20210923Unopposed Motion to Lift Stay.pdf

1407 W. North Temple, Suite 330 Salt Lake City, Utah 84116
September 23, 2021
VIA ELECTRONIC DELIVERY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission 11331 W. Chinden Blvd Building 8 Suite 201A Boise, ID 83714
Re: CASE NO. PAC-E-20-18
IN THE MATTER OF THE APPLICATION FOR APPROVAL OR REJECTION
OF THE AMENDED POWER PURCHASE AGREEMENT BETWEEN PACIFICORP AND AMY FAMILY HOLDINGS, LLC
Dear Ms. Noriyuki:
Please find for filing Rocky Mountain Power’s Motion to Lift the Stay in the above-referenced matter.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at [phone].
Very truly yours,
Joelle R. Steward Vice-President of Regulation
RECEIVED
2021 SEP 23 PM 4:34
IDAHO PUBLIC
UTILITIES COMMISSION

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Emily Wegener (ISB #11614) Rocky Mountain Power 1407 W. North Temple, Suite 320 Salt Lake City, Utah 84116 Telephone: [phone] Email: [e-mail]

Attorney for Rocky Mountain Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
FOR APPROVAL OR REJECTION OF THE
AMENDED POWER PURCHASE
AGREEMENT BETWEEN PACIFICORP
AND AMY FAMILY HOLDINGS, LLC
)
) CASE NO. PAC-E-20-18
)
) UNOPPOSED
) MOTION TO LIFT STAY

Pursuant to the Rules of Procedure of the Idaho Public Utilities Commission, Rule 56,
PacifiCorp dba Rocky Mountain Power (“Rocky Mountain Power” or the “Company”) hereby
moves to lift the stay entered in the above-captioned matter on March 25, 2021, under Order
No. 34971.
BACKGROUND
The Company filed the Application to approve a one-year extension to the Power
Purchase Agreement between PacifiCorp and Amy Family Holdings, LLC, (“Amy”) from
January 1, 2022, through December 31, 2022. The purpose of the one-year extension was to
allow the parties to secure a stand-alone interconnection agreement to replace the
interconnection provisions in the existing contract.
On March 10, 2021, the Company filed a motion to stay the Application because the
Company believed that Amy would be able to complete the interconnection requirements
before the current contract expired on December 31, 2021.
On March 25, 2021, the Idaho Public Utilities Commission (“Commission”) granted
the Company’s motion and ordered that the case be stayed. The Commission further ordered
“If the Seller has not completed its interconnection requirements by October 15, 2021, the

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Company must seek continuance in this case to allow the Commission to fully process it
Application before the December 31, 2021 expiration.”1
CURRENT STATUS AND MOTION TO LIFT STAY
The Company has executed a Small Generator Interconnection Agreement (“SGIA”)
with Amy. However, the transmission upgrades necessary for a long-term power purchase
agreement will not be completed until May 2022. The existing contract must be extended so
that Amy can maintain its current interconnection rights until the transmission upgrades are
complete. Because the Company’s existing contract with Amy expires on December 31, 2021,
the Company must have its Application considered before then.
Now that the parties have entered the SGIA, they will negotiate the terms of a new
power purchase agreement. Section 1 of the amendment to the power purchase agreement,
provide as Attachment A to the application, states: “this Agreement shall expire upon the
earlier of (i) the effective date of a new power purchase agreement… or (ii) December 31,
2022. While the Company’s Application requests a one-year extension of the existing contract,
should the negotiation and approval by the Commission of the new power purchase agreement
take less than a year, the Company will ask the Commission to replace the existing contract
with the new one at the time of approval.
Therefore, the Company respectfully requests that the Commission lift the stay and
consider the Application before December 31, 2021.
DATED this 23rd day of September, 2021.

Respectfully submitted,
By _______________________________ Emily Wegener Attorney for Rocky Mountain Power

1 Order No. 34971.