20160113Application.pdf

ROCKY MOUNTAIN
FOWER
A DIVISION OF FACIFICORP 1407 W . North Temple, Suite 310
Salt Lake City, Utah 84116
January 13,2016
VA OWRNIGHT DELIVERY
Jean D. Jewell ldaho public Utilities commissionCommission Secretary Office ol lhe SecretaryIdahoPublicutilitiesCommission RECEIVED
472w. washington JAN I 3 2016Boise,lD 83702
Attention: Jean D. Jewell Boise' ldaho
Commission Secretary
RE: CASE NO. PAC-E-16-01
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF ELECTRIC SERVICE SCHEDULE NO.38 QUALIFYING FACILITY
AVOIDED COST PROCEDURES
Please find enclosed for filing an original and nine copies of Rocky Mountain Power's
Application in the above-referenced matter, along with nine copies of the direct testimony and
exhibit. Also enclosed is a CD containing the Application, testimony and exhibit.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (S0l) 220-
2963.
Very truly yours,
J *1,t ry P U,t tt-,-,-/ a-,--
Jeffrey K. Larsen
Vice President, Regulation
Yvonne Hogle (ISB# 8930)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
Fax: [phone]
Email : Yvonne.Hogle@Pacifi Corp. com
Attorneyfor Roclcy Mountain Power
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNTAIN POWER FOR APPROVAL
OF ELECTRIC SERVICE SCHEDULE
NO. 38 - QUALIFYING FACILITY
AVOIDED COST PROCEDURES
ldaho Public Utilities Commission
Office of the SecretarvRECEIVED
JAN I 3 20t6
Boise, ldaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.16.O1
APPLICATION
Rocky Mountain Power, a division of PacifiCorp ("Company" or "Rocky Mountain
Power"), in accordance with Idaho Code $ 61-503 and RP 52, hereby respectfully petitions
the Idaho Public Utilities Commission ("Commission") for an order authorizing Rocky
Mountain Power to implement a new Electric Service Schedule No. 38 - Qualified Facility
Avoided Cost Procedures, to govern the Company's negotiating practices and queue
management related to power purchase agreements ("PPA") executed pursuant to the Public
Utility Regulatory Policies Act of 1978 ("PURPA"). Rocky Mountain Power requests that
the Commission issue an order approving this application ("Application") by April l, 2016.
In support of this Application, Rocky Mountain Power represents as follows:
INTRODUCTION AND BACKGROUND
On February 27,2015, the Company petitioned the Commission in Case No. PAC-E-
15-03 for approval to modify (1) terms and conditions related to PURPA PPAs and (2) the
Integrated Resource Plan ("IRP") Avoided Cost methodology. Commission Order No. 33357
directed the Company to "file a tariff schedule...which outlines its PURPA negotiating
process."l The Commission indicated that the "schedule should include specific criteria for
management of the queue to eliminate uncertainty and to facilitate negotiations between
Rocky Mountain and QFs."' The Company is filing the Application with supporting
testimony and its proposed Electric Service Schedule No. 38 - Qualifying Facility Avoided
Cost Procedures (Schedule 38") in compliance with Order No. 33357.
The PURPA negotiating practices and queue management procedures contained in
Schedule 38 include contracting processes and queue management for projects that don't
qualift for published rates in Idaho, will provide fair pricing, and will more accurately reflect
the Company's avoided costs.
II. ELECTRIC SERVICE SCHEDULE NO.38
The purpose of Schedule 38 is to efficiently provide the steps and schedule for both
the Company and developers that will govem the determination of indicative avoided cost
pricing for a proposed QF project. 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.
I Case No. PAC-E- 15-03 , p. 28, ll. 24-27 .
2 Id.
QF developers that timely provide the required information regarding their projects
will likely avoid delays in the development of indicative prices. The Company will work
closely with developers to complete the due diligence and provide feedback on the requested
information. Once the developer provides all the necessary information consistent with
Schedule 38, the Company will be able to prepare and provide indicative prices to the
developer. As set forth by the tariff, the Company and the developer will subsequently follow
the timelines and process for completing the negotiation of a PPA.
As set forth in more detail in the supporting testimony of Mr. Kyle T. Moore, Section
I of Schedule 38 summarizes the process for negotiating a PPA with the Company including:
o contact information;
. procedures to request a pro forma contract and indicative pricing;
o notification of completeness of the request and queue position; and
o timelines related to the delivery of and edits to draft PPAs.
Section II provides information on the process for negotiating a transmission
interconnection agreement. Section III provides information regarding the process to be used
if the parties are unable to resolve an issue. The supporting testimony of Mr. Moore sets forth
additional details related to Schedule 38 including specific response times to which the
Company will adhere once the developer has provided specific information and other
deadlines related to the completion of draft PPAs.
III. MODIFIED PROCEDURE
Rocky Mountain Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed under
Modified Procedure, i.e., by written submissions rather than by hearing in accordance
with RP 201 et seq.lf, however, the Commission determines that a technical hearing is
required, the Company stands ready to present its Application and Mr. Moore's testimony
in such hearing.
IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
Communications regarding this Application should be addressed to:
Ted Weston
Rocky Mountain Power
Idaho Regulatory Affairs Manager
1407 W. North Temple, Suite 330
Salt Lake City UT 84116
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Yvonne R. Hogle
Rocky Mountain Power
Asst. General Counsel
1407 W. North Temple, Suite 320
salt Lake city uT 84116
Telephone: [phone]
Facsimile: [phone]
E-mail : wonne.ho gle@pacifi com.com
In addition, Rocky Mountain Power respectfully requests that all data requests
regarding this maffer be addressed to:
By e-mail (prefened): datarequest@.pacificorp.com
By regular mail:
PacifiCorp
Data Request Response Center
825 NE Multnomah, Suite 2000
Portland, OR 97232
Informal inquires also may be directed to Ted Weston at [phone].
4
v. REQUEST FOR RELTEF
Rocky Mountain Power respectfully requests that the Commission issue
authorizing: (l) this matter to be processed by Modified Procedure, (2) Rocky
Power to implement Schedule 38, Qualified Facility Avoided Cost Procedures,
an Order
Mountain
Respectfully submitted this 13e day of January, 2016.
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
Salt Lake Ciry, Utah 841l6
Telephone: [phone]
Fax: [phone]
Email : Yvonne.Hogle@Pacifi Corp.com
Attorneyfor RoclE Mountain Power