20220714Comments.pdf

Street Address for Express Mail:
I 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR APPROVAL
OR REJECTION OF THE SECOND
AMENDMENT TO ITS ENFRGY SALES
AGREEMENT WITH AMERICAN FALLS
SOLAR, LLC
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CASE NO. IPC.E-22.I9
COMMENTS OF THE
COMMISSION STAFF
Staff of the tdaho Public Utilities Commission ("Staff'), by and through its attorney of
record, Riley Newton, Deputy Attorney General, and submits the following comments.
BACKGROUND
On June l4,2022,Idaho Power Company ("Company") filed an Application with the
Commission requesting approval of the Second Amendment to its Energy Sales Agreement
("ESA") with American Falls Solar, LLC ("Seller") who sells energy generated by the Seller's
20-megawatt solar photovoltaic project ("Facility") located in Power County, 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 modifies the timeframe for adjusting the monthly estimated Net Energy
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STAFF COMMENTS JULY 14,2022
Amount ("NEA"). The new timeframe allows the Seller to make adjustments by the 25th day of
the preceding month in which a change is requested. The Second Amendment does not change
any other obligations of the parties or provisions of the ESA.
STAFF REVIEW
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 Order Nos. 34263 ,34870 ard34937.
STAF ' RECOMMENDATION
Staff recommends that the Commission approve the Second Amendment to the ESA, as
filed on June 14, 2022.
Respecttully submiffed this l{" day of ,luly 2022
Riley Newton,
Deputy Attomey General
Technical Staff: Yao Yin
i:umisc/commenU ipce22. l4myy comments
)STAFF COMMENTS ruLY t4,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF JUNE 2022,
SERVED THE FOREGOING COMMENTS OF' TIIE COMMISSION STAFF, IN
CASE NO.IPC-E-22-19, 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]
mgoicoecheaal len@ idahopower. com
[e-mail]
AMERICAN FALLS SOLAR LLC
C/O AREVON ENERGY INC
88OO N GAINEY CTR DR SUITE 250
SCOTTSDALE AZ 85258
E-MAIL :,ij ohnson@arevonenerg),.com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL : [e-mail]
.lr, /l/*t
SECRETA /
CERTIFICATE OF SERVICE