HomeMy WebLinkAbout20160119_4880.pdfDECISION MEMORANDUM 1
DECISION MEMORANDUM
TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
FROM: DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
DATE: JANUARY 15, 2016
SUBJECT: ROCKY MOUNTAIN POWER’S APPLICATION TO APPROVE
ELECTRIC SERVICE SCHEDULE NO. 38, QUALIFYING FACILITY
AVOIDED COST PROCEDURES, CASE NO. PAC-E-16-01
In Order No. 33357, the Commission directed PacifiCorp dba Rocky Mountain Power
Company (Company or Rocky Mountain) to file a tariff schedule outlining the Company’s
negotiating process under the Public Utility Regulatory Policies Act of 1978 (PURPA). On
January 13, 2016, pursuant to that directive, Rocky Mountain filed an Application for an Order
authorizing it to implement Electric Service Schedule No. 38 – Qualified Facility Avoided Cost
Procedures. Schedule No. 38 will govern the Company’s negotiating practices and queue
management related to power purchase agreements (PPAs) executed under PURPA. The
Company asked that its Application be processed by Modified Procedure.
BACKGROUND
In February 2015, Rocky Mountain petitioned the Commission for approval to
modify terms and conditions related to PURPA PPAs, and – as relevant here – to modify the
Company’s “indicative” or “incremental” pricing practice in its Integrated Resource Plan
Avoided Cost methodology. Application at 2; Order No. 33357 at 26. As to the indicative
pricing practice, the Commission found it reasonable and appropriate to create “a queue to track
the order in which QF projects have entered negotiations with a utility, so that incremental
pricing can be calculated to reflect the actual impacts of each project.” Order No. 3357 at 28.
Accordingly, the Commission directed Rocky Mountain “to file a tariff schedule . . . which
outlines its PURPA negotiating process.” Id. The Commission further provided, “The schedule
should include specific criteria for management of the queue to eliminate uncertainty and to
DECISION MEMORANDUM 2
facilitate negotiations between Rocky Mountain and [qualifying facilities (QFs) under PURPA].”
Id.
ELECTRIC SERVICE SCHEDULE NO. 38
Rocky Mountain states that the purpose of proposed Schedule No. 38 is “to efficiently
provide the steps and schedule for both the Company and developers that will govern the
determination of indicative avoided cost pricing for a proposed QF project.” Application at 2.
“Schedule 38 lists the information required by the Company to prepare indicative prices for a
proposed QF project, includes a timeline and actions to be followed by developers to receive a
PPA as well as the consequences for failure to comply with the tariff.” Id. In support of its
Application to approve Schedule No. 38, the Company attached testimony by Kyle T. Moore,
Originator/Power Marketer for Rocky Mountain, further explaining the purpose and
development of Schedule 38.
STAFF RECOMMENDATION
Staff recommends that the Application be processed by Modified Procedure with a
21-day comment period.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application and Notice of Modified
Procedure with a 21-day comment period?
/s/ Daphne Huang
Daphne Huang
Deputy Attorney General
M:PAC-E-16-01_djh