20120131Clements Direct_Exhibit 202.pdf

RECE D
1m2 J¡\N 31 AM lOr 20
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
COMMISSION'S REVIEW OF PURP A
QF CONTRACT PROVISIONS
INCLUDING THE SUROGATE
AVOIDED RESOURCES (SAR) AND
INTEGRATED RESOURCE
PLANNING (IRP) METHODOLOGIES
FOR CALCULATING PUBLISHED
AVOIDED COST RATES
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) CASE NO. GNR-E-11-03
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) Direct Testimony of Paul H. Clements
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ROCKY MOUNTAIN POWER
CASE NO. GNR-E-11-03
January 2012
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Please state your name, business address and present position with
PacifiCorp, dba Rocky Mountain Power Company (the "Company").
My name is Paul H. Clements. My business address is 201 S. Main, Suite 2300,
Salt Lake City, Utah 84111. My present position is OriginatorlPower Marketer for
PacifiCorp Energy. PacifiCorp Energy and Rocky Mountain Power are divisions
of PacifiCorp (hereinafter referred to as the "Company" or "Rocky Mountain
Power").
How long have you been in your present position?
I have been in my present position since December 2004. .
Please describe your education and business experience.
I have a B.S. in Business Management from Brigham Young University. I have
been employed with PacifiCorp since 2004 as an originator/power marketer
responsible for negotiating qualifying facility contracts, negotiating interrptible
retail special contracts, and managing wholesale or market-based energy and.
capacity contracts with other utilties and power marketers. I also worked. in the
merchant energy sector for approximately six years in pricing and strctuing,
origination, and trading roles for Duke Energy and Ilinova.
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What is the purpose of your testimony?
I present the Company's recent experience with Non-Standad Qualifying Facility
("QF") contracts. Non-Standard QFs are projects that do not qualify for published
rates. In addition, I propose a new taff Schedule 38, provided as Exhibit No.
202, to govern the Non-Standard QF contracting procedures in Idaho going
Clements, Di - 1
Rocky Mountain Power
1 forward and I wil explain the provisions of this new tariff. Lastly, I provide
2 comments on Environmental Attbute ownership as it pertains to QFs.
3 Q.Please summarize your testimony.
4 A.The Company has, over the past five years, received five requests for indicative
5 pricing for projects that do not qualify for published rates for qualifying facilties.
6 The Company used the IRP methodology, as established in IPC-E-95-9, to
7 calculate indicative avoided costs in response to the requests. Rocky Mountain
8 Power witness. Ms. Kelcey Brown provides an overview of the methodology and
9 the Company's proposal for continued use of the IRP methodology. The IRP
10 methodology along with the contracting procedures contained in the proposed
11 tariff Schedule 38 wil provide fair pricing and contracting processes for Non-
12 Standard QFs in Idaho and wil render existing retail customers indifferent as to
13 whether energy is purchased from QFs or supplied by Rocky Mountain Power
14 from other sources in the futue. Regarding Environmental Attbute ownership,
15 the Company's position is that the Company owns all Environmental Attibutes
16 generated by QFs.
17 Proposed Tariff Schedule 38
18 Q.Please explain why the Company is proposing tariff Schedule 38.
19 A.Tariff Schedule 38 is a new tariff for Non-Standard QF projects that wil provide
20 the steps and timeframe that both the Company and a proposed Non-Standard QF
21 work through to determine indicative or estimated avoided cost prices for a
22 proposed QF project. . The taff wil facilitate communication between the
23 Company and potential QFs as they work through the negotiation process. The
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tariff clearly identifies the information required from the QF and the timeline in
which the QF wil receive indicative pricing. The tariff codifies in Idao the
process that Rocky Mountain Power formally uses in Utah and Wyoming and has
informally been using in Idaho for several years. Though experience in
implementing the process in other states, the Company believes the formal
process proposed in Schedule 38 is an efficient and productive process for both
the Company and potential QFs.
Does the Company have a formal Non-Standard QF negotiation procedure in
other jurisdictions?
Yes. The Company's Schedule 38 Non-Standard QF contract negotiation process
is in place in Utah,
1 Oregon and Wyoming.
Please explain the proposed tariff Schedule 38.
Schedule 38 - Avoided Cost Purchases from Non-Standad Qualifying Facilities,
is based on the output of a work-group that was established in 2002 in Uta
Docket 02-035- TIl addressing issues similar to those being addressed in Case
No. GNR-E-ll-03 in Idaho. The work group included many parties with similar
interests to those in this Case, who participated in the ,development and
negotiation of the procedures in this tarff. The general purose of Schedule 38 is
to provide the steps and timeframe that both the Company and a proposed QF
work though to determine indicative avoided cost pricing for a proposed QF
project. The tariff clearly lays out the information the Company requires be
provided by the developer in order for the Company to prepare indicative prices
i As an example the Utah tarff can be found at the following internet address:
htt://ww.rockyountainpower.net/content/dam/rocky _mountain -power/doc/ About_ Us/Rates _and _ Regu
lation/tah! Approved _ Tarffs/Rate _ Schedules/Avoided _ Cost_Purchases _from _ Qualifying_Facilities.pdf.
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Rocky Mountain Power
1 for a proposed QF project.
2 Even a developer of a QF project in the conceptual stage should have most
3 of the information collected and available to provide to the Company because the
4 information required in Schedule 38 is necessary for the design, development,
5 financing, and constrction of the QF project. As outlined by the procedure, QF
6 projects that provide the required details regarding their projects up front have a
7 much lower probability of experiencing a delay in the development of indicative
8 prices. The Company works very closely with the QF in this initial step by
9 completing due diligence and feedback on the information. Once the information
lOis agreed to by both paries, the Company completes its pricing step. As outlned
11 by the tarff, the parties then follow the timelines and process for completing
12 negotiation of a Power Purchase Agreement ("PP A"). The timeline for the varous
13 steps in the process is as follows:
14 1. Indicative pricing is provided within 30 days following receipt of all
15 required information.
16 2. A draft PP A is provided within 45 days following receipt of all
17 required additional information after indicative pricing has been
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19 3. A final PPA is provided within 45 days of agreement by both parties
20 on all material terms in the PP A.
21 4. Counterparties must wait 60 days after one part gives notice that the
22 parties are unable to reach agreement on a final PP A before fiing a
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complaint with the Commission on any specific contract terms not
agreed upon.
What contract terms and conditions will be included by the Company in a
PP A that is provided as part of the Schedule 38 process?
The terms and conditions of the QF PP A wil be similar to those terms and
conditions obtained from recent similarly-sized QFs and third part PPAs and wil
also take into account the terms and conditions established by the Commission in
Case No. GNR-E-11-0L.
How does the proposed Idaho Schedule 38 compare to the current Wyoming
and Utah Schedules 38?
The proposed Idaho Schedule 38 is similar to the Wyoming Schedule 38. Rocky
Mountain Power established the Wyoming Schedule 38 in late 2011 and it reflects
the most up-to-date process that has been refined through experience to provide
the most effcient process for communication between the QF and the Company.
The Utah Schedule 38 has been in place for several years and is slightly different
than the Wyoming Schedule 38 and the proposed Idaho Schedule 38. The
proposed Idaho Schedule 38 provides 45 days for delivery of the draft PPA, the
Utah Schedule 38 provides 30 days. The proposed Idaho Schedule 38 also
establishes a 45 day timeline for delivery of a final PP A, the Utah Schedule 38
does not provide a timeline for delivery of a final PP A. Finally, the proposed
Idaho Schedule 38 establishes a 60 day waiting period before a complaint with the
Commission on contract terms can be filed, the Utah Schedule 38 does not
address Commission complaint filings.
Clements, Di - 5
Rocky Mountain Power
1 Q.Has Schedule 38 worked as it was intended in the other states where it has
2 been implemented?
3 A.Yes. Schedule 38 has provided a framework under which the QF developer knows
r 4 what is required in order to obtain indicative pricing. Even in other states where
5 there is no formal Schedule 38, the Company uses this schedule as a general road
6 map with the developer who is proposing a Non-Standard QF. It provides the QF
7 developer a clear understanding on what is needed to secure indicative prices
8 from the Company. If they wish to proceed with the project or renew their
9 contract, the tarff establishes a procedure that both parties follow throughout the
10 contract negotiations. To work effectively, Schedule 38 requires specific and
11 detailed information from the QF regarding their proposed project. A QF
12 developer that comes to the Company with vague requests or insuffcient details
13 wil go through a series of due diligence meetings until all data is agreed to by
14 both parties. The Company is not in a position to provide indicative pricing
15 without sufficient and clear project details. Once the prices are prepared and
16 accepted by the QF, there is a set time frame for the Company to provide an initial
17 draft PPA for contract negotiations. The QF knows and understands the steps and
18 timeframe to complete a power purchase agreement.
19 Q.Have you provided as an exhibit a proposed Schedule 38 for Idaho?
20 A.Yes. Exhibit No. 202 is the Company's proposed Schedule 38 for Idaho.
21 Environmental Attribute Ownership
22 Q.What is an Environmental Attribute?
23 A.The "Environmental Attbute" of electrcity generation is a collection of the
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environmental and other positive, non-energy attbutes of renewable generation.
Environmental Attbutes include not only the avoided emissions characteristics
and the proof of generation of renewable energy, but also the right to make a
claim with respect to that energy; specifically, the exclusive right to claim to have
pedormed the social and environmental good of generating renewable, as
opposed to fossil fuel, energy. A key value of energy from renewable resources
being purchased is the "renewableness" of the energy. The Environmental
Attributes of the energy that give it the unique characteristic of being "renewable"
can be separated from the energy itself and traded by defining what is called a
"green tag," "renewable energy certificate," "renewable energy credit," "green
attibute," or "tradable renewable energy credits."
Why are you providing testimony on the issue of Environmental Attribute
ownership as it pertains to QFs?
The Company understands that the Commission may elect to address
environmental attibute ownership in conjunction with this Case.
What is Rocky Mountain Power's recommendation on Environment
Attribute ownership as it pertains to Environmental Attributes generated by
QFs?
Environmental Attbutes generated by a QF project should go to the utilty
whenever that QF sells energy to the utility and receives compensation for that
energy at approved avoided cost rates.
How is the Company's recommendation supported by the intent ofPURPA?
Section 210 of PURP A requires utilities to buy power from generation fueled by
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specific resources (biomass, solar, wind, waste, and geothermal) or in specific
configuations (e.g., cogeneration). If those generators were not powered by those
specific resources, the utilities would not be required to purchase that energy
under PUR A. Furthermore, the meters between the QF and the utilty's system
have always shown the energy from that renewable resource flowing to the utility.
Does Rocky Mountain contend it could be paying above avoided cost for
Environmental Attributes if it were required to pay a QF separately for such
Environmental Attributes?
Yes. It is the Company's position that if Rocky Mountain Power were to pay a QF
separately for the Environmental Attribute, Rocky Mountain Power and its
customers would in effect be paying twice for that attbute and thus pay above
avoided cost.
Please further explain your position.
PURP A contains no requirement that a purchasing utility pay twice for what it has
already bought. PURP A requires that utilities purchase from QFs, and QFs are
afforded that designation because of fuel use or effciency criteria. A utility must
purchase from a QF that is also an eligible renewable energy resource because of
the generation's Environmental Attributes. Without these characteristics, the
generator would not be able to require the utilty to purchase its energy at alL. In
other words, it is only by virte of the existence of the Environmental Attbutes
that facilities are deemed QFs and utilities become obligated to purchase their
power. In the case of eligible renewable energy resource QFs, these
Environmental Attbutes are the essence of the requirements to purchase the
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output, and is therefore part of what the utility is buying with the payment of
avoided costs. If Rocky Mountain Power does not get the QF Environmental
Attbute, it is not receiving the very characteristic that enabled the facilty to
achieve its QF status, and which thereby trggered the utility's obligation to
purchase the output from the facilty.
If the utilty is in fact buying energy from a differentiated renewable
resource, can that resource truly sell its Environmental Attributes to third
parties?
Although some QFs do purort to sell Environmental Attbutes to third parties,
any such sale is defective for the following reasons:
(1) a core aspect of the Environmental Attbutes is the exclusive right to
claim to have purchased generation from a particular renewable resource
gènerating facility;
(2) pursuant to a QF contract, the utilty agrees to buy energy from a
particular renewable resource generating facility (as opposed to
undifferentiated energy in bulk at a market delivery point); and
(3) since the utilty is buying the energy from that particular facilty, no
one else can trthfully claim to be doing so.
Irrespective of PUR A, double-counting of renewable generation is false
advertising at best and fraud at worst. Simply because one attibute of what has
always been sold pursuant to PURP A contracts subsequently acquires a separate
market value does not mean that particular attbute now warants separate
compensation, just as it does not mean that the attibute has been, or is being,
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transferred without consideration. A purchasing utilty under a QF contract is not
buying undifferentiated energy from the grid; it is buying energy that is very
paricularly differentiated to such an extent that the utilty is required by law to
buy it at the special price known as "avoided cost". Under PURA, the utility has
the obligation of purchasing energy from a differentiated resource at the utilty's
avoided cost. Absent utilty ownership of all the differentiated resource's
attibutes, the utility is paying higher than its tre avoided cost.
What conclusion can you draw from your analysis of the intent of PURPA
and how it applies to the issue of Environmental Attribute ownership in QF
contracts?
In terms of PURP A, any power purchase agreement securng power from an
eligible renewable energy resource should therefore credit the associated
Environmental Attibutes to the purchasing utility.
Does this conclude your direct testimony?
Yes.
Clements, Di - 10
Rocky Mountain Power
Case No. GNR-E-11-03
Exhibit No. 202
Witness: Paul H. Clements
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
ROCKY MOUNTAI POWER
Exhibit Accompanying Direct Testimony of Paul H. Clements
January 2012
~~OUNTAIN Rocky Mountain Power
Exhibit 202 Page 1 of 7
Case No. GNR-E-11-03
Witness: Paul H. Clements
I.P.U.C. No.1 Original Sheet No. 38.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 38
STATE OF IDAHO
Avoided Cost Purchases from Non-Standard Qualifying Facilties
Available
To owners of Qulifying Facilties ("QF") in all terrtoiy served by the Company in the State ofIdao.
Applicable
To owners of existing or proposed QFs who desire to make sales to the Company and who: (I) have
a design capacity greater than 1,000 kW and a historic or projected annual capacity factor of seventy
percent or below, or (2) have an average monthly capacity and associated energy of greater than
10,000 kW and a historic or projected annual capacity factor of greater than seventy percent. Such
owners shall be required to enter into wrtten power purchase and interconnection agreements with
the Company pursuant to the procedures set forth below. Additional or different requirements may
apply to Idaho QFs seeking to make sales to third-parties or out-of-system QFs seeking to wheel
power to Idaho for sale to the Company.
I. Process For Negotiating Power Purchase Agreements
A. Communications,
Unless otherwse directed by the Company, all communications to the Company
regarding QF power purchase agreements shall be directed in wrting, by mail, as
follows:
Rocky Mountain Power
Manager - QF Contracts
825 NE Multnomah St, Suite 600
Portland, Oregon 97232
Any requirement for wrtten notice in this tariff shall be via mail unless the parties
agree by mutual consent to an alternative form. The Company shall respond to all
such communications in a timely manner as more fully described below.
(Continued)
Submitted Under Case No. GNR-E-II-03
ISSUED: Januaiy 31, 2012 EFFECTIVE:
~~~OUNTAIN Rocky Mountain Power
Exhibit 202 Page 2 of 7
Case No. GNR-E-11-03
Witness: Paul H. Clements
I.P.U.C. No.1 Original Sheet No. 38.2
ELECTRIC SERVICE SCHEDULE NO. 38 - Continued
I.A.Communications (continued)
If the Company is unable to respond on the basis of incomplete or missing information from
the QF owner, the Company shall indicate what additional information is required.
Thereafter, the Company shall respond in a timely manner following receipt of all required
information as more fully described below.
B. Procedures
1. Examples of the Company's tyical generic power purchase agreement may be
obtained from the Company's website at \v"\vw.pacificorp.com, or if the owner is
unable to obtain it from the website, the Company shall send a copy via mail within
seven calenda days of a written request directed to the address in Par 1. A.
2. To obtain an indicative pricing proposal with respect to a proposed Project, the
owner shall provide in wrting to the Company, general project information
reasonably required for the development of indicative pricing. A Project is defined
as an existing or proposed QF that desires to make sales to the Company and that
can satisfy the requirements of Schedule 38. General project information shall
include, but not be limted to:
a) generation technology and other related technology applicable to the site;
b) design capacity (MW), station service requirements, and net amount of power to
be delivered to the Company's electrc system;
c) quantity and timg of monthly power deliveries (including Project abilty to
respond to dispatch orders from the Company);
d) proposed site location and electrcal interconnection point;
e) proposed on-line date (date on which deliveries of energy wil commence) and
outstanding permtting requirements;
f) demonstration of abilty to obtain QF status;
g) fuel tye(s) and source(s);
h) plans for fuel and transportation agreements, includig plans for what part or
paries wil pay transmission costs;
i) proposed contract term and pricing provisions (i.e., fixed, escalating, indexed);
and,
j) status of interconnection arangements.
(Continued)
Submitted Under Case No. GNR-E-ll-03
ISSUED: January 31, 2012 EFFECTIVE:
.,~. ..R..OCKY MOUNTAIN
POWER
A DIVSION Of PACFICP
Rocky Mountain Power
Exhibit 202 Page 3 of 7
Case No. GNR-E-11-03
Witness: Paul H. Clements
I.P.V.C. No.1 Original Sheet No. 38.3
ELECTRIC SERVICE SCHEDULE NO. 38 - Continued
I.B.Procedures (continued)
3. The Company shall not be obligated to provide an indicative pricing proposal until
all information described in Paragrph 2 has been received in wrting from the QF
owner. Within 30 calenda days following receipt of all information required in
Paragraph 2, the Company shall provide the owner with an indicative pricing
proposal, which may include other indicative terms and conditions, tailored to the
individual characteristics of the proposed Project. Such proposal maybe used by
the owner to make determnations regarding Project planning, financing and
feasibility. However, such prices are rnere1y indicative and are not filial and
binding. Prices and other terms and conditions are only fmal and binding to the
extent contained in a power purchase agreement executed by both parties and
accepted for fiing by the Idaho Public Utilties Commssion. Upon request, the
Company shall provide with the indicative prices a description of the methodology
used to develop the prices.
4. If the owner desires to proceed with the Project after reviewing the Company's
indicative proposal, it shall request in writing that the Company prepare a draft
power purchase agreement to serve as the basis for negotiations between the partes.
In connection with such request, the owner shall provide the Company with any
additional Project information that the Company reasonably determnes to be
necessary for the preparation of a draft power purchase agreement, which may
include, but shall not be limted to:
a) updated information of the categories described in Paragraph B.2;
b) evidence of adequate control of proposed site;
c) identification of, and timelines for obtaining any necessar governental
permts, approvals or authoriations;
d) assurance of fuel supply or motive force;
e) anticipated timelines for completion of key Project milestones; and,
f) evidence that any necessary interconnection studies have been completed and
assurance that the necessary interconnection arrangements are being made in
accordance with Part II.
(Continued)
Submitted Under Case No. GNR-E-l 1-03
ISSUED: January 31, 2012 EFFECTIVE:
ROCKY MOUNTAIN
POWER
A OlVSION Of PACIFICRP
Rocky Mountain Power
Exhibit 202 Page 4 of 7
Case No. GNR-E-11-03
Witness: Paul H. Clements
I.P.U.C. No.1 Original Sheet No. 38.4
ELECTRIC SERVICE SCHEDULE NO. 38 - Continued
I.B.Procedures (continued)
5. The Company shall not be obligated to provide the owner wíth a draft power
purchase agreement untí1 all ínformatíon requíred pursuant to Paragraph 4 has been
receíved by the Company in wrting. Wíthin 45 calenda days followíng receípt of
all informatíon required pursuant to Paragraph 4, the Company shall províde the
owner wíth a draft power purchase agreement containíng a comprehensíve set of
proposed terms and condítíons, includig a specífic pricing proposal for purchases
from the Project. Such draft shall serve as the basís for subsequent negotíatíons
between the paríes and, unless clearly índícated, shall not be constred as a binding
proposal by the Company.
6. After revíewing the draft power purchase agreement, the owner shall prepare an
initíal set of wrítten comments and proposals regarding the draft power purchase
agreernent and shall províde such comments and proposals, or notíce that ít has
none, to the Company. The Company shall not be oblígated to commence
negotíatíons wíth a QF owner untí1 the Company has receíved an inítíal set of
wrítten comments and proposals from the QF owner. Followíng the Company's
receípt of such comments and proposals, the owner shall contact the Company to
schedule contract negotíatíons at such times and places as are mutully agreeable to
the parties. Inconnectíon wíth such negotiatíons, the Company:
a) shall not unreasonably delay negotiatíons and shall respond ín good
faíth to any addítíons, deletíons or rnodíficatíons to the draft power
purchase agreement that are proposed by the owner;
b) rnay request to vísít the síte of the proposed Project íf such a vísít has
not prevíously occured;
c) shall update its pricing proposals at appropriate intervals to
accommodate any changes to the Company's avoíded-cost calculatíons,
the proposed Project or proposed terms of the draft power purchase
agreement;
d) may request any additional informatíon from the owner. necessar to
finalíze the terms of the power purchase agreement and satísfy the
Company's due diligence wíth respect to the Project; and,
e) shall resolve disputes related to power purchase agreement terms
consístent wíth Part II of thís tarff.
(Continued)
Submítted Under Case No. GNR-E-I 1-03
ISSUED: January 31, 2012 EFFECTIVE:
~~:OUNTAIN Rocky Mountain Power
Exhibit 202 Page 5 of 7
Case No. GNR-E-11-03
Witness: Paul H. Clements
I.P.U.C. No.1 Original Sheet No. 38.5
ELECTRIC SERVICE SCHEDULE NO. 38 - Continued
I.B.Procedures (continued)
7. When both parties are in full agreement as to all terms and conditions of the draft
power purchase agreement, the Company shall prepare and forward to the owner
within 45 calendar days a final, executable version of the agreement. The Company
reserves the right to condition execution of the power purchase agreement upon
simultaeous execution of an interconnection agreement between the owner and the
Company's power delivery fuction, as discussed in Part II. Prices and other terms
and conditions in the power purchase agreement shall not be fial and binding until
the power purchase agreement has been executed by both paries and the Idaho
Public Utilties Commssion accepts the agreement for fiing.
II. Process for Negotiating Interconnection Agreements
In addition to negotiating a power purchase agreement, QFs intending to make sales to the
Company are also required to enter into an interconnection agreement that governs the
physical interconnection of the Project to the Company's transmission or distrbution
system. The Company's obligation to make purchases from a QF is conditioned upon the
consumation of all necessar interconnection arrangements.
It is recommended that the owner initiate its request for interconnection as early in the
planning process as possible, to ensure that necessar interconnection arrangements proceed
in a timely manner on a parallel track with negotiation of the power purchase agreement.
Because of fuctional separation requirements mandated by the Federal Energy Regulatory
Commssion, interconnection and power purchase agreements are handled by different
fuctions within the Company. Interconnection agreements (both transmission and
distribution level voltages) are handled by the Company's power delivery fuction.
(Continued)
Submitted Under Case No. GNR-E-II-03
ISSUED: January 31, 2012 EFFECTIVE:
~~~OUNTAIN Rocky Mountain Power
Exhibit 202 Page 6 of 7
Case No. GNR-E-11-03
Witness: Paul H. Clements
I.P.U.C. No.1 Original Sheet No. 38.6
ELECTRIC SERVICE SCHEDULE NO. 38 - Continued
II.A.Communications
Initial communications regarding interconnection agreements should be directed to
the Company in writing as follows:
PacifiCorp Transmission
Transmission Account Management
825 NE Multnomah St, Suite 1600
Portland, Oregon 97232
Based on the Project size and other characteristics, the Company shall direct the QF
owner to the appropriate individual within the Company's power delivery fuction
responsible for negotiating the interconnection agreement with the QF owner.
Thereafter, the QF owner should direct all communications regardig
interconnection agreements to the desigiated individual, with a copy of any written
communications to the address set fort above.
B. Procedures
Generally, the interconnection process involves (1) intiating a request for
interconnection, (2) completion of studies to determe the system impacts
associated with the interconnection and the design, cost, and schedules for
constrcting any necessar interconnection facilities, (3) execution of an
Interconnection Facilities Agreernent to address facility constrction, testing and
acceptance, and (4) execution of an Interconnection Operation and Maintenance
Agreement to address ownership and operation and maintenance issues.
For interconnections impacting the Company's Transmission System, the Company
shall process the interconnection application through PacifiCorp Transmission
Services following the procedures for studying the generation interconnection
described in the latest version of the Company's Open Access Transmission Tariff,
PacifiCorp FERC Electric Tariff, Volume No. 11 Pro Forma Open Access
Transmission Tariff (OATT) on file with the Federal Energy Regulatory
Commssion. A copy of the OATT is available on-line at:
htt//ww.oasis.pacificorp.com
For interconnections impacting the Company's Distrbution System only, the
Company wil process the interconnection application through the Manager - QF
Contracts at the address shown in Part i. A.
(Continued)
Submitted Under Case No. GNR-E-II-03
ISSUED: January 31, 2012 EFFECTIVE:
ROCKY MOUNTAIN
.POWER
Rocky Mountain Power
Exhibit 202 Page 7 of 7
Case No. GNR-E-11-03
Witness: Paul H. Clements
A DiVSION OF f'ACIFICORf'
I.P.U.C. No.1 Original Sheet No. 38.7
ELECTRIC SERVICE SCHEDULE NO. 38 - Continued
III. Process for Filng a Complaint with the Commission on Contract Terms
Before filing a complaint with the Idaho Public Utilties Commssion on any specific power
purchase agreement term not agreed upon between the counterpar and the Company, a
counterpart must wait 60 calendar days from the date it notifies the Company in wrting
that it canot reach agreement on a specific term. This includes but is not limted to any
disputes that are not resolved through the procedures set fort in Part i. B. 6.
Submitted Under Case No. GNR-E-l 1-03
ISSUED: January 31, 2012 EFFECTIVE:
Idaho Public Utilties Commssion
Janua 31, 2012
Page 2
Informal inquires may be directed to Ted Weston, Idaho Reguatory Manager at (801) 220-
2963.
Sincerely,~f(~/~
Jeffrey K. Larsen
Vice President, Reguation
Cc: GNR-E-11-03 Service List
CERTIFICATE OF SERVICE
I hereby certify that on ths 31 st day of Janua, 2012, I caused to be served, via E-mail, a
tre and correct copy of Rocky Mountan Power's Testimony & Exhbits in Case No.
GNR - E-11-03 to the followig:
Donovan E. Waler
Lisa D. Nordstrom
Idaho Power Company
POBox 70
Boise, ID 83707-0070
E-mail: dwalker(ßidahopower.com
lnordstrom(ßidahopower .com
Danel Solander
PacifiCorp dba Rocky Mounta Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
E-mail: daneL.solander(ßpacificorp.com
Donald L. Howell, II
Krstine A. Sasser
Deputy Attorneys General
IdahQ Public Utilities Commssion
472 W. Washington
PO Box 83720
Boise, ID 83720-0074
E-mail: don.howell(ßuc.idaho.gov
kris.sasser(ßpuc.idaho.gov
Robert D. Kah
Nortwest and Intermounta Power
Producers Coalition
1117 Minor Ave., Suite 300
Seattle, W A 9810 1
E-mail: rkah(ßnippc.org
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Sprigs, CA 92241
E-mail: robertpau108(ßgmail.com
Michael G. Andrea
A vista Corpration
1411 E. Mission Ave.
Spokae, W A 99202
E-mail: michael.andrea(ßavistacorp.com
Ken Kaufman (E-mail Only)
Lovinger Kaufan, LLP
825 NE Multnomah, Suite 925
Portland, OR 97232
E-mail: Kaufman(ßlk1aw.com
Peter J. Richardson
Gregory M. Adams
Richardson & 0' Lear, PLLC
PO Box 7218
Boise, ID 83702
E-mail: peter(ßrichardsonandolear.com
gregaYrichardsonandoleary.com
Don Stuvant
Energy Dirctor
J.R. Simplot Company
PO Box 27
Boise, ID 83707-0027
E-mail: don.stuevant(ßsimplot.com
James Carkuis
Managig Member
Exergy Development Group of Idao, LLC
802 W. Banock St., Suite 120Ò
Boise, ID 83702
E-mail: jcarkulis(ßexergydevelopment.com
Ronald L. Willams
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise il, 83702
E-mail: ron(iwiliamsbradbur.com
JohnR. Lowe
Consultat to Renewable Energy Coalition
12050 SW Tremont St.
Portland, OR 97225
E-mail: jravenesanmarcos(iyahoo.com
Bil Piske, Manager
Interconnect Solar Development, LLC
1303 E. Carer
Boise, ID 83706
E-mail: bilpiske(icableone.net
Benjamin J. Oto
Idao Conservation League
710 N. Sixth Street (83702)
POBox 844
Boise, ID 83701
E-mail: botto(iidahoconservation.org
Shelley M. Davis
Barker Rosholt & Simpson, LLP
1010 W. Jefferson St. (83702)
PO Box 2139
Boise, il 83701
E-mail: smd(iidahowaters.com
Ted Diehl
General Manager
Nort Side Canal Company
921 N. Lincoln St.
Jerome, il 83338
E-mail: nscanal(icableone.net
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11 tl East
Idaho Falls, ID 83404
E-mail: ted(itsorenson.net
Thomas H. Nelson
Attorney
PO Box 1211
Welches, OR 97067- 1211
E-mail: nelson(ithnelson.com
R. Greg Ferney
Mimur Law Offices, PLLC
2176 E. Frain Rd., Suite 120
Meridian, ID 83642
E-mail: greg(imimuralaw.com
Dean J. Miler
McDevitt & Miler, LLP
PO Box 2564
Boise, ID 83701
E-mail: joe(imcdevitt-miler.com
Wade Thomas
General Counsel
Dynams Energy, LLC
776 W. Riverside Dr., Suite 15
Eagle, ID 83616
E-mail: wtomas(idynamisenergy.com
Brian Olmstead
General Manager
Twi Falls Can Company
PO Box 326
Twin Falls, ID 83303
E-mail: olmstead(itfcanaL.com
Bil Brown, Chair
Board of Commissioners
of Adams County, il
PO Box 48
Council, il 83612
E-mail: bdbrown(ifrontiernet.net
Glenn Ikemoto
Margaret Rueger
Idaho Windfars, LLC
672 Blai Avenue
Piedmont, CA 94611
E-mail: glenn(ienvisionwind.com
Margaret(ienvisionwind.com
M.J. Humphres
Blue Ribbon Energy LLC
4515 S. Amon Road
Amon, ID 83406
E-mail: blueribbonenergy(ßgmail.com
Gar Seifert
Kur Myers
Idaho National Laboratory
Conventional Renewable Energy Group
2525 Fremont Ave
Idaho Falls, ID 83415-3810
E-mail: gary.seifert(ßinl.gov
Kur.myers(ßinl.gov
Megan Walseth Decker
Senior Sta Counsel
Renewable Nortwest Project
917 SW Oak Street, Suite 303
Portland, OR 97205
E-mail: megan(ßmp.org
Aron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 Eat
Sandy, UT 84070
E-mail: arronesq(ßaol.com
Ken Miler
Snake River Alliance
PO Box 1731
Boise, ID 83701
E-mail: kmiler(ßsnakeriveralliance.org
Mar Lewallen
Clearater Paper Corporation
601 W. Riverside Ave., Suite 1100
Spokane, W A 99201
Mar .lewallen(ßclearaterpaper .com
Gw~.i~Care Meyer~
Coordinator, Admstrative Services