20200824Reply Comments.pdf

Y ROCKY MOUNTAIN
POWER
A DtVtStOt{ OF AACIFICORP
lr'[*ttVf S
3*;* &i$ eh PH 3: l*l
1407 W. North Temple, Suite 330
Salt Lake City, Utah &4116
August 24,2020 r. r...i ) ;tL:;Li*-i 'f i',.;: lt' ;u-i.'*i5$l$H
VU ELECTRONIC DELIVERY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
1131 W. ChindenBlvd
Building 8 Suite 201,4'
Boise,lD 83714
Re:CASE NO. PAC.E-20-10
IN THE MATTER OF THE APPLICATION FOR APPROVAL OF THE POWER
PURCHASE AGREEMENT BETWEEN PACIFICORP AI\D FALL RIYER
ELECTRIC COOPERATIYE, INC.
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,
"^-DR.
Vice President of Regulation
Emily Wegener
1407 WestNorth Temple, Suite 320
Salt Lake city, utah 84116
Telephone No. [phone]
Mobile No. [phone]
Email : Emily.weeener@oacifi com.com
Attorneyfor Roclqt Mountain Power
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
FORAPPROVAL OF TIIE POWER
PURCHASE AGREEMENT BETWEEN
PACIFIC ORP AI\D FALL RIVER
ELECTRIC COOPERATIYE, INC.
) cAsE NO. PAC-E-20-10
)) REPLY COMMENTS OF
) ROCKY MOUNTAIN POWER
)
Pursuant to Rule 20201(d) of the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission") and the Commission's July 2, 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.
I. BACKGROUNI)
1. On June 9,2020, Rocky Mountain Power filed anApplication with the Commission
requesting approval of a twenty-year Purchase Power Agreement ("PPA") between the Company
and Fall River Electric Cooperative ("Seller") who owns, operates, and maintains a small hydro-
electric power plant located in Teton County, Idaho with a nameplate capacity rating of 7.5
megawatts (the "Facility"). Seller operates the Facility as a Qualiffing Facility ("QF") under the
applicable provisions of the Public Utility Regulatory Policies Act of 1978 ("PURPA").
2. On July 2, 2020, Commission Order 34717 was issued which noticed the
application, established a procedural schedule with comments due August 17,2020, and reply
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comments due August 24, 2020, and authorized the case to be processed under Modified
Procedure.
3. On August 17,2020, Commission staff filed comments recommending that the
Company file an amended Agreement that incorporates the 82.4 percent discount for purposes of
converting firm market prices to non-firm market prices in the Agreement and change the term
"Mid-C-85" in Exhibit K to "PV-85" to reflect the use of the Palo Verde Hub for market prices.
4. Staff commented that Powerhouse #l had not been operational since 2006 and
recommended that because it had not been contributing capacity for about 14 years that
Powerhouse No. I should be heated as a new project without a capacity payment until the
Company's first deficit year in 2028.
5. Staffalso recommended that because both Powerhouse #l and#2 were metered by
the same meter the Commission should allow additional time, proposing until October 1,2020,to
evaluate and develop a metering solution to assure Powerhouse #1 does not receive a capacity
payment until 2028 while Powerhouse #2receive acapacity payment beginning with the effective
date ofthe new contract.
II. REPLY COMMENTS
6. The Company accepts Staffs recommendation to use 82.4 percent as the discount
rate for purposes of converting firm market prices to non-firm market prices throughout the PPA
and will work with the Seller to update and file an amended contract.
7. The Company accepts Staffs recommendation to correct Exhibit K by replacing
Mid-C-85 references with PV-85. The Company will work with the Seller to update the contract
and Exhibits as soon as possible.
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8. If the Commission approves Staffs recommended capacity treatment the Company
will work with the Seller and Staffto develop a metering solution that assures Powerhouse #1 does
not receive a capacity payment until 2028, while Powerhouse #2 begins receiving a capacity
payment on the effective date of the new contract.
UI. CONCLUSION
The Company and Seller will work with Commission Staffto develop a metering solution
that is acceptable to all parties and to file an updated contract and exhibits incorporating Staffs
comments as soon as possible.
IV. REQUEST FOR RELIEF
Rocky Mountain Power respectfully requests that with the revisions discussed above the
Commission issue an order approving the avoided cost prices set forth in the Revised Agreement
as just and reasonable, in the public interest, and that the Company's incurrence of such costs are
legitimate expenses to recover.
DAIED this 24m day ofAugust,2l2}.
Respectfu I ly submitted,
ROCKY MOUNTATN POWER
Emily Wegener
1407 WestNorth Temple, Suite 320
Salt Lake city, utah 84116
Telephone No. [phone]
Mobile No. [phone]
Email: [e-mail]
Attorneyfor Roclcy Mountain Power
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CERTIFICATE OF SERVICE
I hereby certiff that on this 24ft of August, z}2},Icaused to be served, via electronic
mail a true and correct copy of Rocky Mountain Power's Reply Comments in Case No. PAC-E-
20-10 to the following:
Service List
Dated this 24ft day of August, 2020.
Ve,.
Katie Savarin
Coordinator, Regulatory Operations
FALL RIVER
Gregory M. Adams
Peter J. Richardson
Richardson Adams, PLLC
515 N.27th Street
Boise,Idaho 83702
sre s faric hard sonadam s. c om
[e-mail]
ROCKY MOUNTAIN POWER
Ted Weston
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
Salt Lake Ciry, Utah 84116
ted.weston@paci fi corp.com
Emily Wegener
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
salt Lake city, utah 84116
emily.we gener@pac ifi corp.com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
datareq uest@pac i fi corp.com
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