20220714Comments.pdf

L--'.-;CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMTSSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 8026
Street Address for Express Mail:
I133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
1.:r ial
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OF A SECOND AMENDMENT TO THE
ENERGY SALES AGREEMENT WITH
ORCHARD RANCH, LLC FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY
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CASE NO. IPC,E.22-2I
COMMENTS OF THE
COMMISSION STAFF
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its attomey of
record, Claire Sharp, Deputy Attomey 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 Orchard Ranch, LLC ("Seller"), which sells energy generated by the Seller's 20-
megawatt solar photovoltaic project ("Facility") located in Ada County in Idaho. The Facility is
a qualifuing 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 Section6.2.2, which modifies the timeframe for adjusting the Net Energy Amount ("NEA")
ISTAFF COMMENTS JULY 14,2022
but does not otherwise change other obligations 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.
STAF'F 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 orders such as Order Nos. 34263, 34870 and
34937.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Second Amendment to the ESA as
filed on June 14, 2022.
\Yq", orluty2o22Respectfully submitted this
Technical Staff: Yao Yin
i:umisc/commentsl ipce22.2l csyy comments
Claire Sharp
Deputy Attorney General
U/1'-L
2STAFF COMMENTS JULY 14,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I4TH DAY OF JUNE 2022,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO.IPC-E-22-21, 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]
mgoicoecheaallen@ idahopower.com
[e-mail]
ORCHARD RANCH SOLAR LLC
C/O AREVON ENERGY INC
88OO N GAINEY CTR DR SUITE 250
SCOTTSDALE AZ 85258
E-MAIL : i [e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL : [e-mail]
,L/L/-,4sECmT)rf
CERTIFICATE OF SERVICE