20220714Comments.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9810
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OF A SECOND AMENDMENT
TO THE ENERGY SALES AGREEMENT
WITH AMERICAN FALLS SOLAR II, LLC
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY
CASE NO. IPC.E.22-20
COMMENTS OF THE
COMMISSION STAFF
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 UTILITIBS COMMISSION
)
)
)
)
)
)
)
)
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its Attorney of
record, Chris Burdin, Deputy Attomey General, 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 American Falls Solar II, LLC
("Seller"), which sells energy generated by the Seller's 2}-megawatt solar photovoltaic project
("Facility") located in Power County, State of Idaho. The Company represented that the Facility
is a qualifuing 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
Section 6.2.2, which modifies the timeframe for adjusting the Net Energy Amount ("NEA") but
1STAFF COMMENTS ruLY 14,2022
does not otherwise change other obligations ofthe parties set forth in the ESA. The new timeframe
allows the Seller to make adjustments by the 25th day of the preceding month in which a change
is requested.
STAFF REVIEW
Staffhas reviewed the Application and recommends approval of the five-day advanced
notice. Staffbelieves 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 RECOMMENDATIONS
Staff recommends that the Commission approve the Second Amendment to the ESA as
filed on June 14, 2022.
Respecttully submitted this t'l[\ day of July 2022
*ul
Chris Burdin
Deputy Attomey General
Technical Staff: Yao Yin
i : umis c/comments I ipc*2.20 cbyy comments
2STAFF COMMENTS ruLY 14,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS l4th DAY OF ruLY 2022,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-22-20, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
meoicoecheaal [en@ idaho power. com
doc wer.com
AMERICAN FALLS SOLAR II
C/O AREVON ENERGY INC
88OO N GAINEY CTR DR SUITE 250
SCOTTSDALE AZ 85258
E-MAIL: [e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE