20210422Application.pdf

ROCKY MOUNTAIN
Fo\'t/ER :'l.i ilii i? Pl'i 3:55 1407IItEst North Temple, Suite 330
Salt Lake City, Utah &4116
r:'ill^.\l
r juj tU'i r
April22,2022
VIA ELECTRONIC DELIVERY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
I l33l W Chinden Blvd.
Building 8 Suite 20lA
Boise,ID 83714
Re:CASE NO. PAC-E.2I-I?
IN THE MATTER OF THE APPLICATION OF ROCKY MOTINTAIN POWER
REQUESTTNG APPROVAL OF THE Ar\TNUAL REVTSTON TO QF VARTABLE
ENERGY PRICES PTIRSUANT TO TERMS OF TIIE 1992 AMENDMENTS TO
POWER PURCHASE AGREEMENTS BETWEEN IDAHO QFs AIttD
PACIFICORP
Dear Ms. Noriyuki:
Enclosed for electonic filing in the above referenced matter is Rocky Mountain Power's
application and supporting attachment requesting approval of the annual revision to the qualified
facility variable energy prices.
Informal inquiries may be directed to Ted Weston,Idaho Regulatory Manager at(801)220-
2963.
Very truly yours,
Steward
V President,
Adam Lowney (tSB#10456)
McDowell Rackner Gibson PC
419 SW l ls Avenue, Suite 400
Portland, OR 97205
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Emily Wegener (Idaho Bar application pending)
1407 West North Temple, Suite 320
salt Lake city, utah 841l6
Telephone No. [phone]
Mobile No. [phone]
Email: Emi ly.wegener@pac iflcorp.com
Attorneys for Rocky Mountain Power
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER REQUESTING
APPROVAL OF THE AI\INUAL REVISION TO QTVARIABLE ENERGY PRICES PURSUANT TO
TERMS OF TIIE 1992 AMENDMENTS TO POWER
PURCHASE AGREEMENTS BETWEEN IDAHO
QFs AND PACIFICORP
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.ZI.I2
APPLICATION
Rocky Mountain Power, a division of PacifiCorp ("Company" or "Rocky Mountain
Power"), in accordance with the Rules of Procedure of the ldaho Public Utilities Commission
("Commission"), Rule 52 and Order N o.29316,1 hereby respectfully petitions the Commission for
an order approving the updated Qualifring Facility ("QF") variable energy price pursuant to the
terms of the 1992 amendments to Idaho QF power purchase agreements. [n support of this
Application, Rocky Mountain Power represents as follows:
I In the Matler of the Revision of QF Variable Energt Prices in Accordance with Terms of the 1992 Amendments to
Power Purchase Agreements between ldaho QFs and PaciJiCorp, PAC-E-03-10,2004 WL 316976 (Idaho P.U.C.
August 19,2003).
I. INTRODUCTION AI{D BACKGROUND
In 2003, the Company sent a letter notiffing the Commission of a July l, 2003, revision to
the variable energy price for QFs holding certain power sales contracts with the Company. These
thirteen QF contracts included a Commission-approved 1992 Amendment outlining the
methodology that would be used for determining the variable energy price component of the
avoided cost rate.
As stated in the 1992 Amendment beginning July l, 2003 and continuing throughout the
term of the power purchase agreements, including any extensions, the variable energy rate will be
calculated in accordance with the specified methodology described below.
The variable energy rate will be the sum of PacifiCorp's fuel cost and Colstrip variable
O&M cost. PacifiCorp's fuel costs will be the average cost of fuel consumed in its Utah Division,
specifically the Carbon, Hale, Naughton, Huntington, and Hunter generating plants. If any of the
specified plants fail to operate in any calendar year, such plant will be excluded from the
calculation of the average cost of fuel. Carbon and Hale coal plants have subsequently closed and
are excluded from the calculation. The average cost of fuel will be calculated using the data
reported in the Company's FERC Form l. [n the event that the FERC Form I ceases to include the
cost of fuel or net generation data, comparable data based upon the Company's normal accounting
practices shall be used.
Pursuant to Order No. 23738,2 variable O&M costs were set based on the variable costs
associated with the operation of Colstrip, a coal power generating facility in southeast Montana,
excluding the generation tax and the line loss adjustments.
2 In re ldaho Power Company, Case No. PPL-E-89-3ruPL-E-89-5, l99l WL 501613 (Idaho P.U.C. June 17, 1991).
2
IL VARIABLE ENERGYRATE
The average cost of fuel consumed by the specified Utah division coal plants for calendar
year 2020 was $21.51 per megawatt hour, as summarized in Attachment No. I filed with this
application. The variable operation and maintenance expense set for Colstrip generating facility
was $1.51 per megawatt hour. Therefore, the variable energy rate applicable to deliveries
commencing July l, 2021, extending through June 30, 2022, is $23.02 per megawatt hour.
Attachment No. I provided with the Application supports the calculation with references to the
relevant pages from the Company's FERC Form I for the year ending December 31,2020.
III. MODIFIED PROCEDURE
Rocky Mountain Power believes that a hearing is not necessary to consider the issues
presented herein and respectfully requests that this Application be processed under Modified
Procedure, i.e., by written submissions rather than by hearing in accordance with RP 201 et seq.
IV. COMMUNICATIONS AI\[D SERVICE OF PLEADINGS
Communications regarding this Application should be addressed to:
Ted Weston
Rocky Mountain Power
Idaho Regulatory Affairs Manager
1407 W. North Temple, Suite 330
Salt Lake City UT 841l6
Telephone: [phone]
Facsimile: [phone]
E-mail: ted.weston(iDpacifi corp.com
Emily Wegener
1407 West North Temple, Suite 320
Salt Lake city, Utah 841l6
Telephone No. (801) 2204526
Mobile No. [phone]
Email: Emi l),[e-mail]
3
ln addition, Rocky Mountain Power respectfully requests that all data requests regarding this
matter be addressed to:
By e-mail (preferred): datarequest(@pacificom.com
By regular mail:
PacifiCorp
Data Request Response Center
825 NE Multnomah, Suite 2000
Portland, OR 97232
Informal inquires also may be directed to Ted Weston at [phone].
v. REQUEST FOR RELIEF
Rocky Mountain Power respectfully requests that the Commission issue an Order
authorizing this matter to be processed by Modified Procedure, and approving the variable energy
rate of $23.02 per megawatt hour applicable to the energy delivered from the 1992 QF contracts
commencing July 1,2021, extending through June 30, 2022.
Dated this22n day of April202l.
Respectfully submitted,
ROCKY MOLINTATN POWER
@McDowell Rackner Gibson PC
419 SW I ls Avenue, Suite 400
Portland, OR 97205
Telephone: [phone]
Fax: [phone]
Email: adam@,mrs-law.com
Emily L. Wegener (Idaho Bar admission pending)
1407 WestNorth Temple, Suite 320
Salt Lake city, utah 841l6
Telephone No. [phone]
Mobile No. [phone]
Email: Emily.wegener@pacifi corp.com
Attorneysfor Rocky Mountain Power
4
Attachment 1
PaclflCorp
Total Varlable Energy Rale
tor2O21 I 2022
Naughton Huntingiton Hunter
FuelCost ($) $ 73,662,576 $ 99,325,739 $ 130,667,159
2020 FERC FORM I - Paeca02 Linc m
Generation (MWH) 2,659,033 4,515,305 6,943,816
2020 FERC FORM'l -P{c402 Lin. 12
Average Fuel Cost ($n WH)
Variable O&M
Total Variable Energy Rate br 2021 I 2022
For ddivedes commencing July 1, 2021 extending through June 30, 2022
12 PacifiGorp/QFs contracfs with approved 1992 amendment language
Totals
$ 303,655,474
14,118,1il
21.51
1.51
23.4
$
$
$
/MWH
/MWH
/MWH
lD 2021 - Attach No. t Update Varlable Coal Errryy Rate (Jul21.jun22).{ex ( 2020 )