20220714Comments.pdf

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CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9810
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Street Address for Express Mail:
I I331 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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IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OF A SECOND AMENDMENT TO THE
ENERGY SALES AGREEMENT WITH SIMCOE
SOLAR, LLC FOR THE SALE AND PURCHASE
OF ELECTRIC ENERGY
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CASE NO. IPC.E-22-17
COMMENTS OF THE
COMMISSION STAFF
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its Attorney of
record, Chris Burdin, Deputy Attorney General, and submits the following comments.
BACKGROUND
On June l4,2022,Idaho Power Company ("Company") filed an Application with the Idaho
Public Utilities Commission ("Commission") requesting approval of a Second Amendment to its
Energy Sales Agreement ("ESA") with Simcoe Solar, LLC ("Seller"), which sells energy
generated by the Seller's 2O-megawatt solar photovoltaic project ("Facility") located in Elmore
County, State of Idaho. The Facility is a qualiffing facility ("QF") under the Public Utility
Regulatory Policies Act of 1978 ("PURPA"). The Second Amendment seeks to delete Section
6.2.2 of the ESA and replace it with a new Section 6.2.2, which modif,res the timeframe for
adjusting the monthly estimated Net Energy Amount ('NEA") but does not change other
ISTAFF COMMENTS JULY 14,2022
obligations or provisions of the parties set forth in the ESA. The new timeframe allows the Seller
to make adjustments by the 25thday of the preceding month in which a change is requested.
STAFF REVIEW
Staff has reviewed the Application and recommends approval of the five-day advanced
notice. Staff believes that monthly estimates that are 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. 34263,34870
and34937.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Second Amendment to the ESA as
filed on June 14, 2022.
Respectfully submiued this /q
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-duy ofJuly 2022.
Chris Burdin
Deputy Attorney General
Technical Staff: Yao Yin
i : umisc/commen ts I ipw22. 17 cbry comments
2STAFF COMMENTS JULY 14,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I4TH DAY OF JI.INE 2022,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO.IPC.E.22.I7, BY E-MAILING A COPY TTIEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
mgoicoecheaallen@ idahopower.com
dockets@idahopower. com
SIMCOE SOLAR LLC
C/O AREVON ENERGY INC
88OO N GAINEY CTR DR SUITE 250
SCOTTSDIJ-E AZ 85258
E-MAIL: [e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE tD 83707-0070
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE