20240305Decision Memo.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL

DATE: MARCH 5, 2024

SUBJECT: IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION
REQUESTING AUTHORIZATION TO UPDATE THE WIND AND SOLAR
INTEGRATION RATE FOR SMALL POWER GENERATION
QUALIFYING FACILITIES; CASE NO. PAC-E-23-24.

On November 29, 2023, Rocky Mountain Power, a division of PacifiCorp (“Company”)
applied to the Idaho Public Utilities Commission (“Commission”) for authority to adjust the wind
and solar integration rate applicable to new power purchase agreements (“PPAs”) between the
Company and wind and solar qualifying facilities (“QFs”) (“Application”).
On January 2, 2024, the Commission issued a Notice of Application and Notice of
Intervention Deadline. Order No. 36051. No party intervened.
THE APPLICATION
The Company requested authorization to decrease the wind integration rate from $1.25 to
$1.18 per megawatt-hour (“MWh”) for wind-powered QFs. The Company also requested
authorization to increase the solar integration rate from $0.96 to $1.40 per MWh for solar-powered
QFs.1
The Company stated the proposed changes are due to the integration costs of wind and
solar power compared to published avoided cost rates. However, the Company noted that an
exception to this default practice of determining the price occurs when the QF delivers energy to
the Company on a firm hourly schedule as specified in a PPA.

1 The Company specifically requested that the proposed wind and solar integration rate be priced “in 2024 dollars.”
Application at 1, 6.
DECISION MEMORANDUM 2
STAFF RECOMMENDATION
After discussing the proposed schedule with the Company, Staff recommends the
Commission issue a Notice of Modified Procedure establishing a 21-day public comment deadline,
and a 14-day Company reply deadline.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Modified Procedure establishing a 21-day
public comment deadline, and a 14-day Company reply deadline.?

__________________________
Michael Duval
Deputy Attorney General

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