20220714Comments.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83120
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 11202
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OR REJECTION OF THE
SECOND AMENDMENT TO ITS ENERGY
SALES AGREEMENT WITH MURPHY
FLAT POWER, LLC
CASE NO. IPC-E-22-18
COMMENTS OF THE
COMMISSION STAFF
' , .:.. ;"t
I r i4 "
Street Address for Express Mail:
1I33I W CHTNDEN BLVD, BLDG 8, SUITE 201-A
BOISE, TD 83714
Attorney for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Staff of the Idaho Public Utilities Commission, by and through its Attorney of record,
Riley Newton, Deputy Attorney General, and submits the following comments.
BACKGROUND
On June 14,2022,Idaho Power Company ("Company") filed an Application with the
Commission requesting approval of the Second Amendment to its Energy Sales Agreement
("ESA") with Murphy Flat Power, LLC ("Seller") who sells energy generated by the Seller's 20-
megawatt solar photovoltaic project ("Facility") located in Owyhee County, Idaho. The Facility
is a quali$ing facility under the Public Utility Regulatory Policies Act of 1978.
The Second Amendment seeks to delete Section 6.2.2 of the ESA and replace it with a
new Section6.2.2, which modifies the timeframe for adjusting the Net Energy Amount ("NEA").
The new timeframe allows the Seller to make adjustments by the 25thday of the preceding
STAFF COMMENTS JULY 14,2022
month in which a change is requested. The Second Amendment does not otherwise change other
obligations of the parties set forth in the ESA.
STAX'F REYIEW
Staff has reviewed the Application and recommends approval of the five-day advanced
notice 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 including Order Nos. 34263, 34870 and
34937.
STAF'F' RECOMMENDATIONS
Staff recommends that the Commission approve the Second Amendment to the ESA as
filed on June 14, 2022.
Respecttully submiffed this t'//"day of Jruly2022
Riley Newton
Deputy Attorney General
Technical Staff: Yao Yin
i :umisc/comments/ipce22. I Smyy comments
2STAFF COMMENTS JULY 14,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14th DAY OF ruLY 2022,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-22.18, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
m goicoecheaal [e-mail]
[e-mail]
MURPHY FLAT POWER LLC
C/O AREVON ENERGY INC
88OO N GAINEY CTR DR SUITE 250
SCOTTSD/J-E AZ 85258
E-MAIL: [e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-IVIAIL : ener gy c ontracts @. i dahopower. corn
SECRET Y
CERTIFICATE OF SERVICE