20180129Comments.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. IOI77
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR APPROVAL
OF POWER PURCHASE AGREEMENT
BETWEEN PACIFICORP AND THE CITY OF
PRESTON,IDAHO.
RECEIVED
?0lB JAH 29 Pll t2: 30
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-59T8
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. PAC-8.I7-I4
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Camille Christen, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 33960 on January 8, 2018, in
Case No. PAC-E-17-14, submits the following comments.
BACKGROUND
On December 22,2017, Rocky Mountain Power applied to the Commission for an Order
approving or rejecting its proposed Power Purchase Agreement (PPA) with the City of Preston,
Idaho. Rocky Mountain Power explains the proposed PPA would replace an agreement with an
existing "qualifying facility" (QF) under the Public Utility Regulatory Policies Act (PURPA).
Application at3. Rocky Mountain Power explains the proposed PPA is a renewal contract with
an existing 400 kilowatt hydroelectric QF under PURPA. Id, at3. The proposed PPA would
replace a prior agreement that was in effect from 1982 until it expired on December 31, 2017 .
Id. at3-4.
ISTAFF COMMENTS JANUARY 29,2018
Since the prior agreement has expired and the proposed PPA is not yet effective, the
Company also seeks permission to continue buying the QF's power under the prior agreement
until the Commission approves or rejects the proposed PPA. The Company states it and the QF
have agreed that the price the Company pays for power after 2017 will be trued-up to the price it
would have paid if the proposed PPA had been in effect. Id. at 4.
The Commission issued a Notice of Application and Notice of Modified Procedure,
Order No. 33960, in which it also granted the Company permission to continue to buy power
from the QF under the prior agreement until the proposed PPA is approved or rejected. Order
No. 33960. Prices paid after 2017 are to be trued-up to the price that would have been paid
under the proposedPPA. Id.
STAFF ANALYSIS
Staff has reviewed the proposed rates and confirms they are correct. All other terms and
conditions contained in the proposed Agreement are consistent with prior Commission orders.
STAFF 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 the City of Preston
for purchase of energy will be allowed as prudently incurred expenses for ratemaking purposes.
Respectfully submitted this Lt day ofJanuary 2018.
WL Q)^;,-,
Camille Christen
Deputy Attorney General
Technical Staff: Yao Yin
Kevin Keyt
i:umisc/comments/pacel7. l4ccyykk comments
2STAFF COMMENTS JANUARY 29,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29th DAY OF JANUARY 2018,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-17-14, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ROCKY MOI.JNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOI-INTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 841 16
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE