20220601Comments.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 98IO
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER REQUESTING
APPROVAL OF THE ANNUAL REVISION TO
QF VARIABLE ENERGY PRICES PURSUANT
TO TERMS OF TH.E. 1992 AMENDMENTS TO
POWER PURCHASE AGREEMENTS
BETWEEN PACIFICORP AND IDAHO QFS.
CASE NO. PAC.E.22-07
COMMENTS OF THE
COMMISSION STAFF
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMTSSION
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COMES NOW the Staff of the Idaho Public Utilities Commission ("Staff'), by and
through its Attorney of record, Chris Burdin, Deputy Attomey General, and submits the following
comments.
BACKGROUND
On April 13,2022, Rocky Mountain Power, a division of PacifiCorp ("Company"), applied
for Commission approval to update the variable energy portion of avoided cost rates for Quali$ing
Facility ("QF") under the Public Utility Regulatory Policies Act of 1978 (.'PURPA") with the 1992
amendments to the Company's power purchase agreements.
The proposed update only affects one contract, the Marsh Valley Hydro contract, which is
effective through February 28,2028. The variable energy rate is calculated as the sum of the
Company's fuel costs and Colstrip variable Operation and Maintenance ("O&M") cost, with the
fuel costs being defined as the average cost of fuel consumed in the Utah Division plants,
specifically the Naughton, Huntington, and Hunter coal plants. The Colstrip variable O&M costs
ISTAFF COMMENTS JI.INE 1,2022
were set based on the variable costs associated with the operation of the Colstrip coal power
generating facility, excluding the generation tax and line loss adjustments.
Based on that calculation, the Company has proposed that the variable energy rate
applicable to deliveries cofirmencing July l, 2022, extending through June 30, 2023, should be
$22.44 per megawatt hour ("MWh").
STAFF ANALYSIS
Staff reviewed the variable energy rate of the avoided cost rate for PacifiCorp contracts
vr:rrhlgg2 amendments contained inthe Application and confirmed that the proposed rate is correct
and complies with Order No. 29316. The average cost of fuel was calculated using the data
reported in the Company's FERC Form l, resulting in a variable energy rate of $22.44 per MWh.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the variable energy rate of $22.44 per
MWh applicable to the energy delivered under the Marsh Valley Hydro contract, commencing
July l, 2022, extending through June 30, 2023.
Respectfully submitted this l{ day of June 2022.
V"*La,
Chris Burdin
Deputy Attomey General
Technical Staff: Yao Yin
i : umisc/commentV pace22.7 cby y comments
2STAFF COMMENTS JUNE 1,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS lST DAY OF JUNE 2022, SERVED
THE FOREGOING COMMENTS OF TrrE COMI\{ISSION STAFF, IN CASE NO.
PAC-E-22.07, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
idahodockets @pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datarequest@pacifi corp.com
EMILY WEGENET\
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: emily.wegener@pacifi corp.com
,Itn Z,,\v\SECRETAPY/--
/
CERTIFICATE OF SERVICE