20210608Reply Comments.pdf

Y ROCKY MOUNTAIN
PCIWER
A OIVISION OF PACIFICORP
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1407 W. North Temple, Suite 330
Salt Lake City, Utah &4116
June 8,2021
VIA ELECTRONIC DELIVERY
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 20lA
Boise,ID 83714
Re: CASE NO. PAC-E-21-10
IN TIIE MATTER OF THE APPLICATION FOR APPROVAL OR REJECTION
O['THE POWER PT]RCHASE AGREEMENT BETWEEN PACIX'ICORP AI\D
SUINTY BAR RANCH
Dear Ms. Noriyuki:
Please find for filing 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,
R.
Vice-President of Regulation
Enclosures
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Emily Wegener (ISB #11614)
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
FAX: [phone]
Email : emilv. weeener@pacifi corp.com
Attorneyfor RoclE Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF TOCKY MOTTNTATN ) CASE NO. PAC-E-21-10
POWER'S APPLICATION FORAPPROVAL )
oR REIECTION OF THE POWER ) REPLY COMMENTS OF
PURCHASEAGREEMENT BETWEEN ) ROCIffMOUNTAIN POWER
PACIFICORP AI\[D SUNI\"Y BAR RANCH
Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission"), Rocky Mountain Power a division of PacifiCorp (the "Company")
hereby submits reply comments in the above-referenced case.
OnApril 1,2021, the Company submitted itsApplication forApproval or Rejection of the
Purchase Power Agreement with Sunny Bar Ranch ("Sunny Bar"). The Agreement at issue is a
Power Purchase Agreement ("PPA") executed March 29 ,2021 ("Agreement"), under which Sunny
Bar agrees to use its existing facility, a qualifting facility under the Public Utility Regulatory
PoliciesAct of 1978, to provide power to the Company.
Commission staff filed comments on June l, 2021 recommending the Agreement be
amended to use one set of avoided cost rates with immediate capacity payments and to implement
to 90/ll0 Rule based on that rate structure. Commission staff also recommends that the
Commission allow both energy and capacity payments for the lapsed contract period, between
May l, 2021 and Commission approval of theAgreement, whichbecomes the effective date of the
Agreement. The Company agrees with both recommendations. The Company is the process of
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obtaining an amended Agreement with Sunny Bar consistent with the Commission staff
recommendation, which it will file with the Commission after execution.
The original PPA, executed in June 1985, between Sunny Bar and Utah Power and Light
Company stated that Sunny Bar's hydroelectric facility had a nameplate capacity rating of 350 kW.
During renewal of the PPA PacifiCorp asked for verification of the qualifuing facilities capacity
and was provided a nameplate image by Sunny Bar with a 450 kW rating.
Since the original contract received acapacity payment for the full generation, which never
exceeded 350 kW, and the 350 kW nameplate capacity rating was included in the Company's
Integrated Resource Plan the Company proposed that Sunny Bar receive a capacity and energy
payment for the original contracted amount of 350 kW and an energy payment for the additional
100 kW until the Company's first capacity deficiency date.
Staff confirmed that the PPA contains the 90/110 Rule as required by Commission Order
No.29632 and determined that the 10-day advance notice was reasonable. Staffrecommended
rather than having two sets of rates that only one avoided cost rate with immediate capacity
payment be approved. Staffalso recommended that this rate be applied to all generation from the
project during the lapsed period of the contract, the Company has no objection to Staffs proposals.
Based on Staff's recommendations, the Company is working with Sunny Bar to amend the
PPA with avoided cost rates that includes an immediate capacity payment. The Amended
agreement will be filed with the Commission as soon as it is executed by both parties. Therefore,
the Company respectfully requests that the Commission approve or reject the amended Agreement.
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Detod this 86 day of Junc, 2021.
Respectfttlly submittod by,
ROCKYMOI.'NIAIN POWER
fr,,q UJQrypr^,
rmily ur"/.o* Lt
Rocky MountainPower
1407 WestNorthTemple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
Emai} emilLweeener@pacifi corp.com
Attorney for Roclcy Mo,tfirtoin Power
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