20201203Comments.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10655
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )POWER'S APPLICATION FOR APPROVAL OR )CASE NO.PAC-E-20-07REJECTIONOFAPOWERPURCHASE)AGREEMENT BETWEEN PACIFICORP AND )BIRCH HYDRO COMPANY )COMMENTS OF THE
)COMMISSION STAFF TO
)AMENDED APPLICATION
STAFF OF the Idaho Public Utilities Commission,by and through its Attorneyof
record,Matt Hunter,Deputy AttorneyGeneral,submits the followingcomments.
BACKGROUND
On June 3,2020,Rocky Mountain Power ("Company"),a division of PacifiCorp,applied
for consideration of a power purchase agreement ("PPA")with Birch Hydro Company for
energy generated by a small hydro facility in Clark County,Idaho.
Commission Staff filed timely written comments,recommending several amendments to
the PPA.The Company filed timely reply comments and accepted all of Staff's
recommendations.The Company stated that the "Company and the Seller will work
expeditiously to file an updated contract and exhibits incorporating Commission Staff's
comments as soon as possible."
STAFF COMMENTS 1 DECEMBER 3,2020
The Commission issued an interlocutoryorder on September 1,2020.The order directed
the Company to file the amended PPA by September 15,2020.The Commission also granted
persons until September 22,2020 to file written comments on the amended PPA and set a
September 29,2020 reply comment deadlinefor the Company.Order No.34768.
The Company did not file the amended PPA until November 3,2020,because amending
the PPA took longer than the Company initiallyexpected.
STAFF ANALYSIS
In its comments filed on August 10,2020,Staff recommended the parties file an amended
PPA that includes the followingupdates:(1)update Exhibit A to include correct monthly
estimate information;(2)incorporate the 82.4%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.
Staff reviewed the amended PPA and believes that it has incorporated the
recommendations made by Staff in its comments filed on August 10,2020.
STAFF RECOMMENDATION
Staff recommends approval of the amended PPA between Rocky Mountain Power and
Birch Hydro Company.Staff also recommends that the Commission declare that the avoided
cost rates set forth in the amended PPA are just and reasonable,in the public interest,and that the
Company's incurrence of such costs are legitimate expenses.
Respectfully submitted this 3rd day of December 2020.
Matt Hunter
Deputy AttorneyGeneral
Technical Staff:Yao Yin
i:umisc/comments/pace20.7mhyyrf comments2
STAFF COMMENTS 2 DECEMBER 3,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3 DAY OF DECEMBER 2020,SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TOAMENDEDAPPLICATION,IN CASE NO.PAC-E-20-07,BY E-MAILING A COPY
THEREOF,TO THE FOLLOWING:
TED WESTON JACOB A McDERMOTTROCKYMOUNTAINPOWERROCKYMOUNTAINPOWER
1407 WEST NORTH TEMPLE STE 330 1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84116 SALT LAKE CITY UT 84116
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
ADAM LOWNEY DATA REQUEST RESPONSE CENTER
McDOWELL RACKNER GIBSON E-MAIL ONLY:
419 SW 11TH AVE SUITE 400 [e-mail]
PORTLAND OR 97205
E-MAIL:adam mrg-law.com
SECRETARY
CERTIFICATE OF SERVICE