20200626Decision Memo.pdf

DECISION MEMORANDUM
TO:COMI\4ISSIONER KJELLAI\DER
COMI\{ISSIONER RAPER
COMl\fi SSIONER AI\DERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:DAYN HARDIE
DEPUTY ATTORNEY GENERAL
DATE: JUNE 26,2020
STIBJECT:IN THE MATTER OF ROCI(Y MOUNTAIN POWER'S APPLICATION
FOR APPROVAL OF A POWER PURCHASE AGREEMENT BETWEEN
PACIFICORP AI\ID FALL RTVER ELECTRIC COOPERATIVE, INC;
CASE NO. PAC.E-20.10
On June 9, 2020, Rocky Mountain Power ("Company"), a division of PacifiCorp,
applied for consideration of a Power Purchase Agreement ("Agreement") with Fall River Electric
Cooperative, Inc. for energy generated by the Felt Hydro Facilityl ("Facility"), a small hydro
facility in Teton County, Idaho. Application at l. The Facility is a qualifuing facility under the
Public Utility Regulatory Policies Act of 1978 ("PURPA") and has a nameplate capacity of 7.45
megawatts. Id. at2.
THE APPLICATION
The Facility has been delivering energy to the Company in accordance with a PURPA
contract dated December 4, 1984. Id. at 3. The existing PURPA contract will expire at midnight
on March 31, 2021. Id. The Company states that the Agreement contains non-seasonal hydro
avoided cost rates based on the surrogate avoided resource cost methodology for a 2O-year term.
Id. Tlrte replacement Agreement2 also contains capacity payments for the entire term of the
Agreement with no sufficiency period. Id. at2-3. The Company requests the Commission declare
all payments for purchase of energy under the Agreement be allowed as legitimate expenses for
ratemaking purposes, all of which the Commission will allow the Company to recover in Idaho in
the event otherjurisdictions deny recovery for their proportionate shares. Id. at 3 and 5.
I The Facility was previously known as CDM Hydro.
2 The Company references both Power Purchase Agreement and "ESA" (Energy Sales Agreemart) throughout its Application.
IDECISION MEMORANDUM
STAIT'RECOMMENDATION
Staff recommends the Commission issue a Notice of Application and Notice of
Modified Procedure, setting an August 17 ,2020 comme,nt deadline and an August 24,2020 rqly
comment deadline.
COMMISSION DECISION
Docs the Commission wish to issue a Notice of Application and Notice of Modified
Procedure, setting an August 17,2020 comment deadline and an August 24,2020 reply comment
deadline?
Dayn Hardie
Depuf Attorney General
I:U;SIfiEI.ECTaIOPAC+-2ILt0\ltoor\PACE20lO_doc_rt dcn
2DECISION MEMORANDUM