ldaho Power on Sept. 26 petitioned the ldaho Public Utilities Commission for an order determining the proper avoided cost pricing to be included in the Public Utility Regulatory Policies Act of 1978 (PURPA) contract(s) requested by Jackpot Solar LLC and related companies for a total of four 20-MW (ac) projects.
The commission on Oct. 4 issued a public notice about the application, saying that the affected utilities have until Oct. 18 to file written comments in support or opposition of the petition. Any other person desiring to state a position on the petition may file a written comment in support or opposition with the commission no later than Nov. 8. Idaho Power has until Nov. 22 to file reply comments, if necessary.
PURPA requires ldaho Power, as a public utility, to purchase generation from cogeneration and small power production facilities that are certified as PURPA qualifying facilities (QFs) at avoided cost rates determined by the Idaho PUC. Jackpot Solar claims it is entitled to avoided cost pricing that includes the lock-in of capacity rates determined at the time of its initial two-year contract that extend to future contracts beyond the two-year contractual term.
ldaho Power asserts that prior commission orders require avoided cost rates to be determined at the beginning of each two-year contractual term, and locks in a capacity deficiency date, but in no way locks in an avoided cost rate determined at the time of contracting beyond the authorized maximum two-year term of the contract.
ldaho Power is seeking a declaratory ruling from the commission that the properly authorized avoided cost rate for Jackpot Solar when selecting rates determined at the time of contracting (as opposed to rates determined at the time of delivery) is the avoided cost determined by the incremental cost lntegrated Resource Plan (lRP) methodology at the beginning of each two-year contractual term rather than upon its initial contract, and that the QF is not entitled to lock in an avoided cost rate beyond the two-year maximum contractual term.
Jackpot Solar initially requested PURPA QF pricing on May 20, 2016, via electronic mail for a 20-year contract for an 80-MW solar QF project. On May 26, 2016, Jackpot Solar modified its request for pricing of a single 80-MW (ac) project and submitted applications pursuant to Tariff Schedule 73 for four separate 20-MW solar QF projects: Jackpot North LLC; Jackpot South LLC; Jackpot East LLC; and Jackpot West LLC. These are collectively referred to as “Jackpot Solar.”
The project sites are in Twin Falls County, Idaho, just across the state line from Jackpot, Nevada. Each project would prospectively go on-line as of Dec. 1, 2018.
Jackpot Solar initially contacted ldaho Power by applying for the interconnection of Jackpot North (20 MW) and Jackpot South (20 MW) on Aug. 10, 2015. Jackpot Solar subsequently applied for the interconnection of Jackpot East (20 MW) and Jackpot West (20 MW) on March 15, 2016. All projects applied for interconnection as separate 20-MW solar projects located at the same site.
All projects elected to be studied for interconnection as Energy Resources (ER), stating that they intended to be independent power generators and sell their output either to the market, to California, to NV Energy, or some other entity other than ldaho Power. Jackpot Solar was informed that if it desired to sel! its output to Idaho Power as a PURPA QF, that it must be studied as a Network Resource (NR), and Jackpot Solar affirmed its request to interconnect and be studied as an ER.
Jackpot Solar’s interconnection request is currently in the second phase of study, called the System lmpact Study, as an ER. At Jackpot Solar’s request, ldaho Power held a meeting between Jackpot Solar and ldaho Power’s Transmission Energy Scheduling Leader on May 19, 2016, to discuss the process and requirements for Jackpot Solar to request and obtain wheeling service for its generation output on ldaho Power’s system pursuant to ldaho Power’s Open Access Transmission Tariff (OATT). The next day, on May 20, 2016, Jackpot Solar submitted an electronic mail request to counsel for Idaho Power requesting pricing for a 20-year contract for a single 80-MW Jackpot Solar QF project.
ldaho Power said it informed Jackpot Solar that because it was an 80-MW solar QF project, it was not eligible for a 20-year contract, and upon receipt of a complete application and request for an indicative pricing proposal, Idaho Power would provide the QF with two-year indicative pricing.
On May 26, 2016, Jackpot Solar sent a cover letter and four Schedule 73 Applications for four separate projects, each at 20 MW: Jackpot North, Jackpot South, Jackpot East and Jackpot West. Jackpot Solar again requested indicative pricing lor 20 years stating, “The ESA Applications request 20 year pricing pursuant to the ldaho Public Utilities Commission’s most recent ruling on entitlement to such pricing pursuant to the ‘lRP’ methodology for estimating the Company’s avoided cost rates.” Jackpot further stated, “these projects seek to execute contracts now and lock in calculated avoided capacity and energy costs projected for the next twenty years as they intend to, and will appropriately obligate themselves, continuously renew the initial two year contract for the subsequent nine (9) contract periods.”
On June 1,2016, ldaho Power responded to Jackpot Solar’s May 26 submission and request by letter stating that the applications were incomplete and identifying additional information that was required to complete the applications. Regarding the proposed contract term, ldaho Power stated: “Your Applications list 20 years under Proposed Contracting Term. For clarification, ldaho Power will assume you are requesting the maximum contract term available for your proposed projects, which is 2 years.”
A project contact is: Robert Paul, 515 N 27h Street, Boise, ID 83702, telephone (208) 938-7901, firstname.lastname@example.org.