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HomeMy WebLinkAbout20230524Comments.pdfMICHAEL DUVAL DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE,IDAHO 83720-0074 (208)334-0320 IDAHO BAR NO.11714 Street Address for Express Mail: 11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A BOISE,ID 83714 Attorneyfor the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF ROCKY MOUNTAIN )POWER'S APPLICATION REQUESTING )CASE NO.PAC-E-23-14 APPROVAL OF THE ANNUAL REVISION )TO QF VARIABLE ENERGY PRICES )COMMENTS OF THEPURSUANTTOTERMSOFTHE1992)COMMISSION STAFF AMENDMENTS TO POWER PURCHASE )AGREEMENTS BETWEEN PACIFICORP )ANDIDAHOQFs ) STAFF OF the Idaho Public Utilities Commission,by and through its Attorneyof record, Michael Duval,Deputy AttorneyGeneral,submits the followingcomments. BACKGROUND On April 18,2023,Rocky Mountain Power,a division of PacifiCorp ("Company"), applied for Commission approval to update the Qualifying Facility ("QF")variable energy price pursuant to the terms of the 1992 amendments ("Amendment")to certain Idaho QFs power purchase agreements ("Application").Specifically,the Company requested Commission approval for a variable energy rate of $24.85 per megawatt hour ("MWh"). The Company indicates thirteen QF contracts were affected by the Amendment outlining the method used to determine the variable energy component of the avoided cost rate.The STAFF COMMENTS 1 MAY 24,2023 Company represents that only one QF contract affected by the Amendment remains in effect- Marsh Valley Hydro contract-which is effective through February 28,2028.1 The Company represents that the variable energy rate is calculated as the sum of the Company's fuel costs and Colstrip variable Operation and Maintenance ("O&M")cost.2 The Company represents the variable O&M costs were set based on the variable costs associated with the operation of the coal power generating facility Colstrip,excluding the generationtax and the line loss adjustments. Based on that calculation,the Company proposes the variable energy rate applicable to deliveries commencing July 1,2023,through June 30,2024,should be $24.85 per MWh. STAFF ANALYSIS Staff reviewed the Application and confirmed that the proposed rate is correct.The calculation used the data reported in the Company's FERC Form 1,and the resulting variable energy rate is $24.85 per MWh. STAFF RECOMMENDATIONS Staff recommends that the Commission approve the variable energy rate of $24.85 per MWh applicable to the energy delivered under the Marsh Valley Hydro contract,commencing July 1,2023,extending through June 30,2024. Respectfully submitted this 1 day of May 2023. Michael Duval Deputy AttorneyGeneral Technical Staff:Yao Yin Shubhra Deb Paul i:umisc/comments/pace23.14mdyysd comments *The remaining 12 QF contracts originally subject to the Amendment have expired,among which ten have enteredintonewPPAsandtwodidnotseeknewcontracts. 2 The Amendment defines fuel costs "as the average cost of fuel consumed in the Utah Division plants,specificallyCarbon,Hale,Naughton,Huntington,and Hunter coal plants."Application at 2.The Amendment specifies that anyplantthatdoesnotoperateinacalendaryearwillberemovedfromtheaveragefuelcostcalculation.Since CarbonandHaleplantsarenowclosed,the Company removed these from its calculation. STAFF COMMENTS 2 MAY 24,2023 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 24th DAY OF MAY 2023, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF,INCASENO.PAC-E-23-14,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING: MARK ALDER JOE DALLAS ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER 1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST SALT LAKE CITY UT 84116 STE 2000 E-MAIL:mark.alder@pacificorp.com PORTLAND OR 97232 E-MAIL:joseph.dallas@pacificorp.com DATA REQUEST RESPONSE CENTER E-MAIL ONLY: datarequest@pacificorp.com SECRET RY CERTIFICATE OF SERVICE