20200717Comments.pdf

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?$10 iUL I 7 Pl{ l: 0 [EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10446
Steet Address for Express Mail:
I1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
,r",. ... ,i-., f'L'Sl."ltr
n i ii-i', i,':-; Ct)l#h{BStG+l
IN THE MATTER OF THE AI\NUAL
REVISION TO QT VARIABLE ENERGY
PRICES PURSUANT TO TERMS OF THE
1992 AMENDMENTS TO POWER
PTJRCHASE AGREEMENTS BETWEEN
IDAHO OFS AND PACIFICORP
CASE NO. PAC-E.20.08
COMMENTS OF THE
COMMISSION STAFF
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STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Edward Jewell, Deputy Attorney General, submits the following comments.
BACKGROUND
On June 4,2020, Rocky Mountain Power, a division of PacifiCorp ("Rocky Mountain
Power" or "Company") filed an Application requesting the Commission approve the annual
update to the variable energy portion of avoided cost rates for qualiffing facilities ("QFs") under
the Public Utility Regulatory Policies Act of 1978 ("PURPA") with the 1992 amendments. The
variable component of the rate was ordered by the Commission to be updated annually in Order
No. 29316 for contracts authorized under this methodology. The Company requests an effective
date of July 1,2020.
ISTAFF COMMENTS ruLY t7 ,2020
STAFF ANALYSIS
Staffreviewed the variable energy rate of the avoided cost rate for PacifiCorp contracts
with 1992 amendments contained in the Application and believes that the proposed rate is correct
and complies with OrderNo. 29316. The 1992 amendments apply to 13 QFs.
This year's proposed update was calculated by summing the average of Rocky Mountain
Power's fuel costs for its Naughton, Huntington, and Hunter coal-fired generation plants with the
variable operations and maintenance costs for Colstrip. Carbon and Hale coal plants are no
longer in operation and were properly excluded from the calculation of the average cost of fuel.
The average cost of fuel was calculated using the data reported in the Company's FERC Form l.
The result in the variable energy rate of $23.07 per megawatt hour ("MWh") is a decrease from
the currently authorized rate of $23.85 per MWh.
STAFF RECOMMENDATION
Staffrecommends that the Commission approve the variable energy rate of $23.07 per
MWh applicable to the energy delivered from the 1992 QF contracts commencing July l, 2020,
extending through June 30, 2021.
Respectfully submitted tr" t_7' day of July 2020.
P+*L(
Edward fe(ett\
DeputyAttorne>lvGeneral
Technical Staff: Yao Yin
Rachelle Farnsworth
Travis Culbertson
i:umisc/commentVpace20.Sejrffytnc comments
2STAFF COMMENTS ruLY 17,2020
CERTIFICATE OF' SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17ft DAY OF JUNE 2020,
SERVED THE FOREGOING COMMENTS OF TIIE COMI\dISSION STAFF, IN
CASE NO. PAC.E-20-08, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
ID REG AFFAIRS MGR
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-mail: [e-mail]
DATA REQUEST RESPONSE CENTET\
E.MAIL ONLY:
datarequest@pacificorp. com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-mail: [e-mail]
Rzgn a Q-rzirutero
SECRETARY
CERTIFICATE OF SERVICE