20220527PAC to Staff 1-8.pdf

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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
May 27,2022
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.nori),uki@ouc. idaho. eov (C)
RE rD PAC-E-22-06
IPUC Set I (l-8)
Please find enclosed Rocky Mountain Power's Responses to IPUC l$ Set Data Requests l-8
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
Enclosures
PAC-E-22-06 / Rocky Mountain Power
Ivf.ay 27,2022
IPUC DataRequest I
IPUC Data Request I
Bottr the original contract and Application in CaseNo. PAC-E-2I-I I
stated that the nameplate of the Facility is 330 kW. However, the renewal Power
Purchase Agreement (PPA) states that the nameplate of ttre Facility is 480 kW.
Please respond to the following:
(a) What was the actual nameplate installed when the Facility was first
constructed?
(b) Have there been any modifications to the Facility that increased its nameplate
size since it was first constructed?
(c) Please reconcile the 330 kW and the 480 kW.
Response to IPUC Data Request I
(a) 480 kilowatts (kW) is the original nameplate installed when facility was first
constructed. Please refer to the proof of generator nameplate provided by tre
qualifying facility (QF), Georgetown Inigation Company, below:
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC Data Request 1
O) No.
(c) The contracting parties had made an estimate of ttre capacrty of the unit to
execute the legacy power purchase agreement (PPA) in July 1984 at 330 kW.
Case PAC-E-zL-ll was filed with ttre Idatro Public Utilities Commission
(IPUC) to extend the legacy PPA such that the existing generator
interconnection contact would be automatically extended at 330 kW. The QF
owner sent the above provided photograph of the generator nameplate (refer
to ttre Company's response to subpart (a) above) in support of the PPA
renewal; this was when the generator was discovered to have a nameplate that
was higher than the capacity reflected in the existing legacy PPA and
generator interconnection agreement.
Recordholder:Irene Heng
Craig EllerSponsor:
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC Data Request 2
IPUC Data Request 2
Page 4 of the Application states that the Seller secured a new standalone
transmission interconnection agreement on September 1,2021, but the Seller
continued working through March 24,2022, to secure and provide information
and proof of insurance to support the execution of the renewal PPA. Please
respond to the following:
(a) Please list and provide all the information that ttre Seller was required to
provide between September 1,2021, and March 24,2022.
(b) Please explain why the information was required.
(c) Did any of the information required depend on ttre completion of the
transmission interconnection agreement?
(d) Is the insurance information required by previous Commission order? If so,
please provide the order number.
(e) If the information required did not depend on the fiansmission interconnection
agreement, why couldn't the information be obtained earlier so that the
renewal PPA could be submitted to the Commission prior to the expiration
date of the original PPA on March 31,2022?
Response to IPUC Data Request 2
(a) Seller was required to provide an executed interconnection agreement, water
rights evidence, proof of nameplate capacity, generator detail required in
Exhibit B of power purchase agreement (PPA), and insurance certificate in
accordance with Exhibit I of PPA.
(b) A copy of an executed interconnection agreement is required to ensure the
generator has transmission interconnection. Water rights evidence is needed to
confirm the generator has rights to the water used to generate electical output.
The nameplate capacity and generator detail establishes that ttre generator is
the original generator from the legacy qualiffing facility (QF) PPA, provision
of the insurance certificate ensures that the Seller bears its own risk of
operations and that PacifiCorp's regulated customers do not bear operational
risk of the QF generator.
(c) The Company obtained some generator information from the interconnection
agreement for purposes of populating Exhibit B of the PPA. Information
required of Seller for purposes of the PPA which was not required in
connection with the interconnection agreement includes an insurance
certificate evidencing Seller has obtained the coverages required under the
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC DataRequest 2
PPA and evidence that Seller holds suffrcient water rights to operate the
facility.
(d) The insurance provisions in the PPA, as well as ttre obligation to provide an
insurance certifrcate confirming that such coverages have been obtained, are
required under PacifiCorp's energy risk management policy and are imposed
on all counterparties that want to sell generation output from a generator to
PacifiCorp.
(e) Despite multiple reminders by the Company, Seller did not obtain the required
coverages until March 24,2022.
Recordholder:lrene Heng
Craig EllerSponsor:
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC DataRequest 3
IPUC Data Request 3
Page l5 of the PPA defines the period between the expiration date of the Prior
PPA and the Initial Delivery Date as "Lapse Period." Please answer the following
questions:
(a) Did the project generate and sell energy to the Company during the Lapse
Period?
(b) Is the project planning to generate energy and sell to the Company from now
until the end of the Lapse Period?
(c) What price has the Company paid for the energy delivered during the Lapse
Period?
Response to IPUC Data Request 3
(a) Not initially. The Company could not accept power without obtaining
designated network resource (DNR) status for the generator from PacifiCorp
Transmission. DNR designation ensures compliance with Federal Energy
Regulatory Commission (FERC) requirements. The Company requested DNR
status, which can take up to 90 days to obtain, for the facility upon execution
of the powerpurchase agreement (PPA).On May 12,2022, the Company
advised the Seller that DNR status had been obtained and that Seller could
resume generation activities.
(b) Yes, per the Seller
(c) The Company will pay the price per Exhibit K of the PPA when generation is
received from Seller, subject to adjusfinent consistent with any order issued by
the Idaho Public Utilities Commission (PUC) in this case.
Recordholder:Irene Heng
Craig EllerSponsor:
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC Data Request 4
IPUC Data Request 4
Page 10 of the PPA states that the Seller is obligated to sell its Net Output from
the Scheduled Initial Delivery Date, which is April 1,2022, through March 31,
2042. However, Page 15 states that during the Lapse Period Seller shall be
prohibited from delivering Output without the Company's prior written consent
and the Company will not be obligated to pay Seller for any power. Please
respond to the following questions:
(a) Should the "Scheduled Initial Delivery Date" have been "lnitial Delivery
Date'?
(b) Is the Seller obligated to sell energy during the Lapse Period, or is the Seller
allowed to sell energy with the Company's prior written consent during the
Lapse Period? Please explain.
(c) If the Seller is prohibited from delivering energy by default during ttre Lapse
Period, are the parties deviating from the Commission's expectations
established in prior orders' for QFs' continuous operations when they request
capacrty payments in their renewal contracts?
(d) If the Seller is delivering energy during the Lapse Period, did the Seller
receive the Company's prior written consent? If so, please provide a copy of
the consent.
Response to IPUC Data Request 4
(a) The Initial Delivery Date is the date on which contractually enumerated
conditions have occurred. The Initial Delivery Date should occur on the
Scheduled Delivery Date, which is the date immediately following the
expiration of the legacy power purchase agreement (PPA), ensuring
continuous operations. By definition, the Initial Delivery Date will occur on
the Scheduled Delivery Date if on or before the Scheduled Delivery Date: (i)
the Initial Delivery Requirements are met, (ii) the Company has obtained
designated network resource (DNR) status for the facility and (iii)
Commission approval of the PPA has been obtained. Seller has the obligation
to ensure that the Initial Delivery Requirements are met (and can be held in
default if the Initial Delivery Date does not occur by the Scheduled Delivery
Date). Thus, the provision requiring Seller to sell its Net Output starting on
the Scheduled Delivery Date is accurate except in certain circumstances where
the Company's consent to deliver is required, including the circumstances
contemplated under Section 4.1, in which the Initial Delivery Date does not
occur on or before the Scheduled Delivery Date (i.e., because certain
conditions, such as the requirement for DNR status have not been obtained).
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC Data Request 4
(b) Seller must not deliver energy unless it obtains the Company's prior written
consent during the Lapse Period. The reason for the consent requirement is to
account for the lead time needed for the Company to obtain DNR status for
transmission service when PPA execution does not occur at least 90 days
before the Scheduled Delivery Date.
(c) The purpose of including the Lapse Period provision is not to intemrpt
operations but simply to facilitate compliance with Federal Energy Regulatory
Commission (FERC) requirements (i.e., by ensuring DNR status is obtained
before the Company's system receives power from a facility) in case the PPA
is executed less than 90 days before the Scheduled Delivery Date, as in this
case. DNR status is requested only after a PPA is executed and can take up to
90 days to obtain. The qualiffing facility (QF) generator equipment that
supported the legacy QF PPA is the same QF generator equipment to be used
to generate energy to be sold to the Company under the new PPA. PacifiCorp
has relied on this facility for estimated 0.33 megawatts (MW) of capacity over
the years of operations of the QF unit and will continue to do so. Thus,
capacity payments under the PPA are appropriate. The incremental additional
0.15 MW of nameplate capacity that was not recognized in the legacy PPA
(which referred to the QF as having a 0.33 MW generator when it actually had
a 0.48 MW generator) will not receive any capacity payments until2029,
when PacifiCorp identified that it needs additional capacity in its 2019
Integrated Resource Plan (lRP).
(d) Seller was informed of DNR approval on May 12,2022. Please refer to
Attachment IPUC 4.
Recordholder:Irene Heng
Craig EllerSponsor:
Ftpm!Heng. Irene (Pacifi Corp)
Lynette Smitfi
MiBud. CYnthia Hansen OacifiCorp); Weston. Ted (PacifiCom); Blake. Debbie (PacifiCom); Liechtv. Steven
(PaciffCom)
Geooetown Inigauon @mpany QF PPA (Generator Refirt)
Thumday, May t2,2022 2:15:fi) Pfi
To:
Gc:
SubjGct!
D.b:
Hi Lynette,
The Designated Network Resource (DNR) approval from PacifiCorp Transmission Services for
Georgetown lrrigation Company (GlC) Qualifying Facility generator has been received. As such, GIC
can restart its generator and put its output onto Pacificorp's transmission system without violating
FERC rules on transmission services. The PPA is still subject to ldaho Public Utility Commission
approval at this writing but PacifiCorp will apply the rates on Exhibit K of the PPA unless told
otherwise by Commission when the order is issued. Please advise if there are any questions. Thank
you.
Best,
lrene Heng
PacifiCorp | 825 NE Multnomah Street, Ste 500, Portland, OR97232-2135 | Direa [phone] | Cell [phone]
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC Data Request 5
IPUC Data Request 5
Regarding the Company's Transmission Provider and Interconnection Provider:
(a) Please describe the responsibilities of Transmission Provider and
lnterconnection Provider.
(b) Please describe the role each plays in this PPA.
(c) Please describe the role each plays in the Transmission Interconnection
Agreement.
Response to IPUC Data Request 5
(a) The tansmission provider is responsible for managing all requests for
transmission service utilizing PacifiCorp's fiansmission system per Section II
and III of PacifiCorp's Open Access Transmission Tariff(OATT). The
interconnection provider is responsible for managing all requests for
generation interconnection proposed to connect to PacifiCorp's fansmission
system per Section IV of PacifiCorp's OATT.
(b) Neither the transmission provider nor interconnection provider has no role to
play in the power purchase agreement (PPA).
(c) The tansmission provider has no role to play in the transmission
interconnection agreement. The generation provider is responsible for
drafting, negotiating and managing the interconnection agreement per the
terms in PacifiCorp's OATT.
Recordholder: Brian Fritz
Sponsor:To Be Determined
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC Data Request 6
IPUC Data Request 6
Page 23 of the PPA requires the Seller to "provide an annual update to the
expected long-term monthly/diurnal mean net energy and net capacity factor
estimates (l2X 24 profile)" by December I of each year during the contract term.
Please respond to the following:
(a) Please explain the role of the annual 12X24 profile plays
(b) Please explain the relationship betweenthe 12 X 24 profile and the monthly
estimates used for the 90/l l0 rule.
Response to IPUC Data Request 6
(a) The 12x24 profile is a generator output profile used by PacifiCorp for Long-
Range Forecasting of Seller's generator output over the course of a forward
calendar year. The Seller's 12y24 profile is only one data source used by
PacifiCorp to estimate what energy resource the Company is projected to have
to serve its customers' load requirements.
(b) While the 12x24 profile is provided by December I of each year per Section
6.7.1 of the power purchase agreement (PPA), the Seller has the ability to
update the estimated energy schedule each 20m of the month for the following
month per Section 4.9.2 of the PPA. That estimated energy schedule, if
provided timely for the respective month, will update the applicable month
that was provided inthe 12x24 profile. The Seller's estimated energy
schedule, as may be modified by any timely updates, is what is used in the
90/l l0 rule settlement calculation to determine if the Seller has met the
90/l l0 threshold band to receive compensation at the Conforming Energy
Purchase Price or the Non-Conforming Energy Purchase Price.
Recordholder:Irene Heng
Craig EllerSponsor:
PAC-E-22-06 / Rocky Mountain Power
May 27,2022
IPUC Data Request 7
IPUC Data Request 7
Please explain why the contact does not contain provisions that:
(a) requires an "As-Built Supplement", which provides the final as-built
characteristics of the Facility such as Nameplate Capacrty Rating, Net Output
technology type, generator fuel type, etc., after it becomes operational under
the proposed renewal PPA;
(b) addresses potential deviations that could affect the contract materially(such as
pricing) between the final characteristics contained in an "As-Built
Supplement" and ttre proposed facility characteristics in the renewal PPA
approved by the Commission;
(c) declares that Seller would be in default of the contract if the Seller materially
modifies ttre Facility from the "As-Built Supplement" during the contract term
without promptly notifring the Company; and
(d) requires that the Company is required to file an amendment for Commission
approval if the Seller materially modifies the Facility per the As-Built
Supplement.
Response to IPUC Data Request 7
(a) The power purchase agreement (PPA) does not require 'As-Built
Supplemenf'because this PPA is for an existing qualifring facility (QF)
generator installed in 1984 and not for a new facility. The facility is comprised
of the original physical equipment that had been used to generate and sell
output under the legacy PPA that had just expired. Please also refer to the
Company's response to IPUC Data Request l.
(b) Not Applicable. Please refer to the Company's response to subpart (a) above.
(c) Not Applicable as no "As-Built Supplement" is required as discussed in the
Company's response to subpart (a) above. However, please refer to Section
ll.l.2(g;) of the PPA which provides that Seller will be in default under the
PPA in the event of "[a]ny modification of the Facility that (i) results in the
Facility increasing its Nameplate Capacrty Rating beyond that stated in
Exhibit B of the PPA, or (ii) is reasonably likely to result in the expected
annual Net Output, as calculated in Exhibit A of the PPA, to increase.
(d) Not Applicable as no "As-Built Supplemenf is required as discussed in the
Company's response to subpart (a) above. However, please refer to the
Company's response to subpart (c) above. In the event of a facility
modification that gives rise to a default under Section I1.1.2(g), unless Seller
PAC-E-2246 / Rocky Mountain Power
Ivlay 27,2022
IPUC DataRequest 7
cures such default within the applicable cure perid, the Company has a right
to terminate the PPA. Altematively, the Company could choose to ronegotiato
and amend the PPA which amendment would be subjwt to Idaho Pubfic
Utilities Commission (tr UC) approval.
Reoordholder:Irene Heng
Craig EllerSponsor:
PAC-E-22-06 / Rocky Mountain Power
N'{ay 27,2022
IPUC Data Request 8
IPUC Data Request 8
Page2 ofthe PPA defmes Contract Year as "any consecutive twelve (12) month
period during the Term, commencing at 00:00 hours on April l, 2022 or any of its
anniversaries and endingat24:0O hours on the last day of such twelve (12) month
period." Page2l of ttre PPA describes how "Contract Year" is used in the annual
forecast of Planned Outages. With the final Effective Date being later ttran April
1,2022, does the definition of Contract Year need to be changed? Please explain.
Response to IPUC Data Request 8
ln the event the ldaho Public Utilities Commission (IPUC) approves the power
purchase agreement (PPA), the Company respectfully requests ttrat such approval
be retroactive to April 1,2022. The Company does not believe the definition of
Contact Year requires amendment particularly given that the Expected Net
Output requirements start in the first$l! Contact Year.
Recordholder:Irene Heng
Craig EllerSponsor: