20230111Reply Comments.pdf

1407 W. North Temple, Suite 330
Salt Lake City, Utah 84116

January 11, 2023

VIA ELECTRONIC DELIVERY

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
1131 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714

Re: CASE NO. PAC-E-22-18
IN THE MATTER OF THE APPLICATION FOR APPROVAL OR REJECTION
OF THE POWER PURCHASE AGREEMENT BETWEEN PACIFICORP AND
OJA, LLC.

Dear Ms. Noriyuki:

Please find for filing Rocky Mountain Power’s Reply Comments in the above-referenced matter.

Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at [phone].

Very truly yours,

Joelle R. Steward
Senior Vice-President of Regulation and Customer Solutions

Enclosures

RECEIVED
Wednesday, January 11, 2023 12:25:03 PM
IDAHO PUBLIC
UTILITIES COMMISSION
1

Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
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-22-18
ROCKY MOUNTAIN POWER’S REPLY COMMENTS

In accordance with the Idaho Public Utilities Commission (“Commission”) Notice of
Modified Procedure, PacifiCorp d/b/a Rocky Mountain Power (the “Company”), by and through
its counsel, provides these Reply Comments to the comments received by the Commission from
the Staff of the Commission (“Staff”) on January 4, 2022.
INTRODUCTION
The Company filed its application in this matter with the Commission on November 14,
2022 (“Application”), requesting the Commission approve or reject the power purchase agreement
between the Company and Larry Oja and Christie Oja (“Agreement”). On January 4. 2022, Staff
filed comments recommending the Commission approve the Agreement and declare all payments
for purchase of energy and capacity under the Agreement to be allowed as prudently incurred
expenses for ratemaking purposes, conditioned on the parties to the Agreement correcting the
original contract date referenced within the Agreement. The Company agrees with Staff
comments.

2

REPLY TO STAFF’S COMMENTS
Staff comments identified section 2.2(b) of the Agreement which mistakenly states that the
original 1986 contract was signed on January 3, 1985. However, the actual date of the 1986
contract was March 4, 1986. The Company agrees with Staff comments and is in the process of
preparing an amendment to the Agreement to replace the reference to “January 3, 1985” in Section
2.2(b) with “March 4, 1986.”
CONCLUSION
The Commission should issue an order conditionally approving the Agreement subject to
the date change as noted in Staff comments.
Respectfully submitted this 11th day of January,
2023.
_____________________________
Joe Dallas

Attorney for Rocky Mountain Power