20200812PAC to Staff 3-5.pdf

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August 12,2020
JanNoriyuki
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
i an.norivuki@Ouc. idaho. gov
RE: ID PAC-E-20-09
IPUC 2d Set Data Request (3-5)
Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests 3-5. Also
provided is Attachment IPUC 4.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Encloswes
PAC-E-20-09 / Rocky Mountain Power
August 12,2020
IPUC Data Request 3
IPUC Data Request 3
The updated amendment the Company submitted in response to Staff s
Production Request No. 2 showed the amendment was dated March 20,2020.
However, the Application was not filed until June 8,2020, after the expiration of
the original l99l contract. Page No. 4 of the Application states that due to no
fault of the Seller the Company was late filing this Application. Please explain
why the Company frled this Application late.
Response to IPUC Data Request 3
Due to a miscommunication within the Company, the regulatory team was not
notified promptly of the amendment resulting in a lag in the application filing
date. The communication breakdown has been identified and steps taken to ensure
proper filing timelines in the future.
Recordholder:Kyle Moore
To Be DeterminedSponsor:
PAC-E-20-09 / Rocky Mountain Power
August 12,2020
IPUC Data Request 4
IPUC Data Request 4
Page No. 7 of the 1991 contract stated that the scheduled operation date was
January 1992. Page No. 3 of the Application in PAC-E-20-09 stated that the
contract was scheduled to expire on May 31,2020. Please provide the actual first
operation date and the contract length of the 1991 contract.
Response to IPUC Data Request 4
In 2006, the Company signed a letter agreement with Commercial Energy
Management (CEM) agreeing as to the official termination date of the confact as
May 31, 2020. This same letter reflects an estimated first operation date of June 7,
1993. Please refer to Attachment IPUC 4.
Recordholder:Kyle Moore
To Be DeterminedSponsor:
PAC-E-20-09 / Rocky Mountain Power
August 12,2020
IPUC Data Request 5
IPUC Data Request 5
Appendix I of the 1991 contract described that the avoided cost rates used
included a variable portion and a fixed portion. Please answer the following:
(a) Is the variable portion subject to the annual update of QF variable energy
prices that occurs each July 1, as in Case No. PAC-E-20-08?
(b) If the contract had not expired, what would the variable rate have been each
month for the period from June 1,2020 through February 28,2021?
(c) The initial avoided cost rate was 49.64 mills per kilowatt-hour, which
included a variable portion of 8.78 mills per kilowatt-hour at that time and a
fixed portion of 40.86 mills per kilowatt-hour. Appendix I of the 1991
contract showed that this avoided cost rate was for a contract length of 20
years. If the length of this l99l contract was greater than 20 years, please
explain why the contract used the rate for a}D-year contract length. Please
provide relevant evidence to support the explanation.
Response to IPUC Data Request 5
(a) Yes.
(b) Case PAC-E-19-07 set the variable rate at $23.85 per megawatt-hour
($/MWh) for June 1,2019 through May 31, 2020. Order 34706 in Case PAC-
E-20-08 suspended the proposed rate update of $23.O7lMWh, with an
effective date of June 1,2020 through May 31, 2021, for a period of 30 days
plus five months, unless the IPUC issues an earlier order on the Company's
application.
(c) In preparing the response to this request, the Company notes that it has been
unable to locate copies of the Idaho Public Utilities Commission (IPUC)
orders (either from its own archives or made available on IPUC's website)
referenced in Appendix I of the 1991 contract, which were published
approximately 30 years ago. Notwithstanding the foregoing statement, the
Company responds as follows which is, absent access to the referenced orders,
based on the best information and understanding of the 1991 contract that the
Company has available to it at this time:
Appendix I of the l99l contract does not list a rate for confacts in excess of
20 years, instead it states "Not Applicable" for terms of 2l years to 27 years.
The Company infers the lack of further pricing to mean that contracts in
excess of 2O-years would use the Z0-year rate. Additionally, Appendix J of the
l99l contract references that a contract with a term of 27 years would use an
average rate of 49.64 mills per kilowatt-hour (mills/kWh), the 20-year rate,
PAC-E-20-09 / Rocky Mountain Power
August 12,2020
IPUC Data Request 5
demonstrating that contracts with terms of 27 years would use the stated 20-
year rate. Appendix I of the 1991 contract also indicates that the energy rates
are pursuant to several IPUC orders, those orders, however are not
immediately available on the IPUC website, in addition to "...settlement
discussions between the parties at the offices of the Idaho Public Utilities
Commission on January 25,1991".
Recordholder:Dan MacNeil /Kyle Moore
To Be DeterminedSponsor: