20220318Comments.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 11542
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION REGARDING
THE FIRST AMENDMENT TO THE ENERGY
SALES AGREEMENT WITH EIGHTMILE
TTYDRO CORPORATION FOR THE SALE AI\D
PURCHASE OF ELECTRIC ENERYGY FROM
THE EIGHTMILE HYDRO PROJECT
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-8.22-03
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff the Idaho Public Utilities Commission ("Staff'), by and through
its Auorney of record, Taylor Brooks, Deputy Attorney General, and submits the following
comments:
BACKGROUND
On February ll,2022,Idaho Power Company ("the Company") applied to the Idaho
Public Utilities Commission ("Commission") for approval or rejection of the First Amendment
to the Energy Sales Agreement ("ESA") between the Company and Eightmile Hydro
Corporation ("Seller"). The ESA provides for the purchase of electric energy generated by the
Eightmile Hydro project ("Facility") which is a qualifuing facility ("QF") under the Public
Utility Regulatory Policies Act of 1978 ("PURPA").
1STAFF COMMENTS MARCH 18,2022
The Company and Seller ("Parties") entered an ESA on May 5,2014, for the purchase
and sale of energy produced by the Facility. Section 6.2.3 of the ESA allows Seller to adjust the
Monthly Net Energy Amounts ('NEA") at least one month in advance. Now Seller requests a
change to at least five days in advance for making NEA adjustments in the First Amendment,
which would replace Section 6.2.3 with new language that reflects Seller's proposal.
The First Amendment to the ESA to modifr the NEA adjustment period was executed by
the Parties on February 2,2022, and February 7,2022, but the Amendment does not change any
other obligations or provisions in the ESA.
STAFF REVIEW
Staff recommends approval of the five-day advanced notice because monthly estimates
which are provided closer to the time of delivery can improve the accuracy of input used for
short-term operational planning. [n addition, the five-day advanced notice has been authorized
in prior Commission orders such as Order Nos. 34263 ,34870, and 34937 .
STAFF RECOMMENDATIONS
Staff recommends that the Commission approve the First Amendment to the ESA as filed
on February 11,2022.
Respectfully submitted this l8fl^ day of Mar ch2022.
Technical Staff: Yao Yin
i : um isc/commen tsl ip ce22.3tby y mmments
2STAFF COMMENTS MARCH 18,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF MARCH 2022,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-22-03, 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]
dockets@idahopower. com
JORDAN WHITTAKER
PO BOX 177
LEADORE ID 83464
E-MAIL: twodotirrioation@ gmail.com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
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SECRETARY
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CERTIFICATE OF SERVICE