20160222Reply Comments.pdf

ROCKY MOUNTAIN
BSS,EF"",,
RECEIVED
2016 FEB 22 fii\{ 9: 52
I ..1 i -r
:'I' i | ,-ji;r,;lijSiON
1407W. North Temple, Suite 310
Salt Lake City, Utah 84116
February 19,2016
WA ELECTRONIC DELIWRY
AND OVERNIGHT DELIWRY
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702
Attention: Jean D. Jewell
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
Rocky Mountain Power respectfully files reply comments in response to Staff s request for
clarification on the Application in the above-referenced matter.
All references to days in Electric Service Schedule No. 38 - Qualifying Facility Avoided Cost
Procedures are referencing calendar days. Also provided are clean and legislative copies of
Electric Service Schedule No. 38 incorporating that clarification on Tariff Sheet No. 38.2.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
tL .4-a,ur^r! c**-,
Vice President, Regulation
Jeffrey K. LarYen
Yvonne Hogle (ISB# 8930)
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: (801 ) 220-4050
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 - QUALTFYTNG FACILITY
AVOIDED COST PROCEDURES
NICIIVED
iii6 ruD 2A f,,}{ g: 53
l-l I ii..i, : :" l:i (,iJ:,Li,i lSSl0l'{
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-16-01
REPLY COMMENTS
Rocky Mountain Power, a division of PacifiCorp ("Company" or "Rocky Mountain Power"),
hereby respectfully files reply comments with the Idaho Public Utilities Commission
("Commission") in the above referenced matter. [n support of these comments, Rocky Mountain
Power represents as follows:
REPLY COMMENTS
On January 13,2016, the Company filed an Application with the Commission requesting
approval of Electric Service Schedule No. 38 - Qualified Facility Avoided Cost Procedures. On
February 12,2016, Staff for the Idaho Public Utilities Commission filed comments recommending
that the Commission approve the Company's Application stating: "Sta|f believes that Roclcy
Mountain Power's Application to implement Schedule 38 is reasonable and necessary to ensure a
clear, standard QF contracting procedure. "
Staff also recommended that the Company clarify whether "days" in the proposed tariff
referred to calendar days or business days. tt was the Company's intent that any reference to days in
Electric Service Schedule No. 38 was meant to refer to calendar days. The Company as part of these
reply comments has provided clean and legislative copies of the Tariff Sheet No. 38.2 with this
clarification.
REQUEST FOR RELIEF
With this clarification Rocky Mountain Power respectfully requests that the Commission
approve Electric Service Schedule No. 38 - Qualified Facility Avoided Cost Procedures, as filed.
Respectfully submitted this lgth day of February,20l6.
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
Salt Lake city, utah 84116
Telephone: (80 I ) 220-4050
Fax: [phone]
Ema[f : [e-mail]
Attorneyfor Rocley Mountain Power
-ROCKYMOUNTAIN(PO\Ii ER
\ A dusrq{ oF FtaoFGonP
I.P.U.C. No.1 Original Sheet No. 38.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCIIEDULE NO.38
STATE OF IDAHO
Quali$ing Facility Avoided Cost Procedures
PREFACE:l. The process outlined in this Schedule is typically applicable to projects already
under development.
2. All submissions, responses and notices required in this Schedule must be done in
electronic or hard copy format. Requests and information may be submitted to the
Company at [e-mail] .
3. The QF pricing queue referenced in this Schedule is independent of and unrelated to
the interconnection and transmission services queue maintained and administered by
PacifiCorp Transmission Services pursuant to PacifiCorp Transmission Service's
FERC approved Open Access Transmission Tariff (OATT), as posted on its Open
Access Same-Time Information System (OASIS). The generation interconnection
process is a critical and lengthy process that typically must be well underway before
a power purchase agreement should be requested. QF Developers are strongly
encouraged to gain a clear understanding of the transmission interconnection process
and associated costs and timelines before requesting indicative pricing or a power
purchase agreement under this schedule.
4. The Company must use its reasonable commercial efforts to meet all Company
deadlines specified herein, and shall attempt to make up any Company delays in
meeting subsequent Company deadlines. QF Developer deadlines will be extended
to reflect Company delays beyond Company deadlines specified herein. Under
extenuating circumstances, the Company or a QF Developer may request an
extension of any deadlines from the Commission.
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
Po\TTIER
A Drvtsrofl OFi^clRCOfiP
I.P.U.C. No. I Original Sheet No.38.2
ELECTRIC SERYICE SCHEDULE NO.38 - Continued
PREFACE: (continued)
5. Subject to the specific tariff provisions provided below, the general timelines and
deadlines for actions or responses for Developers and the Company in this tariff are
summarized here for convenience, along with references to the relevant tariff
provisions, (all references to days in this tariff are calendar days):
a) Company must provide Developer illustrative, pro forma contract within seven
(7) days of request [Section t.B.l];
Developer may request indicative pricing at any time by submiuing required
information [Section I.B.2] ;
Company must notify Developer whether request for indicative pricing is
complete within seven (7) days of submission [Section I.8.3];
Company must provide indicative pricing within thirty (30) days of notice of
completeness [Section I.B.a] ;
Developer must request draft power purchase agreement and submit required
information within sixty (60) days of receipt of indicative pricing [Section I.B.5];
Company must notify Developer whether request for power purchase agreement
and required information is complete within seven (7) days of submission to the
Company [Section I.B.6];
Company must provide Developer with draft power purchase agreement within
thirty (30) days of notice of completeness [Section LB.6];
Developer must provide Company with initial comments on and proposed edits
to draft power purchase agreement within thirty (30) days of receipt [Section
r.B.7l;
Company must respond to Developer's initial comments and edits within thirty
(30) days of receipt, and commence negotiations over areas of disagreement
[Section I.B.8];
lndicative prices must be updated unless a PPA is executed within six (6) months
after indicative pricing was provided by the Company [Section I.8.9];
Company must complete all internal reviews and approvals within twenty-one
(21) days after agreement is reached on a proposed final version of a power
purchase agreement [Section I.8.8];
PPA must be executed within five (5) months after Developer's receipt of draft
power purchase agreement [Section I.B.l0];
Company must submit power purchase agreement to Commission for approval
within seven (7) days of execution [Section I.B.8]; and
Company must submit Transmission Service Request within seven (7) days after
execution of purchase power agreement [Section I.8.8].
b)
c)
d)
e)
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s)
h)
i)
k)
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Submitted Under Case No. PAC-E-16-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
V.ROCKYMOUNTAIN(Po\'YER
\ A oMSTON OF PACIHCOnP
I.P.U.C. No.1 Original Sheet No.38.3
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
PREFACE: (continued)
6. QF Developers should pay special attention to the fact that, as specified in the
tariff sections that follow, a QF project will typically be removed from the QF
pricing queue, and any indicative or proposed prices or agreements will no
longer be valid, upon occurrence of any of the following events:
a) Failure of the QF Developer to submit to the Company a request for a power
purchase agreement within sixty (60) days of its receipt of indicative pricing, as
specified in Section I.B.5;
b) Failure of the QF Developer to submit written comments and proposals within
thirty (30) days of its receipt of a proposed power purchase agreement, as
specified in Section 1.8.7;
c) Failure of the parties to execute a power purchase agreement within five (5)
months after a draft power purchase agreement was provided by the Company to
the QF Developer, as specified in Section I.8.10.e.; or
d) A material change in the point of interconnection, a change in design capacity of
more than llYq a change in generation technology, or a change of more than
three (3) months in the online date, as specified in Sections I.B.10.a.-d.
7. When a QF project is removed from the QF pricing queue, the developer may
request new indicative pricing and a new agreement by timely following all of
the steps outlined below, in which case it will be placed in the QF pricing queue
as a new project.
AVAILABILITY: To owners of Qualifying Facilities (QFs) in all territory served
by the Company in the state of Idaho.
APPLICATION: To owners of existing or proposed wind or solar QFs with a
design capacity greater than 100 kW, or Seasonal or Non-Seasonal Hydro projects and all
other projects greater than l0 a MW who desire to make sales to the Company and to QFs
who are not able to obtain pricing under the standard published rates. Such owners will be
required to enter into written 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.
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
a oMstot{ oF nAoFtcohP
I.P.U.C. No.l Original Sheet No. 38.4
L
ELECTRIC SERVICE SCHEDULE NO. 38 - Continued
Process For Negotiating Power Purchase Agreements
A. Communications
Unless otherwise directed by the Company, all communications to
the Company regarding QF power purchase agreements should be
directed in writing as follows:
Rocky Mountain Power
Manager - QF Contracts
825 NE Multnomah St, Suite 600
Portland, Oregon 97232
OFrequests@nac i fi corp. com
The Company will respond to all such communications in a timely manner. [f
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 will respond in a timely
manner following receipt of all required information.
B. Proceduresl. Request for Pro Forma Contract. The Company shall provide a QF
Developer with a pro forma power purchase agreement within seven (7)
days of its receipt of a request for the same. The pro forma document
provided (i) does not constitute an offer to enter into an agreement, (ii)
may include general proposed terms and conditions, and (iii) will not
include pricing or project specific information. Anyone who desires to
enter into a power purchase agreement with the Company must proceed
in accordance with this Schedule to request indicative pricing under
Section I.B.2, to request a proposed power purchase agreement under
Section I.B.5, and to negotiate and execute a power purchase agreement
that is executed by the Company and approved by the Commission.
2. Request for Indicative Pricing. To obtain indicative pricing with
respect to a proposed project, a QF Developer must provide to the
Company the following general project information:
a) A general description of the QF project and the QF Developer,
including email address and other contact information;
b) generation technology and other related technology applicable to the
site and for solar projects specify fixed ground mount or solar
tracking;
Submitted Under Case No. PAC-E-16-01
ISSUBD: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
a DMstOt{ Of AAOFTCOiP
I.P.U.C. No.1 Original Sheet No. 38.5
I.
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
B. Procedures (continued)
c) design capacity (MW), station service requirements, and net amount
of power to be delivered to the Company's electric system;
d) quantity and timing of monthly power deliveries (including project's
ability to respond to dispatch orders from the Company) and an
hourly generation profile (12X24 profile minimum, 8760 preferred)
in Excel or other spreadsheet format with all formulae intact, and the
expected generation degradation per yeff and whether the
degradation rate is calculated against the first year or against the prior
year, or a forecast ofannual generation for each contract year over the
life of the requested contract term;
proposed site location and electrical interconnection point;
proposed on-line date and outstanding permitting requirements;
demonstration of ability to obtain QF status (FERC Form 556);
fuel type(s) and source(s);
plans for fuel and transportation agreements (Motive force plans);
proposed length of contract term;
status of transmission interconnection arrangements including
interconnection queue number; andl) other information promptly and reasonably requested by the
Company.
3. Notice of Completeness and Queue Position. Within seven (7) days of its
receipt of a request for indicative pricing and supporting materials as
specified above, the Company shall confirm its receipt of the same and notify
the QF Developer whether the submission is substantially complete or if
additional information is required. The Company shall not be obligated to
provide indicative pricing until all information described in Paragraph I.B.2
has been received from the QF Developer. Indicative pricing will be
determined in light of other QF projects in the QF pricing queue ahead of the
project, and using inputs and procedures as approved by the Commission. A
QF will be added to the QF pricing queue as of the date the Company has
confirmed receipt of all project information required in Paragraph I.B.2 and
will retain its priority position in the QF pricing queue for purposes of
subsequent requests for indicative pricing unless and until removed from the
QF pricing queue as provided herein. The Company will notify the QF
Developer of the date its project was added to the QF pricing queue. Once a
QF Project has been added to the QF pricing queue, in the event additional
clarifying information is reasonably required by the Company in order to
calculate indicative prices, the deadlines in Section I.B.4 shall be extended
e)
0
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h)
i)
i)
k)
Submitted Under Case No. PAC-E-16-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
VROCKYMOUNTAINxrP0YER
\ A Druliloil of froFiconP
I.P.U.C. No.1 Original Sheet No. 38.6
ELECTRIC SERYICE SCHEDULE NO. 38 - Continued
on a day for day
provided.
the requested clariffing has been
B.Procedures (continued)
4. Indicative Pricing. Within thirty (30) days following the date a QF project was
added to the QF pricing queue under Section I.B.3, the Company shall provide
the QF Developer with indicative pricing, which may include other indicative
terms and conditions, tailored to the individual characteristics of the proposed
project.
An indicative pricing proposal provided by the Company may be used by the QF
Developer to make determinations regarding project planning, financing and
feasibility. However, such prices are indicative only and may be subject to
change by the Company as specified herein or by the Commission. Prices and
other terms and conditions are only final and binding to the extent contained in a
power purchase agreement executed by both parties and approved by the
Commission. The Commission may approve, reject or conditionally approve a
power purchase agreement and may at any time make changes to this Schedule,
QF pricing methods and inputs, or terms and conditions applicable to QF pricing
and power purchase agreements.
5. Request for Draft Power Purchase Agreement. If a QF Developer desires to
precede forward with the project it must, within sixty (60) days of its receipt of
indicative pricing, request that the Company prepare and submit for the
Developer's review a proposed power purchase agreement. Absent timely
submittal of such request, the project will be removed from the QF pricing queue
and the indicative prices will no longer be valid. [n connection with its request
for a power purchase agreement, the Developer must provide the Company with
the fo I lowing additional proj ect information :
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
vrRocKY MOUNTAIN(POWER
\ e uvrsror,r or PlctFrcoFP
I.P.U.C. No.1 Original Sheet No. 38.7
B.
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
Procedures (continued)
a) any available updates to the information specified in Paragraph I.B.2;
b) evidence ofadequate control ofproposed site;
c) identification of and timelines for obtainin g any necessary governmental
permits, approvals or authorizations;
assurance of fuel supply or motive force;
anticipated timelines for completion of key project milestones;
evidence that any necessary interconnection sfudies are underway and
that the necessary interconnection arrangements can timely be completed
in accordance with Part II sufficient for the project to reach energization
by the proposed on-line date;
g) information describing the developer/owner of the proposed project,
including name, address, and ownership organization chart; and
h) other information promptly and reasonably requested by the Company.
Notice of Completeness and Draft PPA. Within seven (7) days of its receipt of
a request for a power purchase agreement and the information specified in
Section I.B.5, the Company shall confirm its receipt of the same and notiff the
Developer whether any additional information is needed. The Company shall
provide the Developer with a proposed power purchase agreement within thirty
(30) days following the date of the Company's notice that the information
required in Paragraph I.8.5 has been received and is substantially complete. The
proposed power purchase agreement shall contain a comprehensive set of
proposed terms and conditions, including specific pricing based on the indicative
pricing provided, as adjusted if necessary in light of specifics of the project. The
proposed power purchase agreement will also specify project specific data and
exhibits that must be provided by the QF Developer prior to final approval or
execution of the PPA. The proposal submitted by the Company shall serve as the
basis for subsequent negotiations.
Developer's Initial Comments and Edits. Within thirty (30) days of receiving
a proposed power purchase agreement, the QF Developer shall prepare and
deliver to the Company an initial set of written comments and proposals, failing
which the Project will be removed from the QF pricing queue and the proposed
agreement and prices will no longer be valid.
Company's Response and Responsibilities. If the QF Developer's proposals
are not acceptable, the Company shall commence negotiations on all outstanding
areas of disagreement, and:
d)
e)
0
6.
7.
8.
Submitted Under Case No. PAC-E-16-01
ISSUED: January 13, 2016 EFFECTM: April 15,2016
J,ROCKYMOUNTAIN(pswEp
\ ewrsronorn^oFcoaP
I.P.U.C. No.1 Original Sheet No.38.8
B.
ELECTRIC SERYICE SCHEDULE NO.38 - Continued
Procedures (continued)
a) shall respond to the developer's initial comments and proposals within thirty
(30) days, and thereafter respond timely to subsequent comments and
proposals;
will not unreasonably delay negotiations and will respond in good faith to
any additions, deletions or modifications to the draft power purchase
agreement that are proposed by the QF Developer;
may request to visit the site of the proposed project if such a visit has not
previously occurred;
may request additional information from the Developer if reasonably
necessary to finalize the terms of the power purchase agteement and satisfy
the Company's due diligence with respect to the Project; and
e) shall submit to PacifiCorp Transmission Services a request for network
transmission service relating to the project within seven (7) days after
execution of a power purchase agreement, or otherwise as early as
practicable based on the applicable PacifiCorp Transmission Services tariff;
f) shall complete credit, legal, upper management and any other required
internal reviews of proposed terms and conditions within twenty-one (21)
days after agreement was reached on a proposed final version of a power
purchase agreement; and
g) shall submit a fully executed power purchase agreement to the Commission
for approval within seven (7) days of execution.
9. Required Pricing Update. The prices in the proposed power purchase
agreement provided by the Company under Section I.8.6 shall be recalculated by
the Company using the most rec.ent available pricing inputs and methods
approved by the Commission, but without a change in the QF project's pricing
queue priority, if the QF Developer and the Company have not executed a power
purchase agreement within six months after indicative pricing was provided by
the Company under Section I.B.4, except to the extent delays are caused by
Company actions or inactions, which may include delays in obtaining legal,
credit or upper management approval by the Company.
10. Removal from QF Pricing Queue. In addition to the circumstances desuibed
in I.B.5 and I.8.7, at any time during the process outlined in I.B.3 through I.B.9,
the Company shall remove a QF project from the QF pricing queue, and any
associated indicative prices, proposed prices or proposed agteement previously
provided will no longer be valid, if any of the following occurs with respect to a
QF project:
b)
c)
d)
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
a oMsrot{ oF moHconP
I.P.U.C. No. 1 Original Sheet No. 38.9
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
I. B. Procedures (continued)
a) A material change in the point of interconnection;
b) A change in design capacity of llYo or more of the original specified
design capacity;
c) A change in generation technology (i.e. solar, wind, thermal), including a
change between fixed tilt and tracking solar projects. Changes in the
quantity and timing of monthly power deliveries will not cause removal
from the QF pricing queue so long as the basic generation technology and
design capacity have not changed;
d) A change in the online date specified in the information provided under
Section I.B.2.f of more than three months earlier or later; or
e) A PPA has not been executed by both parties within five (5) months after
the draft PPA was provided by the Company to the Developer, except to
the extent delays are caused by Company actions or inactions.
11. Standard PPA Terms. Absent Commission approval to the contrary for
good cause shown, a power purchase agreement executed under this
Schedule shall include the following terms and conditions, among others:
a) The scheduled commercial operation date must not be greater than thirty
(30) months after the execution date of the power purchase agreement;
b) The QF Developer must sign a System Impact Study Agreement with
PacifiCorp Transmission (refer to Section 42.2 or Section 51.4 of
PacifiCorp's OATT) within 120 days of the date a Commission Order
approving the agreement has become final and non-appealable; and
c) The QF Developer must provide 100% of the project development
security within 30 days of the date a Commission Order approving the
PPA has become final and non-appealable.
U. 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 distribution
system. The Company's obligation to make purchases from a QF is conditioned upon all
necessary interconnection arrangements being consummated.
It is recommended that the owner initiate its request for interconnection as early in the
planning process as possible, to ensure that necessary interconnection arrangements proceed
in a timely manner on a parallel track with negotiation of the power purchase agreement.
Interconnection agreements (both transmission and distribution level voltages) are handled
by the Company's power delivery function, PacifiCorp Transmission Services.
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 15,2016
-ROCKYMOUNTAINKPolER\ A OrVrSrOr{ OF aAOFrcOAP
LP.U.C. No.1 Original Sheet No. 38.10
II.
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
Process for Negotiating Interconnection Agreements (continued)
A. Communications
Initial communications regarding interconnection agreements should be directed to
the Company in writing as follows:
Pacifi Corp Transmission Services
Interconnection Requests
825 NE Multnomah St, Suite 1600
Portland, Oregon 97232
OFrequests@pacifi com.com
B. Procedures
Generally, the interconnection process involves (l) initiating a request for
interconnection, (2) completion of studies to determine the system impacts
associated with the interconnection and the design, cost, and schedules for
constructing any necessary interconnection facilities, (3) execution of an
interconnection agreement.
The QF project owner is responsible for all interconnection costs assessed by the
Company on a nondiscriminatory basis.
For interconnections greater than twenty (20) megawatts, the Company will process
the interconnection application through PacifiCorp Transmission Services generally
following the procedures for studying the generation interconnection described in
the Company's Open Access Transmission Tariff, PacifiCorp FERC Electric Tariff,
Fifth Revised Volume No. I I Pro Forma Open Access Transmission Tariff (OATT),
as the same may be changed or updated, on file with the Federal Energy Regulatory
Commission (FERC). A copy of the OATT is available on-line at
http//www.oasi s.pacifi co(p.com.
The Company's interconnection forms and agreements, are provided electronically at the
following address: http://www.pacifi corp.com/tran/ts/gip/qf.html
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
Y
r.P.u.c.
ROCKY MOUNTAIN
POWER
A DMSIOIiI OF RASHCONP
No.1
ELECTRIC SERYICE SCHEDULE NO.38 - Continued
Process for Filing a Complaint with the Commission on Contract Terms
The Commission has both informal and formal dispute resolution processes which
can be reviewed on the Commission website at the following
address: http ://www.puc. idaho. gov/forms/consumerassistance
These processes are available for any matter as to which the Commission has
jurisdiction, which may include (i) QF PPA contracts, (ii) small QF interconnection
agreements (less than 20 MW), and (iii) large QF interconnection agreements (more
than}} MW), so long as all of the QF output is sold exclusively to the Company. To
the extent any portion of the QF output is sold to anyone other than the Company, a
QF generation interconnection may be subject to FERC jurisdiction. Nothing in this
Schedule will affect the jurisdiction of the Commission or FERC, and all parties will
retain any and all rights they may have under any applicable state or federal statutes
or regulations.
Original Sheet No. 38.11
III.
Submitted Under Case No. PAC-E-16-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
A OnnsDil of i^oHconP
I.P.U.C. No.l Original Sheet No. 38.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.38
STATE OF IDAHO
Qualiffing Facility Avoided Cost Procedures
PRE,FACE:l. The process outlined in this Schedule is typically applicable to projects already
under development.
2. All submissions, responses and notices required in this Schedule must be done in
electronic or hard copy format. Requests and information may be submitted to the
Company at OFrequests@pacifi corp.com .
3. The QF pricing queue referenced in this Schedule is independent of and unrelated to
the interconnection and transmission services queue maintained and administered by
PacifiCorp Transmission Services pursuant to PacifiCorp Transmission Service's
FERC approved Open Access Transmission Tariff (OATT), as posted on its Open
Access Same-Time Information System (OASIS). The generation interconnection
process is a critical and lengthy process that typically must be well underway before
a power purchase agreement should be requested. QF Developers are strongly
encouraged to gain a clear understanding of the transmission interconnection process
and associated costs and timelines before requesting indicative pricing or a power
purchase agreement under this schedule.
4. The Company must use its reasonable commercial efforts to meet all Company
deadlines specified herein, and shall attempt to make up any Company delays in
meeting subsequent Company deadlines. QF Developer deadlines will be extended
to reflect Company delays beyond Company deadlines specified herein. Under
extenuating circumstances, the Company or a QF Developer may request an
extension of any deadlines from the Commission.
Submitted Under Case No. PAC-E-16-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
V.ROCKYMOUNTAIN
YPOIIVER\ AoM3loNoFaoHconP
I.P.U.C. No. 1 Original Sheet No. 38.2
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
PREFACE: (continued)
5. Subject to the specific tariff provisions provided below, the general timelines and
deadlines for actions or responses for Developers and the Company in this tariff are
summarized here for convenience, along with references to the relevant tariff
provisions. (all references to
a) Company must provide Developer illustrative, pro forma contract within seven
(7) days of request [Section I.B.l];
b) Developer may request indicative pricing at any time by submitting required
information [Section I.8.2];
c) Company must notify Developer whether request for indicative pricing is
complete within seven (7) days of submission [Section I.B.3];
d) Company must provide indicative pricing within thirty (30) days of notice of
completeness [Section I.B.4] ;e) Developer must request draft power purchase agreement and submit required
information within sixty (60) days of receipt of indicative pricing [Section I.8.5];
0 Company must notify Developer whether request for power purchase agteement
and required information is complete within seven (7) days of submission to the
Company [Section I.B.6] ;g) Company must provide Developer with draft power purchase agreement within
thirty (30) days of notice of completeness [Section I.8.6];
h) Developer must provide Company with initial comments on and proposed edits
to draft power purchase agreement within thirty (30) days of receipt [Section
r.B.7l;i) Company must respond to Developer's initial comments and edits within thirty
(30) days of receipt, and commence negotiations over areas of disagreement
ISection I.B.8];
j) Indicative prices must be updated unless a PPA is executed within six (6) months
after indicative pricing was provided by the Company [Section I.B.9];
k) Company must complete all internal reviews and approvals within twenty-one
(2 I ) days after agreement is reached on a proposed final version of a power
purchase agreement [Section I.B.8] ;l) PPA must be executed within five (5) months after Developer's receipt of draft
power purchase agreement [Section t.B.l0];
m) Company must submit power purchase agreement to Commission for approval
within seven (7) days of execution [Section LB.8]; and
n) Company must submit Transmission Service Request within seven (7) days after
execution of purchase power agreement [Section I.B.8].
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
PO|U/ER
A OMSIoi' OF PAOFEOAP
I.P.U.C. No.l Original Sheet No. 38.3
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
PREFACE: (continued)
6. QF Developers should pay special attention to the fact that, as specified in the
tariff sections that follow, a QF project will typically be removed from the QF
pricing queue, and any indicative or proposed prices or agreements will no
longer be valid, upon occurrence of any of the following events:
a) Failure of the QF Developer to submit to the Company a request for a power
purchase agreement within sixty (60) days of its receipt of indicative pricing, as
specified in Section I.B.5;
b) Failure of the QF Developer to submit written comments and proposals within
thirty (30) days of its receipt of a proposed power purchase agreement, as
specified in Section I.8.7;
c) Failure of the parties to execute a power purchase agreement within five (5)
months after a draft power purchase agreement was provided by the Company to
the QF Developer, as specified in Section I.B.l0.e.; or
d) A material change in the point of interconnection, a change in design capacity of
more than l0%o, a change in generation technology, or a change of more than
three (3) months in the online date, as specified in Sections I.8.1O.a.-d.
7. When a QF project is removed from the QF pricing queue, the developer may
request new indicative pricing and a new agreement by timely following all of
the steps outlined below, in which case it will be placed in the QF pricing queue
as a new project.
AVAILABILITY: To owners of Qualifying Facilities (QFs) in all territory served
by the Company in the state of Idaho.
APPLICATION: To owners of existing or proposed wind or solar QFs with a
design capacity greater than 100 kW, or Seasonal or Non-Seasonal Hydro projects and all
other projects greater than l0 a MW who desire to make sales to the Company and to QFs
who are not able to obtain pricing under the standard published rates. Such owners will be
required to enter into written 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.
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
A OMSrOtir Of H0HCOaP
I.P.U.C. No.1 Original Sheet No.38.4
I.
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
Process For Negotiating Power Purchase Agreements
A. Communications
Unless otherwise directed by the Company, all communications to
the Company regarding QF power purchase agreements should be
directed in writing as follows:
Rocky Mountain Power
Manager - QF Contracts
825 NE Multnomah St, Suite 600
Portland, Oregon 97232
OFrequests@nacificorp. com
The Company will respond to all such communications in a timely manner. 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 will respond in a timely
manner following receipt of all required information.
B. Proceduresl. Request for Pro Forma Contract. The Company shall provide a QF
Developer with a pro forma power purchase agreement within seven (7)
days of its receipt of a request for the same. The pro forma document
provided (i) does not constitute an offer to enter into an agreement, (ii)
may include general proposed terms and conditions, and (iii) will not
include pricing or project specific information. Anyone who desires to
enter into a power purchase agreement with the Company must proceed
in accordance with this Schedule to request indicative pricing under
Section I.8.2, to request a proposed power purchase agreement under
Section I.B.5, and to negotiate and execute a power purchase agreement
that is executed by the Company and approved by the Commission.
2. Request for Indicative Pricing. To obtain indicative pricing with
respect to a proposed project, a QF Developer must provide to the
Company the following general project information:
a) A general description of the QF project and the QF Developer,
including email address and other contact information;
b) generation technology and other related technology applicable to the
site and for solar projects specify fixed ground mount or solar
tracking;
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2076 EFFECTryE: April 15, 2016
V,ROCKYMOUNTAIN(POtItER
\ A Onrcloil oF PAOHCOaP
I.P.U.C. No. I Original Sheet No.38.5
B.I.
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
Procedures (continued)
c) design capacity (MW), station service requirements, and net amount
of power to be delivered to the Company's electric system;
d) quantity and timing of monthly power deliveries (including project's
ability to respond to dispatch orders from the Company) and an
hourly generation profile (12X24 profile minimum, 8760 preferred)
in Excel or other spreadsheet format with all formulae intact, and the
expected generation degradation per year and whether the
degradation rate is calculated against the first year or against the prior
year, or a forecast ofannual generation for each contract year over the
life of the requested contract term;
e) proposed site location and electrical interconnection point;
0 proposed on-line date and outstanding permitting requirements;
g) demonstration of ability to obtain QF status (FERC Form 556);
h) fuel type(s) and source(s);
D plans for fuel and transportation agreements (Motive force plans);j) proposed length of contract term;
k) status of transmission interconnection arrangements including
interconnection queue number; and
D other information promptly and reasonably requested by the
Company.
3. Notice of Completeness and Queue Position. Within seven (7) days of its
receipt of a request for indicative pricing and supporting materials as
specified above, the Company shall confirm its receipt of the same and notify
the QF Developer whether the submission is substantially complete or if
additional information is required. The Company shall not be obligated to
provide indicative pricing until all information described in Paragraph I.B.2
has been received from the QF Developer. Indicative pricing will be
determined in light of other QF projects in the QF pricing queue ahead of the
project, and using inputs and procedures as approved by the Commission. A
QF will be added to the QF pricing queue as of the date the Company has
confirmed receipt of all project information required in Paragraph I.8.2 and
will retain its priority position in the QF pricing queue for purposes of
subsequent requests for indicative pricing unless and until removed from the
QF pricing queue as provided herein. The Company will notify the QF
Developer of the date its project was added to the QF pricing queue. Once a
QF Project has been added to the QF pricing queue, in the event additional
clarifying information is reasonably required by the Company in order to
calculate indicative prices, the deadlines in Section I.B.4 shall be extended
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
a oMstot{ of aaoFcoaP
I.P.U.C. No.1 Original Sheet No.38.6
B.L
ELECTRIC SERVICE SCHEDULE NO. 38 - Continued
on a day for day basis until the requested clariffing information has been
provided.
Procedures (continued)
4. Indicative Pricing. Within thirty (30) days following the date a QF project was
added to the QF pricing queue under Section I.B.3, the Company shall provide
the QF Developer with indicative pricing, which may include other indicative
terms and conditions, tailored to the individual characteristics of the proposed
project.
An indicative pricing proposal provided by the Company may be used by the QF
Developer to make determinations regarding project planning, financing and
feasibility. However, such prices are indicative only and may be subject to
change by the Company as specified herein or by the Commission. Prices and
other terms and conditions are only final and binding to the extent contained in a
power purchase agreement executed by both parties and approved by the
Commission. The Commission may approve, reject or conditionally approve a
power purchase agreement and may at any time make changes to this Schedule,
QF pricing methods and inputs, or terms and conditions applicable to QF pricing
and power purchase agreements.
5. Request for Draft Power Purchase Agreement. If a QF Developer desires to
precede forward with the project it must, within sixty (60) days of its receipt of
indicative pricing, request that the Company prepare and submit for the
Developer's review a proposed power purchase agreement. Absent timely
submittal of such request, the project will be removed from the QF pricing queue
and the indicative prices will no longer be valid. In connection with its request
for a power purchase agreement, the Developer must provide the Company with
the following additional proj ect information :
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
A UVTSTON OF ilORCOAP
I.P.U.C. No.1 Original Sheet No.38.7
B.I.
ELECTRIC SERYICE SCHEDULE NO. 38 - Continued
Procedures (continued)
a) any available updates to the information specified in Paragraphl.B.2;
b) evidence ofadequate control ofproposed site;
c) identification of and timelines for obtaining any necessary governmental
permits, approvals or authorizations;
d) assurance of fuel supply or motive force;
e) anticipated timelines for completion of key project milestones;
0 evidence that any necessary interconnection studies are underway and
that the necessary interconnection arrangements can timely be completed
in accordance with Part II sufficient for the project to reach energization
by the proposed on-line date;
g) information describing the developer/owner of the proposed project,
including name, address, and ownership organization chart; and
h) other information promptly and reasonably requested by the Company.
6. Notice of Completeness and Draft PPA. Within seven (7) days of its receipt of
a request for a power purchase agreement and the information specified in
Section [.8.5, the Company shall confirm its receipt of the same and notiff the
Developer whether any additional information is needed. The Company shall
provide the Developer with a proposed power purchase agreement within thirty
(30) days following the date of the Company's notice that the information
required in Paragraph I.8.5 has been received and is substantially complete. The
proposed power purchase agreement shall contain a comprehensive set of
proposed terms and conditions, including specific pricing based on the indicative
pricing provided, as adjusted if necessary in light of specifics of the project. The
proposed power purchase agreement will also specify project specific data and
exhibits that must be provided by the QF Developer prior to final approval or
execution of the PPA. The proposal submitted by the Company shall serve as the
basis for subsequent negotiations.
7. Developer's Initial Comments and Edits. Within thirty (30) days of receiving
a proposed power purchase agreement, the QF Developer shall prepare and
deliver to the Company an initial set of wriffen comtnents and proposals, failing
which the Project will be removed from the QF pricing queue and the proposed
agreement and prices will no longer be valid.
8. Company's Response and Responsibilities. If the QF Developer's proposals
are not acceptable, the Company shall commence negotiations on all outstanding
areas of disagreement, and:
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
A Ot\flSlotit oF P OF|COiP
I.P.U.C. No.1 Original Sheet No.3E.E
B.I.
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
Procedures (continued)
a) shall respond to the developer's initial comments and proposals within thirty
(30) days, and thereafter respond timely to subsequent comments and
proposals;
b) will not unreasonably delay negotiations and will respond in good faith to
any additions, deletions or modifications to the draft power purchase
agrcement that are proposed by the QF Developer;
c) may request to visit the site of the proposed project if such a visit has not
previously occurred;
d) may request additional information from the Developer if reasonably
necessary to finalize the terms of the power purchase agreement and satisfy
the Company's due diligence with respect to the Project; and
e) shall submit to PacifiCorp Transmission Services a request for network
transmission service relating to the project within seven (7) days after
execution of a power purchase agreement, or otherwise as early as
practicable based on the applicable PacifiCorp Transmission Services tariff;
0 shall complete credit, legal, upper management and any other required
internal reviews of proposed terms and conditions within twenty-one (21)
days after agreement was reached on a proposed final version of a power
purchase agreement; and
g) shall submit a fully executed power purchase agreement to the Commission
for approval within seven (7) days of execution.
9. Required Pricing Update. The prices in the proposed power purchase
agreement provided by the Company under Section I.8.6 shall be recalculated by
the Company using the most recent available pricing inputs and methods
approved by the Commission, but without a change in the QF project's pricing
queue priority, if the QF Developer and the Company have not executed a power
purchase agreement within six months after indicative pricing was provided by
the Company under Section [.B.4, except to the extent delays are caused by
Company actions or inactions, which may include delays in obtaining legal,
credit or upper management approval by the Company.
10. Removal from QF Pricing Queue. In addition to the circumstances described
in I.B.5 and I.8.7, at any time during the process outlined in I.B.3 through I.B.9,
the Company shall remove a QF project from the QF pricing queue, and any
associated indicative prices, proposed prices or proposed agreement previously
provided will no longer be valid, if any of the following occurs with respect to a
QF project:
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
A OMSION OF NAOFrcONP
I.P.U.C. No. 1 Original Sheet No. 38.9
B.
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
Procedures (continued)
a) A material change in the point of interconnection;
b) A change in design capacity of l0o/o or more of the specified
design capacity;
A change in generation technology (i.e. solar, wind, thermal), including a
change between fixed tilt and tracking solar projects. Changes in the
quantity and timing of monthly power deliveries will not cause removal
from the QF pricing queue so long as the basic generation technology and
design capacity have not changed;
A change in the online date specified in the information provided under
Section I.B.2.f of more than three months earlier or later; or
A PPA has not been executed by both parties within five (5) months after
the draft PPA was provided by the Company to the Developer, except to
the extent delays are caused by Company actions or inactions.
I l. Standard PPA Terms. Absent Commission approval to the contrary for
good cause shown, a power purchase agreement executed under this
Schedule shall include the following terms and conditions, among others:
a) The scheduled commercial operation date must not be greater than thirty
(30) months after the execution date of the power purchase agreement;
b) The QF Developer must sign a System Impact Study Agreement with
PacifiCorp Transmission (refer to Section 42.2 or Section 51.4 of
PacifiCorp's OATT) within 120 days of the date a Commission Order
approving the agreement has become final and non-appealable; and
c) The QF Developer must provide 100% of the project development
security within 30 days of the date a Commission Order approving the
PPA has become final and non-appealable.
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 distribution
system. The Company's obligation to make purchases from a QF is conditioned upon all
necessary interconnection arrangements being consummated.
It is recommended that the owner initiate its request for interconnection as early in the
planning process as possible, to ensure that necessary interconnection arrangements proceed
in a timely manner on a parallel track with negotiation of the power purchase agreement.
Interconnection agreements (both transmission and distribution level voltages) are handled
by the Company's power delivery function, PacifiCorp Transmission Services.
c)
d)
e)
II.
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
Y
I.P.U.C.
ROCKY MOUNTAIN
POWER
a Dnflstd{ oF eaoFrcoeP
No.1 Original Sheet No. 3E.10
ELECTRIC SERYICE SCHEDULE NO. 38 - Continued
Process for Negotiating Interconnection Agreements (continued)
A. Communications
Initial communications regarding interconnection agreements should be directed to
the Company in writing as follows:
PacifiCorp Transmission Services
Interconnection Requests
825 NE Multnomah St, Suite 1600
Portland, Oregon 97232
OFrequests@nacifi corp.com
B. Procedures
Generally, the interconnection process involves (l) initiating a request for
interconnection, (2) completion of studies to determine the system impacts
associated with the interconnection and the design, cost, and schedules for
constructing any necessary interconnection facilities, (3) execution of an
interconnection agreement.
The QF project owner is responsible for all interconnection costs assessed by the
Company on a nondiscriminatory basis.
For interconnections greater than twenty (20) megawaffs, the Company will process
the interconnection application through PacifiCorp Transmission Services generally
following the procedures for studying the generation interconnection described in
the Company's Open Access Transmission Tariff, PacifiCorp FERC Electric Tarifl
Fifth Revised Volume No. I I Pro Forma Open Access Transmission Tariff (OATT),
as the same may be changed or updated, on file with the Federal Energy Regulatory
Commission (FERC). A copy of the OATT is available on-line at
http//www.oas i s. pacifi corp.com.
The Company's interconnection forms and agreements, are provided electronically at the
following address : http ://www.oacifi corp.com/tran/ts/gip/qf.html
[.
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTM: April 15,2016
ROCKY MOUNTAIN
POWER
a tnlflSroir oF HoFr@nP
I.P.U.C. No.I Original Sheet No. 38.11
ELECTRIC SERVICE SCHEDULE NO.38 - Continued
Process for Filing a Complaint with the Commission on Contract Terms
The Commission has both informal and formal dispute resolution processes which
can be reviewed on the Commission website at the following
address : htto ://www.puc. idaho. gov/forms/consumerassistance
These processes are available for any matter as to which the Commission has
jurisdiction, which may include (i) QF PPA contracts, (ii) small QF interconnection
agreements (less than 20 MW), and (iii) large QF interconnection agreements (more
than20 MW), so long as all of the QF output is sold exclusively to the Company. To
the extent any portion of the QF output is sold to anyone other than the Company, a
QF generation interconnection may be subject to FERC jurisdiction. Nothing in this
Schedule will affect the jurisdiction of the Commission or FERC, and all parties will
retain any and all rights they may have under any applicable state or federal statutes
or regulations.
III.
Submitted Under Case No. PAC-E-I6-01
ISSUED: January 13,2016 EFFECTryE: April 15, 2016