20220119Application.pdf

1407 W. North Temple, Suite 330
Salt Lake City, Utah 84116
January 19, 2022
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-22-01
IN THE MATTER OF THE APPLICATION FOR APPROVAL OR REJECTION
OF THE AMENDED POWER PURCHASE AGREEMENT BETWEEN
PACIFICORP AND OJA LLC.
Dear Ms. Noriyuki:
Please find for filing Rocky Mountain Power’s Application 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
Enclosures
RECEIVED
2022 JAN 19 PM 2:20
IDAHO PUBLIC
UTILITIES COMMISSION
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Emily L. Wegener, (ISB# 11614) Rocky Mountain Power
1407 West North Temple, Rm 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 POWER PURCHASE AGREEMENT BETWEEN PACIFICORP AND OJA, LLC
) CASE NO. PAC-E-22-01 ) ) APP LICATION OF ) ROCKY MOUNTAIN POWER
Pursuant to the Rules of Procedure of the Idaho Public Utilities Commission, Rule 52, and
the applicable provisions of the Public Utility Regulatory Policies Act of 1978 (“PURPA”), Rocky
Mountain Power, a division of PacifiCorp, (“Company”) respectfully requests that the Idaho Public
Utilities Commission (“Commission”) issue an order approving or rejecting the one-year Power
Purchase Agreement (“PPA”) between PacifiCorp and Larry Oja and Christie Oja qualified facility,
(“Seller”) dated December 15, 2021. The Company requests that this application be processed
under modified procedures pursuant to RP 201-204.
I.INTRODUCTION
1.Rocky Mountain Power provides electric service to retail customers in the states of
Idaho, Wyoming, and Utah. Rocky Mountain Power is a public utility in the state of Idaho and is
subject to the Commission’s jurisdiction with respect to its prices and terms of electric service to
retail customers pursuant to Idaho Code § 61-129. Rocky Mountain Power provides retail electric
service to approximately 86,500 customers in the state of Idaho.
2.Seller owns, operates, and maintains a small hydro-electric power plant (the
“Facility”) located in Oneida County, Idaho with a nameplate capacity rating of 260 kilowatts
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(“kW”). Seller operates the Facility as a Qualifying Facility (“QF”) under the applicable provisions
of PURPA.
3.Sections 201 and 210 of PURPA, and pertinent regulations of the Federal Energy
Regulatory Commission (“FERC”) require that regulated electric utilities purchase electricity
produced by co-generators or small power producers that obtain QF status. The rate a QF receives
for the sale of its electricity is generally referred to as the avoided cost and must reflect the
incremental cost to an electric utility of electric energy or capacity or both, which, but for the
purchase from the QF, such utility would generate itself or purchase from another source.
4.The Commission has authority under PURPA, Sections 201 and 210 and FERC
regulations, 18 C.F.R. 292, to set avoided costs, order electric utilities to enter into fixed-term
obligations for the purchase of electricity from QFs and implement FERC rules.
5.On December 18, 2012, the Commission issued Order No. 32697,1 which
established parameters for published and negotiated avoided cost rate calculations. The
Commission further established and defined numerous contract terms and conditions for standard
PPAs entered into between regulated utilities and QFs.
6.On January 2, 2013, the Commission issued an Errata to Order No. 32697, which
corrected published avoided cost rates to include energy payments not discounted by transmission
and line loss. Subsequently the Commission issued reconsideration Orders Nos. 32737 and 32802
on February 5, 2013 and May 5, 2013, respectively, which further clarified certain terms and
conditions of PPAs.
1 In the Matter of the Commission’s Review of PURPA QF Contract Provisions Including the Surrogate Avoided
Resource (SAR) and Integrated Resource Planning (IRP) Methodologies for Calculating Avoided Cost Rates, Case No. GNR-E-11-03.

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7. The energy service agreement (“ESA”) is based on the published rates for projects
of 10 average megawatts (“aMW”) or less pursuant to Commission Order No. 34350. The Facility
is an existing QF that is seeking a one-year contract which will allow the Seller time to complete
the distribution system upgrades called for in the stand-alone interconnection agreement. The ESA
contains capacity payments for the entire term of the Amendment; therefore, no sufficiency period
determination is necessary, see Order No. 32697 at 21-22, Order No. 32737 at 5, and Order
No. 32871. Pursuant to the Commission's direction in its Reconsideration Order No. 32737, the
rates were calculated by Commission Staff for a QF in the “non-seasonal hydro” category based
on the surrogate avoided resource (“SAR”) avoided cost methodology.
II. AMENDED POWER PURCHASE AGREEMENT
8. The Seller’s current PURPA contract is dated January 24, 1992. The PURPA
contract was entered into prior to PacifiCorp separating its energy supply and transmission
functions as required by federal law and regulations.
9. Therefore, the contract includes provisions that address both energy sales and
interconnection requirements. PacifiCorp begin contacting the Seller regarding contract renewal
October 20, 2020. Seller filed the application for transmission interconnection August 31, 2021
with data to begin a transmission interconnection fast track study finally deemed complete
December 30, 2021. The current contract is scheduled to expire on January 31, 2022, and the
Seller expressed a desire to continue to make sales from the Facility to PacifiCorp consistent with
the requirements of PURPA as implemented in the State of Idaho.
10. The Seller has demonstrated to PacifiCorp that the Facility remains a QF as defined
by PURPA and as implemented in the State of Idaho. The Seller and PacifiCorp are in the process
of securing a new stand-alone interconnection agreement that, after all distribution system

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upgrades are constructed and in-service, will replace the interconnection provisions in the current
PURPA contract.
11. During the period that the necessary transmission fast track study and distribution
system upgrades are being completed, PacifiCorp and the Seller have agreed to a limited one-year
PURPA contract, with pricing, as summarized in Exhibit A to the PPA, for energy sales during this
term. The term is effective from February 1, 2022, through the earlier of the effective date of a
new PPA or January 31, 2023. The total nameplate capacity of the facility remains unchanged at
260 kW.
12. The Seller has demonstrated to the Company’s reasonable satisfaction that: (1) the
Facility’s net energy will equal the energy delivery schedules for the extended term of this
Amendment; and (2) the likelihood that the Facility, under average design conditions, will generate
at no more than 0.2 aMW in any calendar month. The Facility’s estimated net output over the
extended term is 678 megawatt-hours.
13. The PPA submitted herewith, as Attachment 1, complies with the Commission's
previous orders, and except as otherwise indicated, the Company will pay the Seller the price set
forth in Exhibit A to the PPA.
14. Paragraph 5 of the PPA provides that the contract will not become effective until
the Commission has approved it and determined that the prices paid for energy and capacity are
just and reasonable, in the public interest, and that costs incurred by the Company for purchasing
energy and capacity are legitimate expenses, all of which the Commission will allow the Company
to recover in Idaho rates in the event other jurisdictions deny recovery of their proportionate share
of said expenses.

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III.COMMUNICATIONS
15. Communications regarding this filing should be addressed to:
Ted Weston Idaho Regulatory Affairs Manager Rocky Mountain Power
1407 West North Temple, Suite 330 Salt Lake City, Utah 84116 Telephone: [phone] Email: [e-mail] [e-mail]
Emily Wegener Senior Counsel Rocky Mountain Power 1407 West North Temple, Suite 320
Salt Lake City, Utah 84116 Telephone: [phone] Email: [e-mail]
In addition, Rocky Mountain Power requests that all data requests regarding this
Application be sent in Microsoft Word to the following:
By email (preferred): [e-mail]
By regular mail: Data Request Response Center PacifiCorp
825 Multnomah, Suite 2000
Portland, Oregon 97232
Informal questions may be directed to Ted Weston, Idaho Regulatory Affairs Manager at
[phone].
IV.MODIFIED PROCEDURE
16. The Company 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, pursuant to RP 201.
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V.REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power respectfully requests that the
Commission: (1) Issue an order authorizing that this matter be processed by Modified
Procedure; (2) Approve or reject the one-year purchase power agreement between Larry Oja and
Christie Oja and the Company without change or condition; and (3) Declare that the avoided cost
prices set forth in the contract are just and reasonable, in the public interest, and that the
Company’s incurrence of such costs are legitimate expenses for recovery in rates in the state of
Idaho.
DATED this 19th day of January 2022.
Respectfully submitted, ROCKY MOUNTAIN POWER
_____________________________
Emily L. Wegener
Attorney for Rocky Mountain Power
Attachment 1
SECOND AMENDMENT
to
POWER PURCHASE AGREEMENT
between
Larry Oja and Christie Oja
and
PacifiCorp
This SECOND AMENDMENT (the “Amendment”), dated December 15, 2021, amends
that certain POWER PURCHASE AGREEMENT between PacifiCorp, an Oregon corporation
(“PacifiCorp”), and Larry Oja and Christie Oja, individually and as successors to Myron Jones
and Nola Jones (“Seller”), dated March 4, 1986 (as amended January 24, 1992, and as may be
supplemented and modified from time to time, the “PPA”). Capitalized terms used but not defined
in this Amendment shall have the meaning set forth in the PPA.
RECITALS
A. PacifiCorp and Seller entered into the PPA prior to PacifiCorp’s separation of its energy
supply and transmission functions as required by federal law and regulations. For this
reason, the PPA includes provisions that address both energy sales and interconnection
requirements.

B. The PPA is scheduled to expire by its terms on January 31, 2022, and Seller has
expressed a desire to continue to make sales from the Facility to PacifiCorp consistent
with the requirements of the federal Public Utility Regulatory Policies Act (“PURPA”),
as implemented in the State of Idaho.

C. Seller has demonstrated to PacifiCorp that the Facility remains a “Qualifying Facility” as
defined by PURPA and as implemented in the State of Idaho.

D. Seller and PacifiCorp are in the process of securing a new stand-alone interconnection
agreement that, once executed and all distribution system upgrades are constructed and
in-service, will replace the interconnection provisions in the PPA.

E. During the period that the necessary distribution system upgrades are being completed,
PacifiCorp and Seller have agreed to a limited extension to the term of the PPA, with
updated pricing for energy sales during the extended term of the PPA as described below.

AGREEMENT
PacifiCorp and Seller agree as follows.
1. The first sentence of Section 1.1 of the PPA is amended and restated to read as follows:
“Subject to the terms and conditions hereof, this Agreement shall be binding upon
execution and shall remain in effect until the earlier of (i) the effective date of a
new power purchase agreement between PacifiCorp and Seller pertaining to the
Facility; or (ii) January 31, 2023.”
2. Notwithstanding any provision in the PPA to the contrary, for the period beginning
February 1, 2022 through the end of the term of the PPA, PacifiCorp shall pay Seller
as provided in Exhibit A to this Amendment for the energy output of the Facility
delivered to the Point of Delivery as adjusted for Losses.
3. Notwithstanding any provision in the PPA to the contrary, PacifiCorp shall not be
responsible to purchase the output of the Facility during periods that the Facility is
curtailed due to construction and completion of the distribution system upgrades called
for in the final, new stand-alone interconnection agreement between Seller and
PacifiCorp’s transmission function.
4. Seller’s contact information in Article 5 of the PPA is amended and replaced with the
following information:
Larry and Christie Oja
267 Mill Canyon Road
Malad City, Idaho 83252
Email: [e-mail]
Phone: [phone]
5. This Amendment shall be effective once signed and delivered by both PacifiCorp and
Seller and approved by the Idaho Public Utilities Commission.
6. All other terms and provisions of the PPA shall remain unchanged. Each party hereby
ratifies and confirms that except as expressly amended hereby, all of the terms,
conditions, covenants, representations, warranties and all other provisions of the PPA
remain in full force and effect.
7. This Amendment shall be governed by and construed in accordance with the laws of
the State of Idaho (without reference to its choice of law doctrine).
8. This Amendment may be executed in multiple counterparts, each of which when so
executed and delivered shall be deemed to be an original and all of which taken together
shall constitute but one and the same instrument. Delivery of an executed counterpart
of this Amendment by electronic transmission (in .pdf form) shall be equally as
effective as delivery of a manually executed counterpart.

[signature page follows]

I
EXHIBIT A
Energy Rate
Energy Purchase Price = Energy Annual Rate * Monthly Peak Multiplier
Table 1: Energy Annual Rates
Year
Energy Annual Rate
$/MWh
2022 56.37
2023 55.84
Table 2: Monthly On-Peak/Off-Peak Multipliers
Month On-Peak
Hours
Off-Peak
Hours
January 103% 94%
February 105% 97%
March 95% 80%
April 95% 76%
May 92% 63%
June 94% 65%
July 121% 92%
August 121% 106%
September 109% 99%
October 115% 105%
November 110% 96%
December 129% 120%
Where:
“Off-Peak Hours” means all hours that are not On-Peak Hours.
“On-Peak Hours” means all hours ending 07:00:00 through 22:00:00 MPT,
Monday through Saturday, excluding NERC designated holidays.