20170906_Camille2.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL

DATE: AUGUST 29, 2017

SUBJECT: THE APPLICATION OF ROCKY MOUNTAIN POWER FOR
AUTHORIZATION TO REVISE THE WIND INTEGRATION RATE AND
IMPLEMENT A SOLAR INTEGRATION RATE FOR SMALL POWER
GENERATION QUALIFYING FACILITIES, CASE NO. PAC-E-17-11.

On August 28, 2017, PacifiCorp dba Rocky Mountain Power applied to the
Commission for an Order authorizing it to (1) decrease its wind integration rate applicable to
power purchase agreements with wind-powered qualifying facilities (QF), from $3.06 to $0.57
per megawatt-hour (MWh), and (2) implement a solar integration rate applicable to purchases
from solar-powered QFs, of $0.60 per MWh. Application at 1. The Company indicates that
these amounts represent the integration costs of wind and solar power to be applied against
published avoided cost rates, except in cases where the QF developer specifies in the power
purchase agreement to deliver the QF output to the Company on a firm hourly schedule. Id. The
Company asks that the Application be processed by Modified Procedure. Id. at 7.
BACKGROUND
In 2008, the Commission approved a stipulation between parties in Case No. PAC-E
07-07 that Rocky Mountain shall “file notice with the Commission of any changes to its wind
integration charge as reflected in subsequent changes to its [Integrated Resource Plan (IRP)].”
Order No. 30497. Rocky Mountain’s wind integration charge was last updated in 2016, when it
was set at $3.06 per MWh. Order No. 33475.
The Company filed its 2017 IRP on April 4, 2017, in Case No. PAC-E-17-03.
Application at 3. The Company includes an excerpt from the 2017 IRP—Appendix F, the
Flexible Reserve Study—as Exhibit A to this Application. Id. The Study estimated “the
DECISION MEMORANDUM 2
regulation reserve required to maintain the PacifiCorp’s system reliability and comply with
North American Electric Reliability Corporation (‘NERC’) reliability standards as well as the
incremental cost of this regulation reserve.” Application, Exhibit A, at 1. The Application
briefly compares the reserve requirements and integration costs identified by the Study with
those identified in the Company’s previous Wind Integration Study. Id. at 5-6.
STAFF RECOMMENDATION
Staff recommends that the Commission issue a Notice of Application and set a 21-
day intervention deadline. Once the intervention deadline has passed, Staff will informally
confer with the parties about further scheduling and will report their findings back to the
Commission.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application and set a 21-day
intervention deadline?

M:PAC-E-17-11_cc