
o A provision for a re-opener in 2024 to renegotiate new rates, conditions, and
charges to account for future DOE needs;
. Added Contract term allowing DOE the right to install and operate on-site
generation to offset all or part of their energy usage consistent with applicable
Commission rules and rate schedules; and
o Added a Contract term allowing the Company to revise INL rates, rate structure, or
charges based on any notification of increase or decrease to contract demand
subject to Commission approval.
Most of these changes are minor or provide additional protection to the Company. An
example of a change that provides additional protection is the increase in time requirements to
l8 months instead of 12 months for written notice when the DOE requests an increase in power
requirements. This allows the Company additional lead time to plan for and determine the effect
of a change in power requirements on the Company's system, and whether the change can be
supported.
Provisions have also been added that allow rates to be revised, subject to Commission
approval, to address anticipated power requirements and/or an increase or decrease in contract
demand. This provides protection because it allows the Company to revise rates if changes in
2STAFF COMMENTS AUGUST 18,2O2I
DOE power requirements affect the cost for the DOE to be served. In addition, a provision has
been added that plans for a renegotiation ofrates, rate structure, or charges in2024 to account for
changes in power requirements for 2025 and beyond.
T\e 2021Agreement does not change the DOE's Schedule 30 rates that the Company is
charging DOE at this time. Application at 1. However, Schedule 30 rates can change as a result
of a change in base rates usually through a general rate case, Power Cost Adjustments (Schedule
55), changes in the Energy Efficiency Rider (Schedule 91), adjustments in Municipal Franchise
Fees (Schedule 95), and other special cases directly pertaining to the DOEI.
STAFF RECOMMENDATIONS
Staff recommends the Commission approve the 2021 Agreement with an effective date of
September 15,202L
Respectfully submiued this lYday of August 2021.
Erick Shaner
Deputy Attorney General
Technical Staff: Michael Eldred
Travis Culbertson
i : umisc:commentVipce2 l.20esmetnc comments
I Schedule 30 rates were changed due to an asset transfer agreement (Case No. IPC-E-20-01).
3STAFF COMMENTS AUGUST I8,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISth DAY OF AUGUST 2021,
SERVED THE FOREGOING COMMENTS OT' THE COMMISSION STAFF, IN
CASE NO. IPC-E.21.20, BY E-MAILING A COPY TTIEREOF, TO THE
FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE tD 83707-0070
E-MAIL:
dockets@idahopow'er.com
ALISON WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
Y
com
CERTIFICATE OF SERVICE