20220315Comments(7)_7.pdf

From:Sara Palma ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:PAC-E-21-19 Rocky Mountain Power IRP
Date:Monday, March 14, 2022 9:17:02 PM
Dear Idaho Public Utilities Commission,
I am writing to urge you to not accept the Rocky Mountain Power 2021 Integrated Resource Plan for filing. As one
of the region?s largest utilities?and largest polluters?the actions of this utility impact our entire state and all Idaho
utility customers like me. Rocky Mountain Power?s Plan relies on continued coal use even in the face of declining
coal economics and Clean Air Act violations at its coal plants. It also relies on last minute plans to build new gas
pipelines and convert some coal plants to gas, even in the face of highly volatile future gas prices. Lastly, it relies
on a last minute plan to build a new nuclear power facility using never-before-used technology with an unrealistic
timeline and budget. This all represents a huge risk for Idaho's future, from our air and the impacts of climate
change down to our pocketbooks.
Our state's other public utilities, Avista and Idaho Power, plan to stop burning coal by 2025 and 2028, respectively,
and are doubling down on investments in energy efficiency, renewable energy, and tested storage technology. It?s
unfair for Idaho customers whose only electric utility option is Rocky Mountain Power to face additional risks and
costs from their utility?s reckless planning. Idahoans deserve a utility Plan that ensures least cost and least risk
energy supply that is based in reality and thoughtful planning, not wishful false solutions. Please reject Rocky
Mountain Power?s 2021 Integrated Resource Plan.
Sincerely,
Sara Palma
1331 N Frazier Ave
Boise, ID 83704
[e-mail]
[phone]
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From:Shiva Rajbhandari ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:PAC-E-21-19 Rocky Mountain Power IRP
Date:Monday, March 14, 2022 11:15:13 PM
Dear Idaho Public Utilities Commission,
I?m a Junior at Boise High and a member of the Idaho Climate Justice League. I?m writing to ask you to PLEASE
stop Rocky Mountain Power from continuing to burn coal and destroy my home. Though I am a customer of Idaho
Power, climate change affects us all, and pollution from burning coal in the Northwest affects me very directly.
Please don?t be a fossil fool. Coal is not a financially nor ecologically viable source of energy. It?s time Rocky
Mountain moves into the 21st Century.
Sincerely,
Shiva Rajbhandari
721 Hearthstone Dr
Boise, ID 83702
[e-mail]
[phone]
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From:Audrey Plass ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:PAC-E-21-19 Rocky Mountain Power IRP
Date:Monday, March 14, 2022 11:27:02 PM
Dear Idaho Public Utilities Commission,
i want a future where we are clean and coal isn?t in that future
I am writing to urge you to not accept the Rocky Mountain Power 2021 Integrated Resource Plan for filing. As one
of the region?s largest utilities?and largest polluters?the actions of this utility impact our entire state and all Idaho
utility customers like me. Rocky Mountain Power?s Plan relies on continued coal use even in the face of declining
coal economics and Clean Air Act violations at its coal plants. It also relies on last minute plans to build new gas
pipelines and convert some coal plants to gas, even in the face of highly volatile future gas prices. Lastly, it relies
on a last minute plan to build a new nuclear power facility using never-before-used technology with an unrealistic
timeline and budget. This all represents a huge risk for Idaho's future, from our air and the impacts of climate
change down to our pocketbooks.
Our state's other public utilities, Avista and Idaho Power, plan to stop burning coal by 2025 and 2028, respectively,
and are doubling down on investments in energy efficiency, renewable energy, and tested storage technology. It?s
unfair for Idaho customers whose only electric utility option is Rocky Mountain Power to face additional risks and
costs from their utility?s reckless planning. Idahoans deserve a utility Plan that ensures least cost and least risk
energy supply that is based in reality and thoughtful planning, not wishful false solutions. Please reject Rocky
Mountain Power?s 2021 Integrated Resource Plan.
Sincerely,
Audrey Plass
1731 S Michigan Ave
Boise, ID 83706
[e-mail]
[phone]
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From:Kate Bernhardt ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:PAC-E-21-19 Rocky Mountain Power IRP
Date:Tuesday, March 15, 2022 7:30:11 AM
Dear Idaho Public Utilities Commission,
I am writing to urge you to not accept the Rocky Mountain Power 2021 Integrated Resource Plan for filing. As one
of the region?s largest utilities?and largest polluters?the actions of this utility impact our entire state and all Idaho
utility customers like me. Rocky Mountain Power?s Plan relies on continued coal use even in the face of declining
coal economics and Clean Air Act violations at its coal plants. It also relies on last minute plans to build new gas
pipelines and convert some coal plants to gas, even in the face of highly volatile future gas prices. Lastly, it relies
on a last minute plan to build a new nuclear power facility using never-before-used technology with an unrealistic
timeline and budget. This all represents a huge risk for Idaho's future, from our air and the impacts of climate
change down to our pocketbooks.
Our state's other public utilities, Avista and Idaho Power, plan to stop burning coal by 2025 and 2028, respectively,
and are doubling down on investments in energy efficiency, renewable energy, and tested storage technology. It?s
unfair for Idaho customers whose only electric utility option is Rocky Mountain Power to face additional risks and
costs from their utility?s reckless planning. Idahoans deserve a utility Plan that ensures least cost and least risk
energy supply that is based in reality and thoughtful planning, not wishful false solutions. Please reject Rocky
Mountain Power?s 2021 Integrated Resource Plan.
Sincerely,
Kate Bernhardt
1711 N 15th St
Boise, ID 83702
[e-mail]
[phone]
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If you need more information, please contact Lillian Miller at Sierra Club at [e-mail] or (415) 977-
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From:Taelyn Baiza ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:PAC-E-21-19 Rocky Mountain Power IRP
Date:Tuesday, March 15, 2022 9:42:43 AM
Dear Idaho Public Utilities Commission,
I am writing to urge you to not accept the Rocky Mountain Power 2021 Integrated Resource Plan for filing. As one
of the region?s largest utilities?and largest polluters?the actions of this utility impact our entire state and all Idaho
utility customers like me. Rocky Mountain Power?s Plan relies on continued coal use even in the face of declining
coal economics and Clean Air Act violations at its coal plants. It also relies on last minute plans to build new gas
pipelines and convert some coal plants to gas, even in the face of highly volatile future gas prices. Lastly, it relies
on a last minute plan to build a new nuclear power facility using never-before-used technology with an unrealistic
timeline and budget. This all represents a huge risk for Idaho's future, from our air and the impacts of climate
change down to our pocketbooks.
Our state's other public utilities, Avista and Idaho Power, plan to stop burning coal by 2025 and 2028, respectively,
and are doubling down on investments in energy efficiency, renewable energy, and tested storage technology. It?s
unfair for Idaho customers whose only electric utility option is Rocky Mountain Power to face additional risks and
costs from their utility?s reckless planning. Idahoans deserve a utility Plan that ensures least cost and least risk
energy supply that is based in reality and thoughtful planning, not wishful false solutions. Please reject Rocky
Mountain Power?s 2021 Integrated Resource Plan.
Sincerely,
Taelyn Baiza
2526 E Roanoke Dr
Boise, ID 83712
[e-mail]
[phone]
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club.
If you need more information, please contact Lillian Miller at Sierra Club at [e-mail] or (415) 977-
5500.
From:Thomas Rogers ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:PAC-E-21-19 Rocky Mountain Power IRP
Date:Tuesday, March 15, 2022 12:06:51 PM
Dear Idaho Public Utilities Commission,
I am writing to urge you to not accept the Rocky Mountain Power 2021 Integrated Resource Plan for filing. As one
of the region?s largest utilities?and largest polluters?the actions of this utility impact our entire state and all Idaho
utility customers like me. Rocky Mountain Power?s Plan relies on continued coal use even in the face of declining
coal economics and Clean Air Act violations at its coal plants. It also relies on last minute plans to build new gas
pipelines and convert some coal plants to gas, even in the face of highly volatile future gas prices. Lastly, it relies
on a last minute plan to build a new nuclear power facility using never-before-used technology with an unrealistic
timeline and budget. This all represents a huge risk for Idaho's future, from our air and the impacts of climate
change down to our pocketbooks.
Our state's other public utilities, Avista and Idaho Power, plan to stop burning coal by 2025 and 2028, respectively,
and are doubling down on investments in energy efficiency, renewable energy, and tested storage technology. It?s
unfair for Idaho customers whose only electric utility option is Rocky Mountain Power to face additional risks and
costs from their utility?s reckless planning. Idahoans deserve a utility Plan that ensures least cost and least risk
energy supply that is based in reality and thoughtful planning, not wishful false solutions. Please reject Rocky
Mountain Power?s 2021 Integrated Resource Plan.
Sincerely,
Thomas Rogers
1828 North Longridge Place
Eagle, ID 83616
[e-mail]
[phone]
This message was sent by KnowWho, as a service provider, on behalf of an individual associated with Sierra Club.
If you need more information, please contact Lillian Miller at Sierra Club at [e-mail] or (415) 977-
5500.
THE RENEWABLE ENERGY COALITION COMMENTS 1 of 10
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of PacifiCorp’s 2021
Integrated Resource Plan
Case No. PAC-E-21-19
THE RENEWABLE ENERGY COALITION COMMENTS
I.INTRODUCTION
The Renewable Energy Coalition (the “Coalition”) respectfully submit these Comments
for consideration by the Idaho Public Utilities Commission (the “Commission” or “IPUC”) in the
matter of PacifiCorp’s 2021 Integrated Resource Plan (“IRP”). PacifiCorp’s 2021 IRP assumes
that no qualifying facilities (“QFs”) will renew their contracts. Further, it does not appear
PacifiCorp produced a sensitivity analysis nor provided an adequate explanation of the impact of
renewing QF contracts on its load resource balance, or if it did it is not clearly articulated.
QFs provide value to the system when they renew their power purchase agreements
(“PPAs”). PacifiCorp has modeled the impact of renewing QFs on its resource acquisition
decisions, which demonstrate that QFs provide significant capacity value to PacifiCorp’s system.
The modeling from the 2019 IRP revealed that by assuming that all existing QFs will renew their
contracts at the end of their current PPAs, PacifiCorp would defer the acquisition of a simple-
cycle combustion turbine (“SCCT”) by three years. PacifiCorp should recognize the value QFs
provide in its IRP and should appropriately compensate them for this value when they renew
their PPAs.
PacifiCorp’s assumption that no QFs renew their contracts feeds into PacifiCorp’s
avoided cost pricing for renewing QFs. The Commission currently recognizes that existing QFs
RECEIVED
Tuesday, March 15, 2022 3:58 PM
IDAHO PUBLIC
UTILITIES COMMISSION

THE RENEWABLE ENERGY COALITION COMMENTS 2 of 10

that renew their contracts should be paid for their capacity for years at the end of their prior
PPAs because the QF is still providing the same value to PacifiCorp’s system. That policy
should continue regardless of PacifiCorp’s inaccurate assumptions regarding QF renewals.
II. COMMENTS
A. PacifiCorp’s QF Assumptions Are Not Consistent with Prudent and Reasonable
Planning
The Commission should not acknowledge PacifiCorp’s QF renewal assumptions because
they are unreasonable and not consistent with least cost and least risk planning.1 In addition,
PacifiCorp’s assumptions should be rejected because they are not the type of reasonable and
accurate assumptions that the Commission would allow a utility to make when setting fair, just,
and reasonable retail rates. The IRP process is designed to “explain the Company’s present
load/resource position, expected responses to possible future events” and “discuss any
flexibilities and analyses considered during comprehensive resource planning[.]”2
QF contracts, even more than other contracts without a mandatory purchase obligation,
should be appropriately and reasonably forecasted like other resources and costs that are
included in rates. QFs that entered into a contract, but are not yet commercially operational, are
generally expected to come on line, but they have a much lower chance of reaching their
commercial operation date than existing QFs that are already operating. The Coalition is not
aware of any other input or assumption in PacifiCorp’s IRP in which it is known for certain that
the cost or benefit will be incurred (here the renewal of most existing QF contracts), but that

1 In re PacifiCorp Application for Approval of 2019 IRP, IPUC Case No. PAC-E-19-16,
Order No. 34780 at 1 (Sept. 14, 2020) (“An IRP is a status report on the utility’s ongoing,
changing plans to serve its customers adequately and reliably at the lowest system cost
and least risk over the next 20 years.”).
2 IPUC Case No. PAC-E-19-16, Order No. 34780 at 1 (internal quotations omitted).

THE RENEWABLE ENERGY COALITION COMMENTS 3 of 10

PacifiCorp simply ignores the costs and benefits. QF renewals are one option PacifiCorp has to
help meet its load and resource forecast and should be addressed in its IRP.
B. PacifiCorp’s Inaccurate Assumptions Are an Outlier

1. Idaho Power Assumes the Majority of Its QFs Renew Their Contracts and
the Idaho Public Utilities Commission Requires Idaho Power to Compensates
QFs for the Capacity Value the Renewing QFs Provided
Idaho Power uses reasonable assumptions regarding QF renewals and the Commission
has recognized that renewing QFs provide capacity value to utilities. It is unreasonable to
assume a zero percent QF renewal rate and unreasonable not to compensate the QFs for the
capacity they provide to the utility. The Commission should require PacifiCorp to use
reasonable assumptions like Idaho Power and fairly compensate QFs for the capacity they
provide such as the Commission has required.
Idaho Power in its 2019 IRP assumes all non-wind QFs such as hydroelectric and solar
will renew after contract expiration.3 In the 2021 IRP, Idaho Power assumes 25 percent of wind
QFs will renew and performed sensitivities for low QF wind renewal (0 percent) and high QF
wind renewal (100 percent).4 Idaho Power bases its decision to assume 25 percent of wind QFs
will renew from “ongoing discussion with wind developers.”5
The Commission also requires utilities to appropriately compensate QFs for the capacity
they provide to the utility when the QF renews. The Commission
[found] it reasonable for utilities to establish capacity deficiency at
the time the initial. . . contract is signed. As long as the QF renews
its contract and continuously sells power to the utility, the QF is

3 In re Idaho Power Company IRP, Oregon Public Utility Commission (“OPUC”) Docket
No. LC 74, Renewable Energy Coalitions’ Final Comments at 5, n.9 & Attachment A
(Jan. 8, 2021).
4 In re Idaho Power 2021 IRP, IPUC Case No. IPC-E-21-43, Idaho Power 2021 IRP at 122
(Dec. 30, 2021).
5 IPUC Case No. IPC-E-21-43, Idaho Power 2021 IRP at 122.

THE RENEWABLE ENERGY COALITION COMMENTS 4 of 10

entitled to capacity based on the capacity deficiency date established
at the time of its initial contract.6
The Commission reasoned that “[t]his adjustment recognizes that in ensuing contract periods, the
QF is considered part of the utility’s resource stack and will be contributing to reducing the
utility’s need for capacity.”7
2. The Oregon Public Utility Commission Is Beginning to Require Oregon
Utilities to Conduct Reasonable Forecasts of QF Renewals
The Oregon Public Utility Commission (“Oregon Commission” or “OPUC”) has
provided guidance to utilities such as PacifiCorp to provide reasonable renewal assumptions in
IRPs. The OPUC has acknowledged that “non-renewal may not be the best planning assumption
when many (or most) QFs do, in fact, renew.”8 The Commission then, directed “PacifiCorp,
Staff and parties [to] discuss a potential study of the capacity value of renewing QFs, and Staff
shall bring this issue to a public meeting before the 2017 IRP Update.”9 PacifiCorp did provide
that analysis as discussed below. In the OPUC’s Order acknowledging PacifiCorp’s 2019 IRP,
the OPUC stated:
Regarding the QF issues, we accept PacifiCorp's commitment to
produce a sensitivity or other explanation of the impact of renewing
QFs on its load resource balance and direct PacifiCorp to include
this in its 2021 IRP. We appreciate Staff and REC showing us a
process for linking the quantification of QF capacity with the
valuation of that capacity in avoided cost rates. We expect that QF

6 In re Idaho Power Company’s, Avista Corporation’s, and Rocky Mountain Power
Company’s Petitions to Modify Terms and Conditions of PURPA Purchase Agreements,
IPUC Case Nos. IPC-E-15-01, AVU-E-15-01, PAC-E-15-03, Order No. 33357 at 25-26
(Aug. 20, 2015).
7 IPUC Case Nos. IPC-E-15-01, AVU-E-15-01, PAC-E-15-03, Order No. 33357 at 26.
8 In re PacifiCorp 2017 Integrated Resource Plan, OPUC Docket No. LC 67, Order No.
18-138 at 12 (Apr. 27, 2018).
9 OPUC Docket No. LC 67, Order No. 18-138, Appendix A at 22.

THE RENEWABLE ENERGY COALITION COMMENTS 5 of 10

renewals provide some capacity value and will consider this issue
further in other proceedings.10
Thus, the OPUC acknowledged that QF renewals provide some capacity value and directed
PacifiCorp to complete a sensitivity analysis regarding QF renewals on its load resource balance
or provide another explanation of the impact of renewing QFs.11
In Idaho Power’s 2019 IRP, the OPUC concluded that Idaho Power was not accurately
estimating whether certain wind QFs were renewing their contracts ordering Idaho Power to
develop “reasonable assumptions through a sensitivity analysis” and “explain how the
sensitivities resulting from the study would affect the IRP’s preferred portfolio and action plan if
incorporated” for its next IRP.12 The OPUC acknowledged Idaho Power’s assumption that all
non-wind QFs will renew their contracts.
Further, in Portland General Electric Company’s (“PGE’s”) 2019 IRP, the Oregon
Commission ordered PGE to “refresh the same inputs that it updated in November 2019 in this
proceeding, with…updated QF levels and sensitivities[.]”13 All of these IRP directives to
produce QF sensitivity analyses suggest the Oregon Commission’s intent in PacifiCorp’s 2019
IRP acknowledgement was for PacifiCorp to produce a similar sensitivity analysis or equivalent
explanation. PacifiCorp’s explanation in its 2021 IRP is not adequate or equivalent to a
sensitivity analysis.

10 In re PacifiCorp 2019 IRP, OPUC Docket No. LC 70, Order No. 20-186 at 13 (June 8,
2020).
11 PacifiCorp has stated it elected to provide an “other explanation” in lieu of a sensitivity
analysis. The Coalition does not believe this “other explanation” is adequate and the
issue is being addressed in OPUC Docket No. LC 77.
12 In re Idaho Power Company 2019 Integrated Resource Plan, OPUC Docket No. LC 74,
Order No. 21-184 at 19-20 (June 4, 2021).
13 In re Portland General Electric Company 2019 Integrated Resource Plan, OPUC Docket
No. LC 73, Order No. 20-152 at 12 (May 6, 2020).

THE RENEWABLE ENERGY COALITION COMMENTS 6 of 10

In OPUC Docket No. UM 1728, PGE also committed to develop “QF online and renewal
sensitivity analyses” in advance of its next IRP.14 Specifically, PGE stated
For QFs with contracts that are executed but that are not yet
operational at the time of the snapshot, PGE will examine factors
including but not be limited to: the historic percentage of PGE’s QFs
having reached commercial operations, the opportunities to sell
power to other utilities, sophistication and experience of project
developers, contractual provisions, technology, and interconnection
risks. At least one analysis will start with PGE’s historic percentage
of PGE’s QFs that have reached commercial operations. For QF
renewals, PGE will examine factors including but not limited to: the
historic percentage of PGE’s QFs that have renewed their contracts,
the sophistication and experience of project developers, contractual
provisions, technology, the opportunity to sell power to other
utilities, and interconnection risks. At least one analysis will start
with PGE’s historic percentage of PGE’s QFs that have renewed
their contracts. PGE will also review the historic percentage of QFs
reaching completion and renewals for other utilities.15
C. PacifiCorp Should Assume that All or the Vast Majority of Operating QFs Will
Renew and Enter into New PPAs
It is not reasonable to assume that no QFs will continue operating and delivering power
to PacifiCorp beyond their current PPA. Utilities should consider any resource that could help
meet its “present load/resource position” or “responses to possible future events” in a least cost
and least risk manner.16 In PacifiCorp’s 2021 IRP, PacifiCorp assumes no QFs will renew their
contracts.17 The Commission should request PacifiCorp to assume that all or a reasonable
amount of QFs will renew their PPAs.

14 In re PGE Updates to Schedule 201 QF (10 MW or less) Avoided Cost, OPUC Docket
No. UM 1728, Order No. 21-215, Appendix A at 12 (July 6, 2021).
15 OPUC Docket No. UM 1728, Order No. 21-215, Appendix A at 12.
16 IPUC Case No. PAC-E-19-16, Order No. 34780 at 1.
17 PacifiCorp’s 2021 IRP, Figure 6.2 – Contract Capacity in the 2021 IRP Summer Load
and Resource Balance at 148 (depicting a decline of QF contracts from 2021 to virtually
none in 2040); See Tables 6.11, 6.12, 9.17, 9.18, and 9.19 at 154-57, 307-12 (similar
trends as in Figure 6.2).

THE RENEWABLE ENERGY COALITION COMMENTS 7 of 10

It is more likely than not that a QF will renew or seek to enter a new contract with
PacifiCorp at the conclusion of its current contract. A new QF can often decide in which utility’s
service territory it wants to locate to achieve the best outcome. However, once operational, the
QF has fewer options to sell its electricity, because it will likely incur significant transmission
charges if it wants to sell to a more distant utility. While some QFs are able to sell to a more
distant utility, the vast majority continue to sell to their currently interconnected utility.
Therefore, existing QFs are more likely to renew or enter a new contract with the utility to which
they are already directly interconnected.
PacifiCorp’s own records show that virtually all QFs will continue operating and renew
their contracts. At the time of PacifiCorp’s last IRP, of the thirty-six QFs that have had a PPA
with PacifiCorp expire, only one has shut down.18 The vast majority have renewed or executed a
new contract with PacifiCorp and will continue to operate and provide significant value to
PacifiCorp’s system for years to come. For example, BYU Idaho in Idaho, a 5.6 MW natural gas
facility, initially executed a PPA with PacifiCorp in 2015, which expired in 2017, and is
currently operating under a renewed contract that does not expire until 2037.19 Another example
in Idaho is Preston City Hydro, a 0.4 MW hydro facility, initially executed a PPA with
PacifiCorp in 1982, which expired in 2017, and is currently operating under a renewed contract
that does not expire until 2032.20 PacifiCorp has been renewing QF contracts for longer than late

18 See OPUC Docket No. LC 70, Renewable Energy Coalition Opening Comments,
Attachment B (PacifiCorp’s Response to Coalition Data Request 1 and Attachment REC
1 dated Nov. 26, 2019) (Jan. 10, 2020). Note: one other QF appears to have renewed at
the expiration of its initial PPA, but then apparently “self-terminated.” It is not clear
whether this QF has shut down completely or chose to sell to someone else.
19 Attachment A (PacifiCorp Data Response to Renewable Energy Coalition Data Request 5
in OPUC Docket No. LC 77).
20 Attachment A.

THE RENEWABLE ENERGY COALITION COMMENTS 8 of 10

2010. For example, Biomass One, L.P., an approximately 30 MW biomass facility, initially
executed a PPA with PacifiCorp in 1987, which expired in 2011, and is currently operating under
a renewed contract that does not expire until 2036.21 Farmers Irrigation District, which operates
a 4.15 MW hydro facility, initially executed a PPA in 1983, which expired in 2010, and
continues to operate under a renewed PPA expiring in 2025.22 These QFs are examples of the
types of businesses that have been providing PacifiCorp with power for decades yet are not fully
compensated for the capacity value they provide.
These QFs show that a QF’s lifespan significantly outlasts that of a single PPA. Many of
these facilities are built to last 100 years, and a single PPA entered into now is only a maximum
of 15-20 years long depending on the state policies regarding contract term length. It is rare for
one of these plants to shut down after the initial PPA. This is especially true because many QFs
likely acquire their up-front capital financing based only on the initial PPA, so continuing to
operate beyond that first PPA, could theoretically be under much more favorable economics.
Thus, it is more likely that all QFs will renew or that nearly all will renew, and at a
minimum, PacifiCorp’s default assumption that no QFs renew is not correct.
D. QFs Provide Significant Capacity Value to PacifiCorp
QFs provide significant value to PacifiCorp. PacifiCorp ultimately provided a study in
response to the OPUC’s Order in Docket No. LC 67, which models QF renewals.23 The results

21 OPUC Docket No. LC 70, Renewable Energy Coalition Opening Comments, Attachment
B (PacifiCorp’s 1st Supplemental Response to Coalition Data Request 4 dated Dec. 18,
2019).
22 Attachment A.
23 See OPUC Docket No. LC 70, Renewable Energy Coalition Opening Comments,
Attachment B (PacifiCorp’s 1st Supplemental Response to Coalition Data Request 4
dated Dec. 18, 2019).

THE RENEWABLE ENERGY COALITION COMMENTS 9 of 10

appear significant.24 Assuming that all QF PPAs continued through the end of the study period,
an SCCT that would have been constructed in 2026 is pushed out to 2029, and an additional
SCCT replaces some battery storage in 2029.25
This analysis reveals that assuming QF renewals can have a major impact on
PacifiCorp’s forecasted capacity needs and the more fundamental point: existing QFs already
provide significant capacity value and should be compensated for it when they renew.
E. The Commission Should Continue to Acknowledge the Value of Existing QF
Capacity
In the IRP process, the Commission should once again acknowledge that QFs provide
significant capacity value to PacifiCorp and request that PacifiCorp recognize such value as well.
While the Commission does not address QF avoided cost pricing in the IRP process, the
assumptions made in the IRP often flow directly into the avoided costs. The Commission should
continue to require that PacifiCorp simply continue paying a QF the capacity payment at the
beginning of their renewed PPA, i.e., there would be no “sufficiency period” at the beginning of
the new contract. The Coalition believes this is one viable option to compensate QFs for the
capacity they provide, and the Coalition requests the Commission continue this policy.
III. CONCLUSION
For the reasons articulated herein, the Commission should not acknowledge PacifiCorp’s
2021 IRP assumptions, request that PacifiCorp assume that QFs will renew or enter new
contracts with PacifiCorp at the end of their current contracts, request PacifiCorp to complete a

24 The Coalition has not independently verified the accuracy of PacifiCorp’s methodology
in that study.
25 See OPUC Docket No. LC 70, Renewable Energy Coalition Opening Comments,
Attachment B (PacifiCorp’s 1st Supplemental Response to Coalition Data Request 4
dated Dec. 18, 2019).
THE RENEWABLE ENERGY COALITION COMMENTS 10 of 10
sensitivity analysis, and require PacifiCorp to continue paying a QF the capacity payment at the
beginning of their renewed PPA.
Dated this 15th day of March 2022.
Respectfully submitted,
Sanger Law, PC
____________________
Irion A. Sanger
Ellie Hardwick
4031 SE Hawthorne Blvd.
Portland, OR 97214
503-756-7533 (tel)
503-334-2235 (fax)
[e-mail]
Of Attorneys for the Renewable Energy Coalition
Attachment A

PacifiCorp Data Response to Renewable Energy Coalition Data Request 5 in
OPUC Docket No. LC 77 (PacifiCorp 2021 IRP)
LC 77 / PacifiCorp February 3, 2022 REC Data Request Set 2 (5)

Despite PacifiCorp's diligent efforts, certain information protected from disclosure by the attorney-client privilege or other applicable privileges or law may have been included in its responses to these data requests. PacifiCorp did not intend to waive any applicable privileges or rights by the inadvertent disclosure of protected information, and PacifiCorp reserves its right to request the return or destruction of any privileged or protected materials that may have been inadvertently disclosed. Please inform PacifiCorp immediately if you become aware of any inadvertently disclosed information.
REC Data Request 5 Please refer to REC Data Request 1.1 and PacifiCorp’s Response to REC Data Request 1.1 including Attachment REC 1.1. For each qualifying facility, please indicate the state
where the facility is located. Please provide this information in an updated version of
Attachment REC 1.1. Response to REC Data Request 5

The Company continues to object to REC Data Request 1 and now REC Data Request 5 on grounds that it seeks information that is not relevant and the request is not reasonably calculated to lead to information relevant to the discovery of admissible evidence. The 2021 Integrated Resource Plan (IRP) is forward looking, covering the period 2021 through 2040. Qualifying facilities (QF) included in the IRP are existing / executed QF
power purchase agreements (PPA). The IRP does not make any assumptions for QF
PPAs based on historical information. Subject to and without waiving the foregoing objection and based on the foregoing clarification, the Company responds as follows:
Please refer to the Company’s 1st Supplemental response to REC Data Request 1.
(a)(b)(c)(d) (e)(f)(g)(h)(i)(j)
Plant Name PPA Execution Date Resource Type Nameplate
Capacity (MW)
Commercial Operation
Date (COD)Original COD
Type of PPA
(Standard / Non-
standard)
Current PPA Expiration
Date
Vintage of
PPA Facility / PPA Status State
Adams Solar Center, LLC August 7, 2014 Solar 10.0 July 27, 2018 November 27, 2017 Standard October 30, 2036 Original Operating Oregon
Bear Creek Solar Center, LLC August 7, 2015 Solar 10.0 September 28, 2018 December 8, 2017 Standard October 30, 2036 Original Operating Oregon
Bell Mountain Hydro LLC (Ted Sorenson)February 4, 2010 Hydro 0.28 February 4, 2010 December 1, 2009 Standard August 31, 2029 Original Operating Idaho
Bell Mountain Power (Jake Amy)January 3, 1985 Hydro 0.45 December 1, 1986 January 3, 1985 Standard December 31, 2021 Original Operating Idaho
Bell Mountain Power (Jake Amy)November 18, 2020 Hydro 0.60 December 1, 1986 January 3, 1985 Standard December 31, 2022 Amended Amendment executed Idaho
Beryl Solar June 4, 2013 Solar 3.0 August 24, 2015 July 31, 2015 Standard July 30, 2035 Original Operating Utah
Big Top LLC (QF)December 19, 2008 Wind 1.65 August 1, 2009 March 24, 2009 Standard January 29, 2029 Original Operating Oregon
Birch Creek Hydro August 21, 1984 Hydro 2.65 August 21, 1994 August 21, 1994 Standard December 31, 2040 Original Operating Idaho
Bly Solar Center, LLC July 24, 2014 Solar 8.5 December 21, 2018 January 24, 2018 Standard October 30, 2036 Original Operating Oregon
Bogus Creek March 11, 1983 Hydro 0.16 March 11, 1983 March 11, 1983 Unknown December 31, 1997 Original PPA Expired California
Bogus Creek Amended Hydro 0.16 Existing Existing Unknown December 31, 2040 Amended Operating California
Buckhorn June 4, 2013 Solar 3.0 December 23, 2015 July 31, 2015 Standard July 30, 2035 Original Operating Utah
Bureau of Land Management - Rawlins Office August 13, 2012 Wind 0.10 March 12, 2013 August 13, 2012 Standard August 31, 2022 Original Operating Wyoming
Butter Creek Power LLC December 19, 2008 Wind 4.95 August 1, 2009 March 12, 2009 Standard January 29, 2029 Original Operating Oregon
BYU Idaho January 23, 2015 Natural Gas 5.60 September 30, 2015 August 1, 2015 Standard July 31, 2017 Original PPA Expired Idaho
BYU Idaho Renewal Natural Gas 5.60 Existing Existing Standard September 28, 2037 Renewal Operating Idaho
C Drop October 18, 2011 Hydro 1.10 May 3, 2012 March 15, 2012 Standard May 02, 2032 Original Operating Oregon
Captain Jack Solar June 8, 2020 Solar 2.70 Not COD yet December 31, 2021 Standard December 30, 2041 Original Construction Oregon
Cargill, Q3 (Kettle Butte Dairy)February 8, 2011 Biogas 1.70 June 14, 2011 February 26, 2011 Standard February 28, 2021 Original PPA Expired Idaho
CDM Hydro December 4, 1984 Hydro 6.00 March 1, 1986 December 4, 1984 Standard March 31, 2021 Original PPA Expired Idaho
CDM Hydro March 29, 2020 Hydro 7.45 Existing Existing Standard March 31, 2041 Renewal Operating Idaho
Cedar Valley June 4, 2013 Solar 3.0 December 7, 2015 September 12, 2015 Standard July 30, 2035 Original Operating Utah
Central Oregon Irrigation District April 12, 1983 Hydro 6.00 September 1, 1989 September 1, 1989 Standard December 30, 2020 Original PPA Expired Oregon
Central Oregon Irrigation District Renewal Hydro 6.00 Existing Existing Standard December 31, 2024 Renewal Operating Oregon
Central Oregon Irrigation District - Juniper Ridge August 17, 2009 Hydro 5.00 October 4, 2010 October 4, 2010 Standard August 01, 2030 Original Operating Oregon
Chiloquin Solar October 12, 2015 Solar 9.90 January 26, 2018 October 30, 2017 Standard December 15, 2036 Original Operating Oregon
City of Albany, Dept of Public Works April 4, 2008 Hydro 0.50 January 20, 2009 April 7, 2008 Standard October 09, 2023 Original Operating Oregon
City of Astoria January 5, 2015 Hydro 0.03 April 8, 2015 February 10, 2015 Standard December 18, 2029 Original Operating Oregon
City of Buffalo October 26, 1995 Hydro 0.20 August 1, 1997 August 1, 1997 Standard December 31, 2015 Original PPA Expired Wyoming
City of Buffalo Renewal Hydro 0.20 Existing Existing Standard December 31, 2021 Renewal Operating Wyoming
City of Portland, Portland Hydro Bureau April 4, 2008 Hydro 0.03 November 1, 2012 December 1, 2011 Standard February 28, 2027 Original Operating Oregon
Commercial Energy Management November 21, 1991 Hydro 0.90 May 1, 1993 January 1, 1992 Unknown May 31, 2020 Original PPA Expired Idaho
Commercial Energy Management March 20, 2020 Hydro 0.90 May 1, 1993 January 1, 1992 Unknown February 28, 2021 Amended PPA Expired Idaho
Commercial Energy Management February 26, 2021 Hydro 0.90 May 1, 1993 January 1, 1992 Unknown November 30, 2036 Renewal Operating Idaho
Consolidated Irrigation Company September 11, 2015 Hydro 0.48 September 16, 2015 September 16, 2015 Standard October 26, 2035 Original Operating Idaho
Cottonwood Hydro (FKA Alta Energy)October 23, 2003 Hydro 1.10 January 1, 2005 January 1, 2005 Standard December 31, 2008 Original PPA Expired Utah
Cottonwood Hydro (FKA Alta Energy)Renewal Hydro 1.10 Existing Existing Standard December 31, 2009 Renewal PPA Expired Utah
Cottonwood Hydro (FKA Alta Energy)Renewal Hydro 1.10 Existing Existing Standard December 31, 2011 Renewal PPA Expired Utah
Cottonwood Hydro (FKA Alta Energy)Renewal Hydro 1.10 Existing Existing Standard December 31, 2025 Renewal Operating Utah
Deschutes Valley Hydro District June 29, 1982 Hydro 4.30 January 1, 1985 November 15, 1982 Unknown December 31, 2020 Original PPA Expired Oregon
Deschutes Valley Hydro District Renewal Hydro 4.30 Existing Existing Standard December 31, 2035 Renewal Operating Oregon
Dorena Hydro April 28, 2011 Hydro 6.10 December 11, 2014 December 1, 2012 Standard November 30, 2032 Original Operating Oregon
Draper Irrigation Company October 14, 2004 Hydro 0.51 October 14, 2004 September 1, 2004 Standard October 13, 2006 Original PPA Expired Utah
Draper Irrigation Company Renewal Hydro 0.51 Existing Existing Standard October 13, 2009 Renewal PPA Expired Utah
Draper Irrigation Company Renewal Hydro 0.51 Existing Existing Standard October 13, 2012 Renewal PPA Expired Utah
Draper Irrigation Company Renewal Hydro 0.51 Existing Existing Standard February 29, 2032 Renewal Operating Utah
Dry Creek May 2, 1986 Hydro 4.00 April 1, 1987 May 2, 1986 Unknown April 30, 2022 Original Operating Idaho
Dry Creek April 20, 2021 Hydro 4.00 April 1, 1987 May 2, 1986 Standard April 30, 2042 Renewal Renewal executed Idaho
Eagle Point Irrigation District (Nichols Gap)September 28, 1983 Hydro 0.72 March 1, 1987 September 28, 1983 Unknown December 31, 2021 Original Operating Oregon
EBD Hydro (Apple)April 6, 2012 Hydro 2.99 June 11, 2015 April 15, 2013 Standard April 14, 2028 Original Operating Oregon
Elbe Solar Center, LLC August 7, 2014 Solar 10.0 August 10, 2018 December 5, 2017 Standard October 30, 2036 Original Operating Oregon
Enterprise Solar LLC June 12, 2014 Solar 80.0 July 29, 2016 October 31, 2016 Non standard July 21, 2036 Original Operating Utah
Escalante Solar I LLC June 12, 2014 Solar 80.0 August 31, 2016 October 31, 2016 Non standard August 30, 2036 Original Operating Utah
Escalante Solar II LLC June 12, 2014 Solar 80.0 August 31, 2016 October 31, 2016 Non standard August 30, 2036 Original Operating Utah
Escalante Solar III LLC June 12, 2014 Solar 80.0 August 31, 2016 October 31, 2016 Non standard August 30, 2036 Original Operating Utah
Farm Power Misty Meadow March 29, 2012 Biogas 0.75 May 6, 2013 March 29, 2012 Standard September 30, 2027 Original Operating Oregon
Farmers Irrigation June 29, 1983 Hydro 4.15 June 29, 1987 June 29, 1983 Unknown December 31, 2010 Original PPA Expired Oregon
Farmers Irrigation Renewal Hydro 4.15 Existing Existing Standard December 31, 2025 Renewal Operating Oregon
REC Data Request 1 Additional Column
Plant Name PPA Execution Date Resource Type Nameplate
Capacity (MW)
Commercial Operation
Date (COD)Original COD
Type of PPA
(Standard / Non-
standard)
Current PPA Expiration
Date
Vintage of
PPA Facility / PPA Status State
Fiddler's Canyon 1 May 29, 2013 Solar 3.0 September 22, 2015 May 30, 2015 Standard May 29, 2035 Original Operating Utah
Fiddler's Canyon 2 May 29, 2013 Solar 3.0 September 22, 2015 May 30, 2015 Standard May 29, 2035 Original Operating Utah
Fiddler's Canyon 3 October 29, 2013 Solar 3.0 December 21, 2015 October 15, 2015 Standard October 14, 2035 Original Operating Utah
Finley Bioenergy October 24, 2007 Biogas 4.80 December 25, 2007 October 24, 2007 Standard November 15, 2022 Original Operating Oregon
Four Corners Windfarm LLC June 16, 2009 Wind 10.00 September 11, 2009 September 11, 2009 Standard June 30, 2029 Original Operating Oregon
Four Mile Canyon Windfarm LLC June 16, 2009 Wind 10.00 September 11, 2009 September 11, 2009 Standard June 30, 2029 Original Operating Oregon
Galesville Dam (Douglas County)September 1, 1982 Hydro 1.80 February 1, 1987 September 1, 1982 Unknown December 31, 2021 Original Operating Oregon
Georgetown Irrigation July 2, 1984 Hydro 0.33 December 1, 1985 December 15, 1984 Unknown March 31, 2021 Original PPA Expired Idaho
Georgetown Irrigation March 30, 2021 Hydro 0.33 December 1, 1985 December 15, 1984 Unknown March 31, 2022 Amended Operating Idaho
Granite Mountain East April 6, 2015 Solar 80.0 September 21, 2016 October 31, 2016 Non standard August 11, 2036 Original Operating Utah
Granite Mountain West April 6, 2015 Solar 50.4 September 30, 2016 October 31, 2016 Non standard September 07, 2036 Original Operating Utah
Granite Peak October 18, 2013 Solar 3.0 August 21, 2015 July 31, 2015 Standard July 30, 2035 Original Operating Utah
Greenville June 4, 2013 Solar 2.2 October 29, 2015 July 31, 2015 Standard July 30, 2035 Original Operating Utah
Hill Air Force Base January 10, 2005 Biogas 2.46 January 10, 2005 January 10, 2005 Standard January 09, 2025 Original Operating Utah
Iron Springs Solar April 6, 2015 Solar 80.0 August 15, 2016 October 31, 2016 Non standard August 14, 2036 Original Operating Utah
J Bar 9 Ranch August 15, 2011 Wind 0.10 November 17, 2011 October 31, 2011 Standard October 31, 2016 Original PPA Expired Wyoming
J Bar 9 Ranch Renewal Wind 0.10 Existing Existing Standard October 31, 2018 Renewal PPA Expired Wyoming
J Bar 9 Ranch Renewal Wind 0.10 Existing Existing Standard December 31, 2020 Renewal PPA Expired Wyoming
J Bar 9 Ranch October 12, 2020 Wind 0.10 Existing Existing Standard October 31, 2025 Amended Operating Wyoming
Klamath Falls Solar 1 (FKA Ewauna Solar LLC)August 8, 2014 Solar 0.8 July 12, 2016 September 30, 2015 Standard September 29, 2035 Original Operating Oregon
Klamath Falls Solar 2 (FKA Ewauna Solar 2 LLC)June 5, 2015 Solar 2.9 December 16, 2017 November 30, 2017 Standard November 29, 2037 Original Operating Oregon
Lacomb Irrigation (CHI)October 28, 1982 Hydro 0.96 January 1, 1984 January 1, 1984 Unknown Original PPA Expired Oregon
Lacomb Irrigation (Lacomb PPA Renegotiated)June 19, 1998 Hydro 0.96 July 1, 1987 Existing Unknown December 31, 2022 Amended Operating Oregon
Laho #1 October 18, 2013 Solar 3.0 July 14, 2015 July 31, 2015 Standard July 30, 2035 Original Operating Utah
Lake Siskiyou (Box Canyon)March 14, 1983 Hydro 5.00 August 1, 1986 March 14, 1983 Unknown December 31, 2020 Original Operating California
Latigo Wind July 3, 2013 Wind 60.0 March 11, 2016 May 1, 2015 Non standard April 30, 2035 Original Operating Utah
Loyd Fery June 28, 1985 Hydro 0.04 June 28, 1985 June 28, 1985 Unknown June 30, 2003 Original PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2004 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2005 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2006 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2007 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2008 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2009 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2010 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2011 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2012 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2013 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2014 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2015 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2016 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2017 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2018 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2019 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2020 Renewal PPA Expired Oregon
Loyd Fery Renewal Hydro 0.04 Existing Existing Standard June 30, 2024 Renewal Operating Oregon
Luckey, Paul April 27, 1983 Hydro 0.05 January 1, 1987 April 27, 1983 Unknown December 31, 2018 Original Shutdown California
Luckey, Paul Renewal Hydro 0.05 Existing Existing Non standard December 31, 2020 Renewal Shutdown California
Luckey, Paul Renewal Hydro 0.05 Existing Existing Non standard December 31, 2035 Renewal Operating California
Mariah Wind April 1, 2014 Wind 10.0 Terminated December 1, 2018 Standard August 31, 2030 Original Not built/terminated Oregon
Marsh Valley Hydro & Electric Company November 21, 1986 Hydro 1.70 November 21, 1986 November 21, 1986 Standard March 28, 2028 Original Operating Idaho
Meadow Creek Project Company - Five Pine January 4, 2012 Wind 40.00 December 22, 2012 December 22, 2012 Standard December 30, 2032 Original Operating Idaho
Meadow Creek Project Company - North Point January 4, 2012 Wind 80.00 December 11, 2012 December 11, 2012 Standard December 30, 2032 Original Operating Idaho
Middlefork Irrigation District June 29, 1983 Hydro 3.70 September 29, 1983 September 29, 1983 Unknown December 31, 2005 Original PPA Expired Oregon
Middlefork Irrigation District Renewal Hydro 3.70 Existing Existing Standard December 31, 2006 Renewal PPA Expired Oregon
Middlefork Irrigation District Renewal Hydro 3.70 Existing Existing Standard December 31, 2021 Renewal Operating Oregon
Middlefork Irrigation District Renewal Hydro 0.98 Existing Existing Standard December 31, 2021 Renewal In effect January 1, 2022 Oregon
Milford 2 April 4, 2014 Solar 3.0 December 21, 2015 October 15, 2015 Standard October 14, 2035 Original Operating Utah
Milford Flat October 18, 2013 Solar 3.0 July 23, 2015 July 31, 2015 Standard July 30, 2035 Original Operating Utah
Mink Creek Hydro May 21, 1985 Hydro 2.70 December 1, 1986 May 21, 1985 Unknown March 31, 2022 Original Operating Idaho
Mink Creek Hydro May 25, 2021 Hydro 2.95 December 1, 1986 May 21, 1985 Standard March 31, 2042 Renewal Renewal Executed Idaho
Monroe Hydro (Apple)April 9, 2012 Hydro 0.3 June 9, 2016 April 1, 2015 Standard August 31, 2028 Original Operating Oregon
Plant Name PPA Execution Date Resource Type Nameplate
Capacity (MW)
Commercial Operation
Date (COD)Original COD
Type of PPA
(Standard / Non-
standard)
Current PPA Expiration
Date
Vintage of
PPA Facility / PPA Status State
Mountain Energy June 17, 1985 Hydro 0.05 January 1, 1986 June 17, 1985 Unknown December 31, 2004 Original PPA Expired Oregon
Mountain Energy Renewal Hydro 0.05 Existing Existing Standard December 31, 2005 Renewal PPA Expired Oregon
Mountain Energy Renewal Hydro 0.05 Existing Existing Standard December 31, 2006 Renewal PPA Expired Oregon
Mountain Energy Renewal Hydro 0.05 Existing Existing Standard December 31, 2007 Renewal PPA Expired Oregon
Mountain Energy Renewal Hydro 0.05 Existing Existing Standard December 31, 2022 Renewal Operating Oregon
Mountain Wind 1 July 14, 2006 Wind 60.90 July 2, 2008 July 2, 2008 Non standard July 01, 2033 Original Operating Wyoming
Mountain Wind 2 July 23, 2006 Wind 79.80 September 29, 2008 September 29, 2008 Non standard September 29, 2033 Original Operating Wyoming
Nicholson Sunnybar Ranch June 27, 1985 Hydro 0.35 April 1, 1986 June 27, 1985 Unknown April 30, 2021 Original PPA Expired Idaho
Sunny Bar Ranch (formerly Nicholson Sunnybar Ranch)March 29, 2021 Hydro 0.45 Existing Existing Standard April 30, 2041 Renewal Operating Idaho
Norwest Energy 2 LLC (Neff)May 29, 2015 Solar 9.9 December 31, 2016 December 31, 2016 Standard November 17, 2031 Original Operating Oregon
Norwest Energy 4 LLC (Bonanza)May 29, 2015 Solar 6.0 February 27, 2019 July 31, 2018 Standard November 17, 2031 Original Operating Oregon
Norwest Energy 7 LLC (Eagle Point)May 29, 2015 Solar 9.9 12/30/2017 September 9, 2017 Standard November 17, 2031 Original Operating Oregon
Norwest Energy 9 LLC (Pendleton)June 29, 2015 Solar 6.6 11/30/2018 July 31, 2018 Standard November 17, 2031 Original Operating Oregon
O.J. Power Company March 4, 1986 Hydro 0.26 January 1, 1987 March 4, 1986 Unknown January 31, 2022 Original Operating Idaho
Obsidian Renewables LLC - Black Cap Solar II July 30, 2014 Solar 8.0 November 30, 2016 December 31, 2016 Standard November 30, 2036 Original Operating Oregon
Obsidian Renewables LLC - Ivory Pine Solar July 30, 2014 Solar 10.0 Terminated December 31, 2016 Standard Original Not built/terminated Oregon
Obsidian Renewables LLC - Sprague River Solar July 30, 2015 Solar 7.0 Terminated December 31, 2016 Standard Original Not built/terminated Oregon
OR Solar 1 (Sprague River Solar)June 11, 2015 Solar 10.0 Terminated November 1, 2016 Standard Original Not built/terminated Oregon
OR Solar 2 (Agate Bay Solar)June 11, 2015 Solar 10.0 October 22, 2020 October 31, 2017 Standard October 31, 2036 Original Operating Oregon
OR Solar 3 (Turkey Hill Solar)June 11, 2015 Solar 10.0 December 30, 2017 December 15, 2017 Standard October 31, 2036 Original Operating Oregon
OR Solar 5 (Merrill)June 17, 2015 Solar 8.0 January 12, 2018 December 15, 2017 Standard October 31, 2036 Original Operating Oregon
OR Solar 6 (Lakeview)June 17, 2015 Solar 10.0 December 18, 2017 December 15, 2017 Standard October 31, 2036 Original Operating Oregon
OR Solar 8 (Dairy)June 11, 2015 Solar 10.0 March 14, 2018 December 15, 2017 Standard October 31, 2036 Original Operating Oregon
Orchard Wind Farm 1, LLC June 30, 2016 Wind 10.0 December 28, 2020 October 1, 2020 Standard September 30, 2040 Original Operating Oregon
Orchard Wind Farm 2, LLC June 30, 2016 Wind 10.0 December 28, 2020 October 1, 2020 Standard September 30, 2040 Original Operating Oregon
Orchard Wind Farm 3, LLC June 30, 2016 Wind 10.0 December 28, 2020 October 1, 2020 Standard September 30, 2040 Original Operating Oregon
Orchard Wind Farm 4, LLC June 30, 2016 Wind 10.0 December 28, 2020 October 1, 2020 Standard September 30, 2040 Original Operating Oregon
Oregon Environmental Industries August 16, 2006 Biogas 3.20 January 17, 2007 September 7, 2007 Standard July 31, 2022 Original Operating Oregon
Oregon Institute of Technology April 9, 2010 Geothermal 0.28 April 9, 2010 April 15, 2010 Standard March 17, 2030 Original Operating Oregon
Oregon State University November 23, 2010 Natural Gas 6.50 November 12, 2010 January 15, 2011 Standard June 30, 2020 Original PPA Expired Oregon
Oregon State University Renewal Natural Gas 6.50 Existing Existing Standard March 31, 2022 Original Operating Oregon
Oregon Trail Windfarm LLC December 19, 2008 Wind 9.90 August 1, 2009 March 31, 2009 Standard January 15, 2029 Original Operating Oregon
OSLH - Collier Solar June 29, 2015 Solar 9.9 February 1, 2017 November 18, 2016 Standard November 17, 2031 Original Operating Oregon
Pacific Canyon Windfarm LLC December 19, 2008 Wind 8.25 August 1, 2009 March 31, 2009 Standard January 22, 2029 Original Operating Oregon
Pavant Solar April 11, 2014 Solar 50.0 December 30, 2015 December 31, 2015 Non standard December 30, 2035 Original Operating Utah
Pavant Solar II LLC March 25, 2015 Solar 50.0 November 22, 2016 December 1, 2016 Non standard November 30, 2036 Original Operating Utah
Pioneer Wind Park I LLC April 11, 2014 Wind 80.00 October 27, 2016 June 30, 2016 Non standard October 26, 2036 Original Operating Wyoming
Power County Wind Park North August 18, 2010 Wind 22.50 December 23, 2011 December 23, 2011 Standard December 22, 2031 Original Operating Idaho
Power County Wind Park South August 18, 2010 Wind 22.50 December 23, 2011 December 23, 2011 Standard December 22, 2031 Original Operating Idaho
Preston City Hydro February 24, 1982 Hydro 0.40 December 1, 1982 February 24, 1982 Unknown December 31, 2017 Original PPA Expired Idaho
Preston City Hydro Renewal Hydro 0.40 Existing Existing Standard December 31, 2032 Original Operating Idaho
Quichapa 1 October 29, 2013 Solar 3.0 December 13, 2016 May 30, 2016 Standard May 29, 2036 Original Operating Utah
Quichapa 2 October 29, 2013 Solar 3.0 December 23, 2016 June 30, 2016 Standard June 29, 2036 Original Operating Utah
Quichapa 3 October 29, 2013 Solar 3.0 December 23, 2016 July 29, 2016 Standard July 28, 2036 Original Operating Utah
RES Ag- Oak Lea November 29, 2009 Biogas 0.17 December 5, 2011 December 5, 2011 Standard November 30, 2026 Original Operating Oregon
Roseburg Forest Products - Weed November 15, 2010 Biomass 10.00 November 18, 2010 November 18, 2010 Standard June 30, 2011 Original PPA Expired California
Roseburg Forest Products - Weed Renewal Biomass 10.00 Existing Existing Standard June 30, 2012 Renewal PPA Expired California
Roseburg Forest Products - Weed Renewal Biomass 10.00 Existing Existing Standard June 30, 2018 Renewal PPA Expired California
Roseburg Forest Products - Weed Renewal Biomass 10.00 Existing Existing Standard June 30, 2028 Renewal Operating California
Roseburg LFG February 18, 2011 Biogas 1.60 December 20, 2011 June 20, 2011 Standard April 30, 2032 Original Operating Oregon
Sage Solar I July 3, 2017 Solar 20.00 September 30, 2019 October 1, 2019 Non standard September 30, 1939 Original Operating Utah/Wyoming
Sage Solar II July 3, 2017 Solar 20.00 September 13, 2019 October 1, 2019 Non standard September 30, 1939 Original Operating Utah/Wyoming
Sage Solar III July 3, 2017 Solar 20.00 September 13, 2019 October 1, 2019 Non standard September 30, 1939 Original Operating Utah/Wyoming
Sand Ranch Windfarm LLC January 19, 2008 Wind 9.90 August 1, 2009 March 31, 2009 Standard January 15, 2029 Original Operating Oregon
Shiloh Ingram Warm Springs Ranch March 5, 1986 Hydro 0.95 March 14, 1986 March 14, 1986 Unknown March 31, 2021 Original PPA Expired Idaho
Slate Creek January 1, 1982 Hydro 4.20 January 1, 1985 January 21, 1982 Unknown December 31, 2018 Original PPA Expired California
Slate Creek January 1, 1982 Hydro 4.20 January 1, 1985 January 21, 1982 Non standard December 31, 2033 Renewal Operating California
South Milford May 29, 2013 Solar 3.0 April 1, 2015 May 30, 2015 Standard January 14, 2035 Original Operating Utah
Spanish Fork Wind Park 2 June 30, 2006 Wind 18.90 July 31, 2008 July 31, 2008 Non standard July 30, 2028 Original Operating Utah
Sprague Hydro (North Fork Sprague)September 26, 1980 Hydro 0.75 September 1, 1989 September 28, 1983 Unknown December 31, 2021 Original Alternate buyer 1/1/2022 Oregon
St. Anthony December 20, 2012 Hydro 0.50 October 11, 2014 November 30, 2013 Standard November 29, 2033 Original Operating Idaho
Plant Name PPA Execution Date Resource Type Nameplate
Capacity (MW)
Commercial Operation
Date (COD)Original COD
Type of PPA
(Standard / Non-
standard)
Current PPA Expiration
Date
Vintage of
PPA Facility / PPA Status State
Stahlbush Island Farms March 19, 2009 Biogas 1.60 June 24, 2009 April 17, 2009 Standard 5/31/2011 Original PPA Expired Oregon
Stahlbush Island Farms Renewal Biogas 1.60 Existing Existing Standard May 31, 2014 Renewal PPA Expired Oregon
Stahlbush Island Farms Renewal Biogas 1.60 Existing Existing Standard September 30, 2014 Renewal PPA Expired Oregon
Stahlbush Island Farms Renewal Biogas 1.60 Existing Existing Standard May 31, 2017 Renewal PPA Expired Oregon
Stahlbush Island Farms Renewal Biogas 1.60 Existing Existing Standard May 31, 2019 Renewal PPA Expired Oregon
Stahlbush Island Farms Renewal Biogas 1.60 Existing Existing Standard May 31, 2021 Renewal PPA Expired Oregon
Stahlbush Island Farms Renewal Biogas 1.60 Existing Existing Standard May 31, 2022 Renewal Operating Oregon
Swalley Irrigation District September 4, 2009 Hydro 0.75 April 23, 2010 November 10, 2009 Standard January 03, 2030 Original Operating Oregon
Sweetwater Solar, LLC February 23, 2016 Solar 80.00 December 28, 2018 November 1, 2018 Non standard December 27, 2038 Original Operating Wyoming
Tata Chemical (FKA General Chemical)September 15, 1989 CHP 16.00 September 15, 1989 September 15, 1989 Unknown December 31, 2013 Original PPA Expired Wyoming
Tata Chemical (FKA General Chemical)Renewal CHP 32.00 Existing Existing Non standard December 31, 2018 Renewal PPA Expired Wyoming
Tata Chemical (FKA General Chemical)Renewal CHP 32.00 Existing Existing Non standard December 31, 2038 Renewal Operating Wyoming
Thayn Ranch Hydro April 1, 1992 Hydro 0.48 April 1, 1992 April 1, 1992 Unknown December 31, 2035 Original Operating Utah
Three Peaks Power August 15, 2015 Solar 80.0 December 9, 2016 October 31, 2016 Non standard December 14, 2036 Original Operating Utah
Three Sisters Irrigation District (Watson Hydro) (200 kW)May 8, 2018 Hydro 0.20 November 5, 2018 September 1, 2018 Standard August 31, 2038 Original Operating Oregon
Three Sisters Irrigation District (Watson Hydro) (700 kW)February 18, 2014 Hydro 0.70 August 22, 2014 May 1, 2014 Standard August 31, 2038 Original Operating Oregon
TMF Biofuels February 16, 2012 Biogas 4.80 December 31, 2012 February 21, 2012 Standard April 30, 2023 Original Operating Oregon
Tooele Army Depot (Wind 1)May 10, 2016 Wind 1.70 11/7/2016 November 7, 2016 Standard May 9, 2026 Original Operating Utah
Tooele Army Depot (Wind 2)May 10, 2016 Wind 1.90 11/7/2016 November 7, 2016 Standard May 9, 2026 Original Operating Utah
Tumbleweed Solar, LLC (Saturn Power Corporation)October 12, 2015 Solar 9.90 12/28/2017 November 6, 2017 Standard December 15, 2036 Original Operating Oregon
Utah Red Hills Renewable Park September 27, 2013 Solar 80.0 December 16, 2015 January 1, 2017 Non standard December 30, 2036 Original Operating Utah
Wagon Trail LLC December 19, 2008 Wind 3.30 September 1, 2009 March 31, 2009 Standard August 31, 2029 Original Operating Oregon
Ward Butte Windfarm LLC December 19, 2008 Wind 6.60 September 1, 2009 March 31, 2009 Standard August 31, 2029 Original Operating Oregon
Weber County, State of Utah December 16, 2004 Biogas 0.95 July 26, 2008 December 16, 2004 Standard December 26, 2023 Original Operating Utah
Woodline Solar LLC June 5, 2015 Solar 8.0 December 31, 2017 November 30, 2017 Standard November 29, 2037 Original PPA Expired Oregon
Yakima Tieton (Cowiche)June 12, 1985 Hydro 1.47 June 12, 1985 June 12, 1985 Unknown December 31, 2005 Original PPA Expired Washington
Yakima Tieton (Cowiche)Renewal Hydro 1.47 Existing Existing Standard December 31, 2008 Renewal PPA Expired Washington
Yakima Tieton (Cowiche)Renewal Hydro 1.47 Existing Existing Standard December 31, 2011 Renewal PPA Expired Washington
Yakima Tieton (Cowiche)Renewal Hydro 1.47 Existing Existing Standard December 31, 2015 Renewal PPA Expired Washington
Yakima Tieton (Cowiche)Renewal Hydro 1.47 Existing Existing Standard December 31, 2020 Renewal PPA Expired Washington
Yakima Tieton (Cowiche)Renewal Hydro 1.47 Existing Existing Standard December 31, 2030 Renewal Operating Washington
Yakima Tieton (Orchards)June 12, 1985 Hydro 1.47 June 13, 1985 June 12, 1985 Unknown December 31, 2005 Original PPA Expired Washington
Yakima Tieton (Orchards)Renewal Hydro 1.47 Existing Existing Standard December 31, 2008 Renewal PPA Expired Washington
Yakima Tieton (Orchards)Renewal Hydro 1.47 Existing Existing Standard December 31, 2011 Renewal PPA Expired Washington
Yakima Tieton (Orchards)Renewal Hydro 1.47 Existing Existing Standard December 31, 2020 Renewal PPA Expired Washington
Yakima Tieton (Orchards)Renewal Hydro 1.47 Existing Existing Standard December 31, 2030 Renewal Operating Washington
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I have this day served the Comments on behalf of the
Renewable Energy Coalition upon all parties of record in this proceeding, by electronic
transmission to the email address(es) of each party or party representative listed in the
Commission’s Notice of Parties for this docket.
Dated at Portland, Oregon, this 15th day of March 2022.
Sincerely,
/s/ Irion Sanger
Irion A. Sanger
PacifiCorp, dba Rocky Mountain Power: Ted Weston
PacifiCorp/ dba Rocky Mountain Power
1407 West North Temple Suite 330 Salt Lake City, UT 84116 E-Mail: [e-mail]
[e-mail]
Emily Wegener PacifiCorp/ dba Rocky Mountain Power 1407 West North Temple
Suite 320
Salt Lake City, UT 84116 E-Mail: [e-mail] Electronic Copies Only:
Data Request Response Center
PacifiCorp E-Mail: [e-mail] Commission Staff:
Riley Newton
Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714) PO Box 83720 Boise, ID 83720-0074
E-mail: [e-mail]
Idaho Conservation League: Benjamin J. Otto Idaho Conservation League
710 N. 6th Street
Boise, ID 83702 E-mail: [e-mail] Sierra Club:
Rose Monahan
Sierra Club 2101 Webster St., Suite 1300 Oakland, CA 94612 E-mail: [e-mail]

Ana Boyd Sierra Club 2101 Webster St., Suite 1300 Oakland, CA 94612
E-mail: [e-mail]