20230524Comments.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
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:[e-mail] PORTLAND OR 97232
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
SECRET RY
CERTIFICATE OF SERVICE