20220223PAC to Staff 1-4.pdf

Y ROCKY MOUNTAIN
Po\TI'ER
i:iI ri I iVi: t]
i'ii: fI: i3 &H 9: 2l
l:l)iUl.t 1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
February 23,2022
Jan Noriyuki
[e-mail]. qov (C)
RE: ID PAC-E-22-01
IPUC Set I (l-4)
Please find enclosed Rocky Mountain Power's Responses to IPUC's ls Set Data Requests 14.
Provided via BOX are Confidential Attachments IPUC I and 4. Confidential information is
provided subject to protection under IDAPA 31.01.01.067 and 31.01 .01.233, the Idaho Public
Utilities Commission's Rules of Procedure No. 67 - Information Exempt from Public Review,
and further subject to the Non-Disclosure Agreement (t{DA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
--!sl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-22-01 / Rocky Mountain Power
February 23,2022
IPUC Data Request I
IPUC Data Request 1
The proposed Second Amendment states that it was dated December l5,2Wl.
However, the signature pages show that the Seller signed the Second Amendment
on December 6,2021. Please provide evidence that the Company signed the
Second Amendment on December 15, 2021.
Response to IPUC Data Request 1
Please refer to Confidential Attachment IPUC I which provides copies of an
email exchange supporting the Company's execution of the Second Amendment
to the power purchase agreement (PPA) between PacifiCorp and Larry Oja and
Christie Oja, by Company representative, Ron Scheirer, as December 15,2021.
Confidential information is provided subject to protection under TDAPA
31.01.01.067 and 31.01.01.233,the ldaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Irene Heng
Craig M. EllerSponsor:
PAC-E-22-01 / Rocky Mountain Power
February 23,2022
IPUC Data Request 2
IPUC Data Request 2
The proposed Second Amendment states "[n]otwithstanding any provision in the
PPA to the contrary, PacifiCorp shall not be responsible to purchase the output of
the Facility during periods that the Facility is curtailed due to construction and
completion of the distribution system upgrades called for in the final, new stand-
alone interconnection agreement between Seller and PacifiCorp's transmission
function". Please answer the following questions:
(a) Has the Facility been curtailed due to completion of the distribution system
upgrades?
(b) If so, has the Company purchased any output of the Facility during the
curtailment period?
(c) If the Company has purchased any output during the curtailment period, what
price was paid to the Seller?
Response to IPUC Data Request 2
(a) No, the Facility has not been curtailed by the Company due to completion of
the distibution system upgrades.
(b) The Facility has not been curtailed.
(c) The Facility has not been curtailed thus the Company will continue to buy
power from the Seller's Facility at the proposed Second Amendment contact
pricing unless the contract is not approved by the Idaho Public Utilities
Commission (IPUC).
Recordholder:lrene Heng
Craig M. EllerSponsor:
PAC-E-22-01 / Rocky Mountain Power
February 23,2022
IPUC Data Request 3
IPUC Data Request 3
The proposed Second Amendment states "[t]his Amendment shall be effective
once signed and delivered by both PacifiCorp and Seller and approved by the
Idaho Public Utilities Commission". Please answer ttre following questions:
(a) Betrveen February 1,2022, when the Seller no longer is operating under the
current contract, and when the Commission issues its final order, does the
Company expect the Facility to generate energy during this period without a
contract?
(b) What price will the Company pay to the Seller during this period?
Response to IPUC Data Request 3
(a) Yes.
(b) The Company will pay the price proposed in the Second Amendment to the
power purchase agreement (PPA) if the ldaho Public Utilities Commission
(PUC) provides retoactive approval to February 1,2022.
Recordholder:Irene Heng
Craig M. EllerSponsor:
PAC-E-22-01 / Rocky Mountain Power
February 23,2022
IPUC Data Request 4
IPUC Data Request 4
The Application states that the Company began contacting the Seller regarding
contract renewal on October 20,2020, and the Seller filed the Application for
Transmission Interconnection August 3l,2Wl, with data to begin a transmission
interconnection fast-track study fmally deemed complete December 30,2021.
Please answer the following questions:
(a) Please provide a timeline of historic and future events regarding the
transmission interconnection including but not limited to: (l) when the Seller
was first notified of the need for an Application for Transmission
Interconnection, (2) when the Application was first submitted, (3) when the
Application was considered complete, (4) when the transmission
interconnection fast-track study was initiated, (5) when the study is targeted
for completion, and (6) when construction of interconnection upgrades should
be done.
(b) Please provide copies of all correspondence between the Company and the
Seller regarding the Transmission Interconnection reflecting events included
in the timeline above.
(c) Please explain why it took approximately four months for the Interconnection
Application data to be complete.
(d) Please explain how delays in completing the interconnection process could
have been prevented so that an extension Amendment would not be necessary.
Response to IPUC Data Request 4
(a) Please refer to the Company's responses to subparts (l) through (6) below:
(l) The Company first notified the Seller regarding the need for a new
transmission interconnection agreement on October 20,2020, the same
email advising the Seller regarding confiact renewal. This was followed
up by telephone calls from PacifiCorp Transmission, and on February 23,
2|2l,PacifiCorp Transmission followed up with an email advising the
Seller that a new application needed to be submitted.
(2) The Application for Transmission Interconnection was first submitted by
the Seller to PacifiCorp Transmission on July 9,2021.
(3) The Application for Transmission Interconnection was considered
complete on October 22,2021.
PAC-E-22-01 / Rocky Mountain Power
February 23,2022
IPUC Data Request 4
(4) The transmission interconnection fast-track study was initiated on
December 30,2021.
(5) The study was completed January 27,2022.
(6) No upgrades were required in the January 27,2022 study which concluded
the generator could remain interconnected with no changes to the existing
configuration.
(b) Please refer to Confidential Attachment IPUC 4 which provides copies of the
correspondence supporting the Company's responses provided in subpart (a)
above.
(c) The Seller was unable to provide both the required site control and technical
data required for PacifiCorp to process the request during this period.
(d) The Seller could have responded to PacifiCorp's request to address renewal of
the power purchase agreement (PPA) and apply for the new transmission
interconnection earlier. In addition, the Seller could have hired a consultant to
assist with the site control and technical data requirements that resulted in
months of delays.
Confidential information is provided subject to protection under IDAPA
31.01.01 .067 and,31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Irene Heng / Kris Bremer
Craig M. Eller / Rick A. VailSponsor: