20120727PAC to Exergy 15-18.pdf

ROCKY MOUNTAIN
RE CE! V D
201 South Main, Suite 2300
POWER Salt Lake City, Utah 84111
A DIVISION OF PACIRCORP
1.11T(L!TE3 COMMSS10
July 26, 2012
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27" Street
P.O. Box 7218
Boise, Idaho 83702
[e-mail]
gregrichardsonandoleary.com
RE: ID GNR-E-1 1-03
Exergy Data Request (15-18)
Please find enclosed Rocky Mountain Power's responses to Exergy Data Requests 15-18.
If you have any questions, please feel free to call me at [phone].
Sincerely,
z
J. Ted Weston
Manager, Regulation
Enclosure
C.c.: Jean Jewell/1PUC Jean.jewell(puc.idaho.gov
Donald L. Howell, II [e-mail]
Kristine A. Sasser kris.sasserpuc.idaho.gov
Donovan E. Walker [e-mail]
Lisa Nordstrom [e-mail]
Michael G. Andrea [e-mail]
Ken Kaufmann (E-mail Only) Kaufmann@1kIawcorn
Daniel Solander [e-mail]
Dean J. Miller [e-mail]
Thomas H. Nelson [e-mail]
John R. Lowe [e-mail]
R. Greg Femey greg(mirnuraIaw.com
Bill Piske [e-mail]
Ronald L. Williams i11iarnsbradbury.corn
Wade Thomas wthornas(Zdynamisenergy.com
Shelley M. Davis
Brian Olmstead [e-mail]
Robert A. Paul [e-mail]
James Carkulis jcarkulis@exergydeveloi,ment.com
Arron F. Jepson [e-mail]
M.J. Humphries [e-mail]
Ted Diehl [e-mail]
Bill Brown [e-mail]
Ted S. Sorenson rensopnet
Glenn Ikemoto gIennienvisionwind.corn
Margaret Rueger Margaretenvisionwind.com
Megan Walseth Decker megan(mp.org
Benjamin J. Otto botto@idahoconçyiQfl.or
Ken Miller kmii1er(snakerivera11iance.org
Robert D. Kahn-rk qhn@nipp
Don Sturtevant [e-mail]
Mary Lewallen [e-mail]
C. Thomas Arkoosh/CTL [e-mail]
GNR-B-11-03/Rocky Mountain Power
July 26, 2012
Exergy Data Request 15
Exergy Data Request 15
On page 3 of his rebuttal testimony Mr. Clements states that the Company's
Schedule 38 has been in place in other states in similar form for several years.
Please provide copies of said schedules for each state in which it is in place.
Response to Exergy Data Request 15
The Company's current tariffs are available on PacifiCorp's website. Please
select a link below to access the current Tariff Schedule 38 in Oregon, Utah, and
Wyoming:
Oregon:
i3iIpL/iwpcificpower.net/content/dam/pacific_power/doc/About Us/Rates Re
gulation/Oregon/Approved Tariffs/Rate Schedules/Avoided Cost Purchase Fro
rn Qualifying Facilities of Greater than 1O0O0KW.pdf
Utah:
http://www.rockyrnountainpower.net/content/darn]rockymom -itajn_power/doc/A
bout Us/Rates_and Regulation/Utah/Approved Tariffs/Rate_Schedules/Oualifii
ng_Facility_Procedures.pdf
Wyoming:
hLL.roeyountainpower.net/content/dam/rockymountain power/doe/A
bdut Us/Rates and Regulationyoming/Approved Tariffs/Rate Schedules/Av
oided Cost Purchases from Non Standard Quali fying Facilities.p
Recordholder: N/A
Sponsor: Paul Clements
GNR-E-1 1-03/Rocky Mountain Power
July 26, 2012
Exergy Data Request 16
Exergy Data Request 16
At page 8 of his rebuttal testimony Mr. Clements is asked, "Mr. [sic] Reading
recommends that Rocky Mountain Power file a non-firm standard contract similar
to Idaho Power's Schedule 86. Have any Idaho QFs in recent history requested a
non-firm standard contract from Rocky Mountain Power?" In response Mr.
Clements says, "No." Please provide copies of all documents relating to a request
for an as available PURP A arrangement from Lower Valley Energy to Rocky
Mountain Power/PacifiCorp in Idaho in or around June 2011. If Mr. Clements
denies that Lower Valley Energy requested that Rocky Mountain Power purchase
QF output on a nonfirm or "as available" basis, please state so.
Response to Exergy Data Request 16
The Company has no written record of having received a request from Lower
Valley Energy for an as-available PURPA arrangement in or around June 2011.
Recordholder: Bruce Griswold
Sponsor: Paul Clements
GNR-E-1 1-03/Rocky Mountain Power
July 26, 2012
Exergy Data Request 17
Exergy Data Request 17
At page 9 of his rebuttal testimony Mr. Clements states, "If the developer wishes
to sell its output at market rates on a competitive basis in the wholesale power
market comparable to other independent power producers, it should be treated
similar to other independent power producers and receive the financial treatment
under the current FERC procedures."
(a)Please describe the FERC procedures referred to and provide documentation
of said procedures.
(b)Please explain whether PacifiCorp would use its FERC/OATT procedures for
financial treatment discussed if a QF interconnecting to PacifiCorp and
wheeling its output over PacifiCorp's system for delivery and sale to another
utility pursuant to that utility's mandatory purchase obligations. Please explain
why QFs making off-system sales should be entitled to FERC cost-sharing
(and any other OATT interconnection procedures) if Mr. Clements believes
that those processes should only be available to developers who sell their
output "at market rates on a competitive basis."
Response to Exergy Data Request 17
(a)Please refer to PacifiCorp's Open Access Transmission Tariff (OATT), which
can be accessed using the following website link:
http://www.oasia.pacificorn.com/oasjs/ppw/
(b)PacifiCorp would follow the procedures in its OATT regardless of whether
the generation project was a QF or non-QF interconnecting directly to
PacifiCorp, a QF or non-QF not directly interconnected to PacifiCorp but
selling its output to PacifiCorp, a QFor a non-QF interconnected to
PacifiCorp and purchasing transmission services to move the power across
PacifiCorp's system to another off-taker.
Recordholder: Paul Clements
Sponsor: Paul Clements
GNR-E-11-03/Rocky Mountain Power
July 26, 2012
Exergy Data Request 18
Exergy Data Request 18
Please describe Mr. Clements' understanding of the difference between the way a
QF and "other independent power producers" are treated pursuant to his
recommendations for purposes of network transmission upgrades. Please explain
in detail the basis for not adopting FERC's Large Generator Interconnection
Procedures and Small Generator Interconnection Procedures from the utility's
OATT for all QF interconnections.
Response to Exergy Data Request 18
Please refer to PacifiCorp's Open Access Transmission Tariff (OATT), which can
be accessed using the following website link:
http://www.oasis.paciflcorp.comloasis/ppw/
Recordholder: Paul Clements
Sponsor: Paul Clements