20240604Staff Comments.pdf

RECEIVED
Tuesday, June 4, 2024 9:22:30 AM
IDAHO PUBLIC
UTILITIES COMMISSION
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 ROCKY MOUNTAIN )
POWER'S APPLICATION REQUESTING ) CASE NO. PAC-E-24-08
APPROVAL OF THE ANNUAL REVISION )
TO QF VARIABLE ENERGY PRICES )
PURSUANT TO TERMS OF THE 1992 ) COMMENTS OF THE
AMENDMENTS TO POWER PURCHASE ) COMMISSION STAFF
AGREEMENTS BETWEEN PACIFICORP )
AND IDAHO QFs )
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 April 12, 2024, Rocky Mountain Power, a division of PacifiCorp ("Company"),
applied for Commission approval of updates to the Qualifying Facility("QF")variable energy
price pursuant to the terms of the 1992 amendments ("Amendment") to certain Idaho QFs power
purchase agreements. Specifically, the Company requests Commission approval for a variable
energy rate of$31.76 per megawatt hour("MWh").
STAFF COMMENTS 1 JUNE 4, 2024

The Company represents that, of the 13 QF contracts originally affected by the
Amendment, only one remains in effect—the Marsh Valley Hydro contract. According to the
Company, this contract will remain effective through February 28, 2028.1
The Company represents that the variable energy rate is calculated as the sum of the
Company's fuel costs and Colstrip variable Operation and Maintenance ("O&M") cost.2 The
Company represents the variable O&M costs were set based on the variable costs associated with
the operation of the coal power generating facility Colstrip, excluding the generation tax and the
line loss adjustments.
Based on that calculation, the Company proposes the variable energy rate applicable to
deliveries commencing July 1, 2024, through June 30, 2025, should be $31.76 per MWh.
STAFF ANALYSIS
Staff reviewed the Application and confirmed that the proposed rate is correct. The
calculation used the data reported in the Company's FERC Form 1, and the resulting variable
energy rate is $31.76 per MWh.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the variable energy rate of$31.76 per
MWh applicable to the energy delivered under the Marsh Valley Hydro contract, commencing
July 1, 2024, extending through June 30, 2025.
Respectfully submitted this 4th day of June 2024.
Adam Triplett
Deputy Attorney General
Technical Staff: Yao Yin
1:\Utility\LJMISC\COMMENTS\PAC-E-24-08 Comments.docx
1 The other 12 QF contracts have expired. Ten of these contracts transitioned to new Power Purchase Agreements,
and two did not seek new contracts.
2 The Amendment defines fuel costs"as the average cost of fuel consumed in the Utah Division plants, specifically
Carbon,Hale,Naughton,Huntington,and Hunter coal plants." Application at 2. The Amendment specifies that any
plant that does not operate in a calendar year will be removed from the average fuel cost calculation. Since Carbon
and Hale plants are now closed,the Company removed these from its calculation.
STAFF COMMENTS 2 JUNE 4, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS " % DAY OF JUNE 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. PAC-E-24-08, BY &MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL: mark.alder(@,pacifico!p.com PORTLAND OR 97232
E-MAIL: joseph.dallas@,pacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest(a,pacificorp.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE