20160809Comments.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
RECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S APPLICATION )
TO APPROVE AN ADDENDUM TO ITS POWER)
PURCHASE AGREEMENT WITH LOWER )
VALLEY ENERGY, INC. ) ___________________ )
CASE NO. PAC-E-16-11
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 submits the following
comments.
BACKGROUND
On July 7, 2016, PacifiCorp dba Rocky Mountain Power (the Company) filed an
Application asking the Commission to approve an Addendum to its Power Purchase Agreement
(PPA) with Lower Valley Energy, Inc. The Addendum extends the PPA, set to expire on
September 30, 2016, for another year. The Company requested that the Commission process the
Application under Modified Procedure.
The Commission approved the Company's current PPA with Lower Valley in August
2014. Application at 2; Order No. 33107. Under the PPA, Lower Valley sells, and the Company
purchases, electric power generated from Lower Valley's three facilities -the Upper Facility, the
STAFF COMMENTS AUGUST 9, 2016
Lower Facility, and the Culinary Facility -which are run-of-river hydroelectric generating
facilities in or near Afton, Lincoln County, Wyoming. PPA (Attachment 2 to Application). The
facilities -each a separate qualifying facility under the Public Utility Regulatory Policies Act
(PURP A) -are deemed a single generating facility for purposes of the PP A. Id.
Under the Addendum, the parties agree to extend the term of the PPA for one additional
year, using applicable rates. Addendum (Attachment 1 to Application). The applicable rates are
the non-levelized I avoided cost rates for non-seasonal hydro projects less than 10 average
megawatts, approved by the Commission in December 2015 in Order No. 33435 (Case No.
PAC-E-15-12). For energy deliveries in 2016, the rate is $34.06 per megawatt-hour (MWh).
Application at 3. For energy deliveries in 2017, until the PPA expires on September 30, the rate
is $34.42 per MWh. Id.
STAFF ANALYSIS
Staff has reviewed the proposed rates and confirms that they are correct. All other terms
and conditions contained in the proposed Agreement are consistent with prior Commission
orders.
RECOMMENDATION
Staff recommends that the Commission approve all of the Agreement's terms and
conditions and declare that all payments made by Rocky Mountain Power to Lower Valley
Energy for purchase of energy will be allowed as prudently incurred expenses for ratemaking
purposes.
Respectfully submitted this
·-fl,!_ ?{ ;,.,,--day of August 2016.
Technical Staff: Yao Yin
i:umisc:comments/pace 16. 11 djhyy comments
1 See PacifiCorp's Errata.
STAFF COMMENTS 2 AUGUST 9, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9TH DAY OF AUGUST 2016,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-16-11 , BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DAT A REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@pacifi com. com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
SECRETARY -
CERTIFICATE OF SERVICE