20210806Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03t2
IDAHO BAR NO. 9917
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OR REJECTION OF THE FIRST
AMENDMENT TO THE ENERGY SALES
AGREEMENT WITH DOUG AND NANCY
HULL
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Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.2I.23
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attomey of
record, Dayn Hardie, Deputy Attorney General, submits the following comments.
BACKGROUND
On June 30,202l,ldaho Power Company ("Company") filed an Application for approval
of an amendment ("Amendment") to its Energy Sales Agreement ("ESA") with Doug and Nancy
Hull ("Seller") who sell energy to the Company from the Curry Cattle Company hydro project
("Facility"). The Facility is a qualifying facility under the Public Utility Regulatory Policies Act
of 1978.
The Commission approved the Company's ESA with Seller in 2018. Order No. 34002.
The Company asks the Commission to approve or reject the Amendment to the ESA, which
modifies when the Seller must notiff the Company to revise future monthly Estimated Net
Energy Amounts. Currently, Section 6.2.3 requires the Seller to notifr the Company at least one-
STAFF COMMENTS AUGUST 6,2021
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 p.m. Mountain
Standard time on the 25th day of the month that is prior to the month to be revised. If the 25th
day falls on a weekend or holiday, written notice must be received by the Company by the last
business day before the 25th day of the month.
The Amendment provides this example: "...if the Seller would like to revise the
Estimated Net Energy Amount for October, they would need to submit a revised schedule no
later than September 25th or the last business day prior to Septemb er 25th."
STAFF REVIEW
Staff recommends approval of the Amendment between the Company and the Seller,
because monthly estimates provided closer to the time of delivery can improve the accuracy of
input used for short-term operational planning. In addition, the five-day advanced notice has
been authorized in prior Commission orders such as Order Nos. 34263 and 34870.
STAFF RECOMMENDATIONS
Staff recommends the Commission approve the Amendment to the ESA, with all other
terms and conditions unchanged.
lbRespectfully submitted this day of August2027
Deputy Attomey General
Technical Staff: Yao Yin
i:umisc/comments/ipce2l. I ldhyy comments
2STAFF COMMENTS AUGUST 6,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY oF AUGUST 2021,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-21.23, BY E.MAILING A COPY THEREOF, TO THE
FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
dockets@i dahopower.com
ENERGY CONTRACTS
P.O. BOX 70
BOISE, tD 83707
E-MAIL : [e-mail]
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SECRETARY
CERTIFICATE OF SERVICE