20230418Application.pdf

April 18, 2023
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-23-14
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 THE 1992 AMENDMENTS TO
POWER PURCHASE AGREEMENTS BETWEEN PACIFICORP AND IDAHO
QFs

Dear Ms. Noriyuki:
Enclosed for electronic filing in the above referenced matter is Rocky Mountain Power’s application requesting approval of the annual revision to the qualified facility variable energy prices.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at [phone]. Very truly yours,
Joelle Steward Senior Vice President of Regulation and Customer Solutions
RECEIVED
2023 April 18, 4:54PM
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
REQUESTING UPDATED VARIABLE ENERGY FOR QFs SUBJECT TO TERMS OF THE CERTAIN POWER
APPLICATION

Rocky Mountain Power, a division of PacifiCorp (“Company”), in accordance with the
Rules of Procedure of the Idaho Public Utilities Commission (“Commission”), Rule 52 and Order
No. 29316,1 hereby respectfully petitions the Commission for approval of the updated Qualifying
Facility (“QF”) variable energy price pursuant to the terms of the 1992 amendments to certain
Idaho QFs power purchase agreements (the “Application”). In support of this Application, Rocky
Mountain Power represents as follows:
I. INTRODUCTION AND BACKGROUND
1. Rocky Mountain Power is a division of PacifiCorp, an Oregon corporation, which
provides electric service to retail customers through its Rocky Mountain Power division 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 in Idaho pursuant to Idaho Code § 61-129. Rocky Mountain Power is

1 In the Matter of the Revision of QF Variable Energy Prices in Accordance with Terms of the 1992 Amendments to
Power Purchase Agreements between Idaho QFs and PacifiCorp, PAC-E-03-10, 2004 WL 316976 (Idaho P.U.C. August 19, 2003).
2
authorized to do business in the state of Idaho providing retail electric service to approximately
88,000 customers in the state.
2. In 2003, the Company notified the Commission of a July 1, 2003, revision to the
variable energy price for QFs holding certain power sales contracts with the Company.2 Thirteen
QF contracts were affected by the Commission-approved 1992 Amendment (“Amendment”) that
outlined the methodology used for determining the variable energy component of the avoided cost
rate.3
3. Of the 13 QF contracts originally subject to the Amendment supporting the annual
variable energy rate update, only one QF contract remains in effect. The Marsh Valley Hydro
contract is in effect through February 28, 2028. The other 12 QF contracts that were originally
subject to the 1992 amendment have expired, ten of which have entered into new PPAs, two did
not seek new contracts.
4. As stated in the 1992 Amendment beginning July 1, 2003, and continuing
throughout the term of the power purchase agreements, including any extensions, the variable
energy rate would be the sum of the Company’s fuel costs and Colstrip variable O&M cost.4
PacifiCorp’s fuel costs were defined as the average cost of fuel consumed in the Utah Division
plants, specifically Carbon, Hale, Naughton, Huntington, and Hunter coal plants.5
5. If any of the specified generating plants do not operate in any calendar year, those
plants are 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 was
calculated using the data reported in the Company’s FERC Form 1. In the event that the FERC

2 Id. Order No. 29316 at 1. 3 Id.at 1-3.
4 Id. at 1-2. 5 Id. at 2 (quoting Order No. 28708).
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Form 1 ceases to include the cost of fuel or net generation data, comparable data based upon the
Company’s normal accounting practices shall be used.
6. Pursuant to Order No. 23738,6 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.
II. VARIABLE ENERGY RATE
7. The average cost of fuel consumed at the Utah Division coal plants for calendar
year 2022 is $23.34 per megawatt hour, as summarized in Attachment No. 1 filed with this
Application. The variable operation and maintenance expense set for Colstrip generating facility
is $1.51 per megawatt hour. Therefore, the Company proposes that the variable energy rate
applicable to deliveries commencing July 1, 2023, extending through June 30, 2024, is $24.85 per
megawatt hour. Attachment No. 1 summarizes the calculation with references to the relevant pages
from the Company’s FERC Form 1 for the year ending December 31, 2022.
III. COMMUNICATIONS AND SERVICE OF PLEADINGS
Communications regarding this Application should be addressed to:
Mark Alder Rocky Mountain Power
Idaho Regulatory Affairs Manager
1407 W. North Temple, Suite 330 Salt Lake City UT 84116 Telephone: [phone] E-mail: [e-mail]

Joe Dallas (ISB# 10330) PacifiCorp, Senior Attorney 825 NE Multnomah Street, Suite 2000 Portland, OR 97232
Email: [e-mail]

6 In re Idaho Power Company, Case No. PPL-E-89-3/UPL-E-89-5, 1991 WL 501613 (Idaho P.U.C. June 17, 1991).
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In addition, Rocky Mountain Power respectfully requests that all data requests regarding this
matter be addressed to:
By e-mail (preferred): [e-mail] By regular mail:
PacifiCorp
Data Request Response Center 825 NE Multnomah, Suite 2000 Portland, OR 97232
Informal inquires also may be directed to Mark Alder at [phone].
IV. 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.
V. REQUEST FOR RELIEF
Rocky Mountain Power respectfully requests Commission Orders authorizing this matter
to be processed by Modified Procedure and approving the variable energy rate of $24.85 per
megawatt hour commencing July 1, 2023, through June 30, 2024, for certain Idaho QFs power
purchase agreements subject to Commission Order No. 29316.
Dated this 18th day of April 2023.
Respectfully submitted, ROCKY MOUNTAIN POWER

_______________________ Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000 Portland, OR 97232 Email: [e-mail] Attorney for Rocky Mountain Power

Attachment 1
PacifiCorp
Total Variable Energy Rate
for 2023 / 2024
Naughton Huntington Hunter Totals
Fuel Cost ($) 90,267,799$ 125,825,036$ 110,615,302$ 326,708,136$
2022 FERC FORM 1 - Page 402 Line 20
Generation (MWH) 2,456,201 5,673,115 5,865,764 13,995,080
2022 FERC FORM 1 - Page 402 Line 12
Average Fuel Cost ($/MWH) 23.34$ /MWH
Variable O&M 1.51$ /MWH
Total Variable Energy Rate for 2023 / 2024 24.85$ /MWH
For deliveries commencing July 1, 2023 extending through June 30, 2024
13 PacifiCorp/QFs contracts with approved 1992 amendment language