20200817Reply Comments.pdf

Y ROCKY MOUNTAIN
POWER
A DIVISION OF PAOFI@RP
August 17,2020
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1407 W. North Temple, Suite 330
Salt Lake City, Utah M116
VIA ELECTRONIC DELIVERY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
l13l W. Chinden Blvd
Building 8 Suite 20lA
Boise,lD 83714
Re:CASE NO. PAC.EAO-07
IN TIIE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION FOR
APPROVAL OF POWER PURCHASE AGREEMENT BETWEEN PACIFICORP
AND BIRCH ITYDRO COMPAI\TY
Dear Ms. Noriyuki:
Please find attached Rocky Mountain Power's reply comments in the above referenced matter
Informal inquiries may be directed to Ted Weston,Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
R.
Vice-President of Regulation
Emily Wegener
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. (801) 2204526
Mobile No. [phone]
Email: Emily.wegener@pacifi corp.com
Attorneyfor Roclcy Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF'ROCKY MOUNTAIN ) CASE NO. PAC.E-20-07
POWER'S APPLICATION FOR APPROVTTL IOF POWER PURCHASE AGREEMENT ) REPLY COMMENTS OFBETWEEN PACIF'ICORPAI\ID BIRCH ) ROCKY MOTJNTAIN POWERIIYDRO COMPAIYY )
Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission") and the Commission's June 26,2020, Notice of Application and
Modified Procedure, Rocky Mountain Power a division of PacifiCorp (the "Company") hereby
submits its reply comments in the above-referenced case.
L BACKGROI]ND
l. On May 29, 2020, Rocky Mountain Power filed an Application with the
Commission requesting approval of a Z}-year Purchase Power Agreement (.'PPA") between the
Company and Birch Hydro ("Seller") who owns, operates, and maintains a small hydro-elecnic
power plant located in Clark County, Idaho with a nameplate capacity rating of 2.65 megawatts
(the "Facility"). Seller operates the Facility as a Qualifring Facility ("QF") under the applicable
provisions of the Public utility Regulatory PoliciesAct of 1978 ("puRpA').
2. On June 26, 2020, Commission Order 34709 was issued which noticed the
application, established a procedural schedute with comments due August lO, 2020, and reply
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conrments due August 17, 2020, and authorized the case to be processed under Modified
Procedure.
3. On August I0, 2020, Commission staff filed comments with the following
recommendations: (l) Update Exhibit A to include correct monthly estimate information;
(2) Incorporate the 82.4 percent discount for purposes of converting firm market prices to non-
firm market prices throughout the PPA; and (3) Correct mistakes and errors in Exhibit K. With
those corrections Staff recommended the Commission approve the amended PPA and also
recommended that, if the updates described above are made by the Company, the Commission
declare that the avoided cost prices set forth in the Agreement are just and reasonable, in the public
interest, and that the Company's incurrence of such costs are legitimate expenses.
II. REPLY COMMENTS
4. The Company agrees with Staffs comments that Exhibit A should be updated to
correct the monthly estimate information and is working with the Seller to file an updated Exhibit
A as soon as possible.
5. The Company accepts Staffs recommendation to use 82.4 percent as the discount
rate rather than 85 percent for purposes of converting firm market prices to non-firm market prices
throughout the PPA. The Company is working with the Seller to update and file the contract as
soon as possible.
6. The Company accepts Staffs recommendation to correct Exhibit K to reference the
Firm Market Price Index instead of Index Price and PV-85 rather than Mid-C-85. The Company is
working with the Seller to file an updated contract and Exhibits as soon as possible.
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III. CONCLUSION
The Company and Seller will work expeditiously to file an updated contract and exhibits
incorporating Commission Staffs comments as soon as possible.
rv. REQUEST X'OR RELIEF
Rocky Mountain Power respectfully requests that the Commission issue an order
approving the avoided cost prices set forth in the RevisedAgreement as just and reasonable,
in the public interest, and that the Company's incurrence of such costs are legitimate
expenses to recover.
DATED this 17ft day ofAugust 2020.
Respectfu lly submitted,
ROCKYMOUNTAIN POWER
Emily Wegener
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Mobile No. [phone]
Email: Emily.weeener@pacifi corp.com
Attorneyfor Roclry Mountain Power
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