20210310Unoppossed Motion and Stay.pdf

Y ROCKY MOUNTAIN
POWER
"., .- i,' r irJ +it! ..6 '-,; -
iitii li;iit 1* Ptt ?: *s 1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
March 10,2021
VIA ELECTRONIC DELIWRY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. ChindenBlvd
Building 8 Suite 20lA
Boise,ID 83714
Re:CASE NO. PAC.E-20.18
IN THE MATTER OF THE APPLICATION FOR APPROVAL OR REJECTION
OF TIIE AMENDED POWER PURCHASE AGREEMENT BETWEEN
PACIFICORP AI\ID AMY FAMILY HOLDINGS, LLC
Dear Ms. Noriyuki:
Please find for filing Rocky Mountain Power's Motion for Stay in the above-referenced matter
Informal inquiries may be directed to Ted Weston,Idaho Regulatory Manager at(801)220-
2963.
Very truly yours,
"^,.DJoelle R.
Vice-President of Regulation
Emily L. Wegener, (pro hac vice)
Rocky Mountain Power
1407 WestNorth Temple, Rm 320
Salt Lake City, Utah 841l6
Telephone : [phone]
Email: emil),[e-mail]
Attorneyfor Rocley Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF THE APPLICATION ) cAsE NO. PAC_E_20-18
FORAPPROVAL OR REJECTTON OF THE )
AMENDED POWER PURCHASE ) ROCKY MOUNTAIN POWER
AGREEMENT BETWEEN PACIFICORP ) UNOPPOSSED MOTION FOR STAY
AND AMY EAMILY HOLDINGS, LLC )
Comes now Rocky Mountain Power, a division of PacifiCorp, ("Company") pursuant to
RP 324 - Stay of Order, respectfully files this unopposed Motion for Stay with the Idaho Public
Utilities Commission ("Commission"). In support of this Application, Rocky Mountain Power
states as follows:
I. BACKGROUND
l. On December 3,2020, the Company filed this application ("Application") with the
Commission requesting a one-year extension to the Amy Family Holdings,LLC qualified facility
contract ("Seller"). Seller owns, operates, and maintains a small hydro-electric power plant (the
"Facility") located in Butte County, Idaho with a nameplate capacity rating of 450 kilowatts
(*kW"). Seller operates the Facility as a Qualifying Facility ("QF") under the applicable provisions
of PURPA.
2. The Seller's current PURPA contract entered into on January 3, 1985, is scheduled
to expire on December 31, 2021. The PURPA contract was entered into prior to PacifiCorp
separating its energy supply and transmission functions as required by federal law and regulations.
Page 1
3. Therefore, the contract includes provisions that address both energy sales and
interconnection requirements. The Seller has expressed a desire to continue to make sales from the
Facility to PacifiCorp consistent with the requirements of PURPA as implemented in the State of
Idaho.
4. The Seller and PacifiCorp are in the process of securing a new stand-alone
interconnection agreement that, after all distribution system upgrades are constructed and in-
service, will replace the interconnection provisions in the current PURPA contract.
5. The Application requested a one-year extension to the contract to provide the Seller
enough time to complete the required interconnection agreement before a new QF contract can be
completed. Since filing the Application, the Seller has made significant progress on the new
interconnection provisions to the point the Company is reasonably certain the Seller should be able
to complete the interconnection requirements before the current contract expires.
6. Based on the Seller's progress to acquire an interconnection agreement and
discussions with Commission Staffthe Company respectfully files this Motion for Stay with the
Commission subject to the Seller acquiring an interconnection agleement by October 15,2021.
[. COMMUNICATIONS
7. Communications regarding this filing should be addressed to:
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 WestNorth Temple, Suite 330
salt Lake city, utah 84116
Telephone : [phone]
Email: ted.weston@pacifi com.com
IdahoDockets@oaci fi corp.com
Page2
Emily Wegener (pro hac vice)
Senior Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake city, utah 84116
Telephone : [phone]
Email: emilv.weqener@pacifi corp.com
In addition, Rocky Mountain Power requests that all data requests regarding this
Application be sent in Microsoft Word to the following:
By emai I (preferred) : datareque st@pac i fi corp. com
By regular mail: Data Request Response Center
PacifiCorp
825 Multnomah, Suite 2000
Portland, Oregon 97232
Informal questions may be directed to Ted Weston, Idaho Regulatory Affairs Manager at
[phone].
TII. REOUEST FOR STAY
WHEREFORE, Rocky Mountain Power respectfully files the unopposed motion for Stay
in the above referenced proceeding with the Idaho Public Utilities Commission.
DATED this 10ft day of March,ZlTl.
Respectfully submitted,
ROCKY MOUNTAIN POWER
Emily L.
Attorneyfor Rocky Mountain Power
Page 3