20210602Reply Comments.pdf

Y ROCKY MOUNTAIN
POWER
A DIVISION OF PAOFICORP
Jvne2,202l
r.,._r.j:tlE,i.;
.1.:...-,i-:tEL
:Xii Jii;i -? Pi{ 2' 28
.-rr I ^- 'r- :'.. - 'r :L'l$tlOi'l, I .. .i''flI'i,
1407 W. North Temple, Suite 330
Salt Lake City, Utah &4116
VIA ELECTRONIC DELIWRY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
ll33l W. Chinden Blvd
Building 8 Suite 20LA
Boise,lD 83714
Re:CASE NO. PAC-E,-zI.II
IN TIIE MATTER OF TIIE APPLICATION FOR APPROVAL OR REJECTION
OF THE AMENDED POWER PURCHASE AGREEMENT BETWEEN
PACIFICORP AIID GEORGETOWN IRRIGATION
Dear Ms. Noriyrki:
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,
Joelle R. Steward
Vice-President of Regulation
Enclosures
"^..D
Emily Wegener (ISB #l 1614)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
FAX: [phone]
Email: emilv.weeener@pacifi corp.com
Attorneyfor Roclcy Mountain Power
BEFORE TIM IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF TIrE APPLTCATTON OF ) CASE NO. PAC-E-2l-U
PACIFICORP FORAPPROVAL OR REJECTION )
OF THE AMENDED PT]RCHASE POWER ) REPLY COMMENTS OF
AGREEMENT BETWEEN PACII'ICORPAI\D ) ROCKYMOUNINN POWER
GEORGETOWI\I IRRIGATION
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.
On April 8,2021, the Company submitted an Application for approval or rejection of the
purchase power agreement with Georgetown Irrigation ("Georgetown"). The Agreement at issue
is a power purchase agreement ("PPA") executed March 30,2021 ("Agreement"), under which
Georgetown agreed to use its existing facility, a qualifuing facility under the Public Utility
Regulatory Policies Act of 1978, to provide power to the Company.
The PPA filed with the Application was signed by Georgetown on March 25ft and executed
by the Company on March 30,2021. Commission Stafffiled comments on May 26,2021(*Staff
Comments"). Staffs Comments noted that the opening paragraph of the Amended PPAwas dated
March 25ft rather than March 30d', the date the PPA was executed. Statr recommended the
Commission approve the amended PPA contingent on the parties frling an updated PPA that
included the March 30m execution date.
Page I
Provided herewith is the updated PPAwith the March 30,2021, execution date. With the
modification noted above, the Company respectfully requests that the Commission approve or
reject the Agreement as requested in the Application.
Dated this 2od day of June,202l
Respectfully submitted by,
ROCKYMOI.JNTAIN POWER
A,4 UJehp" ,
Emily Wegder a
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
Email: [e-mail]
Attorneyfor Rocky Mountain Power
Page2
AI}IENDIffiNT
b
POWER P URCEASE AGREEMENT
bctwcen
GEORGETOWN IRRIGATION COMPAII"Y and
PecitiCorp
March 30,2021
This AMENDMEITIT (the'Amcndmcnf), dued
POWER PLTRCHASE AGREEMENT between PacifiCorp, an Orqon .corpmuion
fPacifiCorp), and Creorgetoum Inigcion Conpnrry (Sdlef), dated July 2, 1984 (as amendd
zupplemenrted and modified frrom time b timg the *PPA"). Caprtalired mms used but nc defined
in this Amendment shall have the meaning set ftrth in th PPA
RECITALS
A. The PPA was entered into pior to PacifiCorp's sepudion of its energry supply and
transmissim funaions as required by federal law and rqulaions. For this reason, &e
PPA includes prorrisions thataddress bodr energy sales ud interconnection requirements.
B. The PPA is scnduled to orpire by its terms on It[rch 3l,z0zl,and Sdler has orpressed
a desire to cmtinue to make sales ftom the Facility b P8cifiCory consi*ent with the
requirements ofthe Heral h$licUtility Reguloory Policies Act('PtlRPA'), as
implemented in the Sure of Idaho.
C. Seller has demmstrded to PacifiCorp thet the facility remains a "Qrnlifying Facilityr as
defined by PURPA and as implernented in the State of ldaho.
D. Seller and PacifiCorp are in the process of securing I new stand-alone interconnection
agreernentthat, once er(ecuted and all distibution system upgrades are constnrcted aud
in-service, will replace the interconnection provisions in the PPA
E. Dudng the puiod that the neoessaf,y distibution sy$cm upgndes are being complete(
PacifiConp and Seller have agreod to a limited exmsim to theterm of the PPA witr
updaed pncing for energy sales duing the ortended term of the PPA as described bdon,
AGREEMENT
PacifiCorp and Seller agree as follows.
Article I of the PPA is amended and restated to read as follows
"Unless terminatedearlier pursuantt to the tetms of this Agreemenl this Agreement
slall expire upt tlu earlier of (t) the effective fute of a new polver pnchose
agreement between PacifiCorp ud Seller pertaining to the Facility; or (ii) March
31, 2022.',
,ffir".* certain
I
2.
3
4.
5
6.
7
Ncwidr*anding any provisiur in the PFA to &e conrary, fr the perid beginning
Apnl l,2O2l0rorgh the end dilre tcrm of th PPA' PacifiCup shall pay Seller as
prwided in Bhibit A to flris Ammdmeffi forthe ffiSr orput ofthe Facility delivered
b the Poiff of Delivery as a{u*ed fs Losses.
Notlviftstanding arry provisior in the PPA to the confrary, PacifiCorp $all nd be
respmsible to purclnse &e o4prt dthe Fadlity etriry pcdods tha the Facility is
curtailed due to construdion and cmpleim of the disEibutim sysfiem upgnades calldfc in the final, new stand-alone interconnection agrwmcnt between Seller and
Pacifi Corp' s transurissiqr fiurctiqr.
Ihis Amendment slull be ed[ective moe signed and ddivered by both PacifiCorp and
Seller and apprwed by the ldaho Public tftilities Cmmission.
All odrer temls and prwisims ofthe PPA shall rsnain undunged. Each psrty hereby
ratifies and confirms ilrat orcept as orpressly amended hereby, all of the tenns,
conditions, covuanfiq represenmiog warranties and all drer provisims of fie PPA
reurain in full force and effect and are binding om such party, including Seller as
successtr in interest undertre PPA. '!
firis Amendment shall be gwerned by and cmsfrud in acoordance with the laws of
the State of Idaho (without rderence to its choice of law docuine).
lhis Amendmeut may be executod in multiple counterpartsr each ofwhich when so
oreorrcd and delivered shall be deemed to be an original and all of which trken
togefter shall constitrte but one andthe same insrument Ddivery of an oreorted
cornterpart of this Amendmert by electnonic tnansmission (n .pdf forrr) shall be
equatly as effective as delivery of a manually oreorted comt€rprt.
fsigt@oe pgefoilNs]
t
IN Wffi{ESS W}IEREOF, the parties bdm hivc canod this Amcndmetr to be crm&d in &eir
reopoctivt ntfliG8.
PeeffiCorp
By:Bruce66srffid,H#u*--.7 ftrc -lruunqrr
Name: BnrcGrlnrrddfrde: IUrrEh n,flUlt
Cw$ffilnlrriSrdotr
fiflo:
It
,'
By:
l
t.I Ilr
t
EXEIBIT A
Enerq'Rate
Encrgr hrrchare Price = Enorgy Annual Ratc + Monthly Peak Muldplio
Tablc l: Energr Annuel Rrtca
Yeer
EnogrAnnuelRete
S[r{Wh
202t $23.83
20?2 $23.90
TaHe 2: Monthly On-Peak/Ofr-Peek Muttidicrg
Monlh On-Pcak
,Hours
Otr-Pcnk
IIonrs
Imuar l03%o 94o/"
Febnran,l05o/o YlY"
Itdarch 95o/.o $ff/"
Aoril 95o/"76Y"
Mn,92o/o 630/"
June 94s/"650/"
Iulv l2lo/o 92Yo
Ausust l2lo/o 1060/"
SeDmbcr l09/o 99/"
October ll1o/"l05o/o
Norrcmber ll(Jf/o 960/0
Decomber 129/"12tr/"
Where:
"Off-Peak Hcurs" means all hours that are nd On-Peak Hours.
..On-Pcak Hours' means all hours ending fr/:00:00 throrgh 22:@:00 MPf,
Mmday tkough S&rrday, excluding NERC designared holidays.
t