20231107Comments of the Commission Staff.pdf

STAFF COMMENTS 1 NOVEMBER 7, 2023
ADAM TRIPLETT DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 BOISE, IDAHO 83720-0074 [phone] IDAHO BAR NO. 10221
Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION FOR APPROVAL OF A THIRD AMENDMENT TO THE ENERGY SALES AGREEMENT WITH THE HAZELTON A HYDRO PROJECT

IPC-E-23-22
OMMENTS OF THE
COMMISSION STAFF (“STAFF”) OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Adam Triplett, Deputy Attorney General, submits the following
comments.

BACKGROUND
On September 22, 2023, Idaho Power Company (“Company”), applied for approval of a
third amendment (“Third Amendment”) to its energy sales agreement (“ESA”) with North Side
Energy Company (“Seller”) for energy generated by the Hazelton A Hydro Project (“Facility”).
The Third Amendment revises the energy sales agreement to: (1) correct discrepancies in the
nameplate capacity of the Facility’s generating units; (2) delete obsolete language about the
facility location; (3) harmonize language about the Facility’s maximum capacity with the
generator interconnection agreement; and (4) reconcile Article XXIII (Modifications) with
Commission approved language.
RECEIVED
2023 November 7 9:40 PM
IDAHO PUBLIC
UTILITIES COMMISSION
STAFF COMMENTS 2 NOVEMBER 7, 2023
The Company represents that it has had an ESA for the purchase and sale of energy from
the Hazelton A Hydro Project since 2010. The Company represents that the ESA has previously
been amended twice since its formation. The Company represents that the proposed revisions
will not affect conditions, rates, or other terms of the ESA.

STAFF ANALYSIS
Staff reviewed the proposed Third Amendment and recommends Commission approval.
Staff’s review focused on the nameplate capacity, the maximum capacity amount, and the Article
XXIII (Modifications).

Nameplate Capacity
Staff believes it is reasonable to amend the nameplate capacity size from 2,700 kW to
2,898 kW for each of the three generators to reflect the actual nameplate capacities. The original
ESA listed the nameplate capacity at 2,700 kW for each of the three generators. Appendix B of
the ESA. However, the manufacturer’s nameplate attached to each of the three generators shows
that each generator is actually 2,898 kW. Third Amendment at 1.

Maximum Capacity Amount
The Company and Seller (“Parties”) agreed to amend the maximum capacity amount
from 8.1 MW to 7.7 MW to reflect the actual maximum output of the Facility. Staff believes this
is reasonable because the actual maximum output does not change and does not trigger an update
of the avoided cost rates in the contract. Although the Parties listed the Maximum Capacity
Amount of 8.1 MW in the original ESA, they agreed to amend the maximum output to 7.7 MW
to remain consistent with the amount of capacity in the Generator Interconnection Agreement
associated with the Facility.

Article XXIII (Modifications)
Staff believes the language in Article XXIII (Modifications) is reasonable and complies
with Order No. 35705.

STAFF COMMENTS 3 NOVEMBER 7, 2023
STAFF RECOMMENDATION
Staff recommends approval of the proposed Third Amendment to the ESA.

Respectfully submitted this 7th day of November 2023.

________________________________ Adam Triplett Deputy Attorney General
Technical Staff: Yao Yin
i:umisc/comments/ IPC-E-23-22 Comments
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF NOVEMBER 2023,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-23-22, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070
E-MAIL:
[e-mail] [e-mail] [e-mail]
ALAN HANSTEN E-MAIL: [e-mail]

_________________________________ SECRETARY