20150316Comments.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF THE FIRST
AMENDMENT TO A POWER PURCHASE
AGREEMENT WITH ST. ANTHONY HYDRO,
LLC.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E.15.02
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Daphne Huang, Deputy Attorney General, and in response to the Notice of
Application and Notice Modified Procedure issued in Order No. 33236 on February 25,2015, in
Case No. PAC-E-15-02, submits the following comments.
BACKGROUND
On February 13,2015, PacifiCorp dba Rocky Mountain Power (the Company) filed an
Application asking the Commission to approve the First Amendment to the Power Purchase
Agreement (PPA) between the Company and St. Anthony Hydro, LLC (together, the Parties). The
Commission originally approved the PPA on July 31,2013. Order No. 32865. St. Anthony Hydro
operates the hydroelectric facility (the Facility) in St. Anthony, Idaho, generating electric power
with a capacity rating of 700 kilowatts. Application at 2.
STAFF COMMENTS MARCH 16,2015
The Parties entered into the First Amendment to the PPA on January 13,2015. In that
Amendment, the Parties agree that icing, when within the immediate water source and used as the
primary motive for a reduction in energy production, is a force majeure event. Application at 2.
The Parties also agree to changes in scheduling power delivery. Id.
STAFF ANALYSIS
Staff has reviewed the Amendment to the PPA and believes that it is reasonable to add
icing as a force majeure event. The Facility is located in an area subject to extreme weather, and
icing outages are beyond the control of the Project owner.
The changes in the power delivery schedule were first proposed by Idaho Power and
approved by the Commission in the Little Wood River Ranch II Project (see Case No. IPC-E-14-
06), and have been applied to all other new hydro projects since then. Given the fact that the St.
Anthony project has only been in operation for a few months, Staff recommends applying the
same changes in schedule to this project, even though the old schedules in the original Power
Purchase Agreement were approved earlier.
RECOMMENDATIONS
Staff recommends approval of Pacificorp's First Amendment to the Power Purchase
Agreement with St. Anthony Hydro as proposed.
Respecttully submitted this I 612 day of March 2015.
Technical Staff: Yao Yin
i :umisc:comments/pace I 5.2djhrpsyy comments
Deputy Attomey General
STAFF COMMENTS MARCH 16,2OI5
I HEREBY CERTIFY
SERVED THE FOREGOING
CASE NO. PAC-E.I5-02, BY
TO THE FOLLOWING:
BRUCE GRISWOLD
PACIFICORP
825 NE MULTNOMAH
STE 18OO
PORTLAND OR 97232
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. com
CERTIFICATE OF SERVICE
THAT I HAVE THIS 16th DAY OF MARCH 2015,
COMMENTS OF THE COMMISSION STAFF, IN
MAILING A COPY THEREOF, POSTAGE PREPAID,
DANIEL E SOLANDER
TED WESTON
ROCKY MOUNTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
CERTIFICATE OF SERVICE