20210525Exhibit 14.pdf

Exhibit 14

March 13, 2020
Email from Kyle Moore
From:Moore, Kyle {Mkt Function}
To:Greg Adams; Bryan Case
Cc:McDermott, Jacob; Woodworth, Thomas
Subject:RE: Fall River"s Proposed PPA for Chester Diversion Hydro Project
Date:Friday, March 13, 2020 3:54:05 PM
Bryan, Greg –

Thank you for this additional information, as it helped us to better understand your project
submittal. We now understand that although the Chester hydroelectric project is an existing
operating hydro project interconnected to Fall River, Fall River has elected not to pursue a
transmission arrangement to deliver the output to a point of delivery on PacifiCorp’s system in Idaho
(due to the various complications Mr. Adams explains below). Instead, Fall River has elected to
pursue a separate interconnection directly to PAC’s system in Idaho. We further understand based
on the correspondence you have provided that the interconnection study from PacifiCorp
Transmission has been delayed due to the volume of requests in PacifiCorp’s interconnection queue
in this same general geographic region. Unfortunately, as a consequence of these decisions and
events, Fall River is unable to provide information that reasonably demonstrates when the Chester
Hydro project will deliver power to PacifiCorp. As such, consistent with QF contracting procedures
set forth Parts I.B.5 and I.B.6 of RMP’s Idaho Schedule 38 (which PacifiCorp applies to both QFs
eligible and ineligible for standard published rates ), RMP remains unable to commence negotiation
of this PPA. Please let me know if developments change that would reasonably support a firm date
Fall River is able to commit to deliver power to PacifiCorp. Such evidence could include an
interconnection study (if interconnection continues to be pursued and a supporting interconnection
study is delivered) or evidence of a transmission service arrangement to a POD on PacifiCorp’s
system in Idaho.

Finally, with respect to the updated Form 556 QF certification for the Chester project, that form,
once filed, can be provided to myself and Tom Woodworth (copied).

Thanks,

Kyle Moore
Rocky Mountain Power
Commercial Services
O 801.220.4467
C 385.210.4209

From: Greg Adams [mailto:[e-mail]]
Sent: Monday, March 9, 2020 2:26 PM
To: Moore, Kyle {Mkt Function} <[e-mail]>; Bryan Case
<[e-mail]>
Cc: McDermott, Jacob <[e-mail]>; Woodworth, Thomas
<[e-mail]>
Subject: [INTERNET] RE: Fall River's Proposed PPA for Chester Diversion Hydro Project

** REMEMBER SAIL WHEN READING EMAIL **
Exhibit 14 Page 1
Sender The sender of this email is [e-mail] using a friendly name ofGreg Adams .
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displayed above?
Attachments Does this message contain attachments? Yes If yes, are you expecting them?Fall River Distribution One-Line.pdf, Chester Interconnection Request.pdf, RE_
Q1182_ – Fall River Rural Electric Cooperative, Inc. _ QF System Impact Study
Agreement.pdf, Fully Executed 191108 Q1182 QFSGI SISA.pdf, 191125 Q1182LTR Study Provision Delay Notification.pdf, QF10-337-001.pdf
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Tom, Jacob, and Kyle,
To follow up on my phone call with Tom on Friday, I am responding to the requests foradditional information related to Fall River Rural Electric Cooperative’s Chester Diversion
Project, as requested by Kyle. I have reproduced Kyle’s questions in italics below andprovided Fall River’s response beneath each question. We look forward to hearing back from
PacifiCorp and reaching agreement on terms of the proposed PPA for the Chester Project. Ifyou have any further questions, please contact me.
(1) While we understand from your original information provided in September 2019 that
the Chester Diversion Project is already operating, you also mention that you areseeking an interconnection to PacifiCorp’s system. Considering these two statements
together, we assume this means the project is already interconnected to another systemand delivering power. Can you please confirm and elaborate so we may understand
the situation better? Assuming we understand the situation correctly, have youconsidered purchasing transmission to deliver the output to PacifiCorp’s system?
That would seem to avoid the interconnection study delays you indicate you areexperiencing.
Fall River’s Response: As discussed with Tom on the phone on Friday, the Chester
project is currently interconnected to Fall River’s own distribution system, and theoutput of the facility is currently being used to serve Fall River’s own members’ loads.
However, there is a 12.5-kV PacifiCorp line located directly adjacent to the currentinterconnection point on the Fall River line, and therefore Fall River’s engineers have
concluded that interconnecting the facility to the PacifiCorp system would be feasibleand reasonably achievable. During the scoping meeting with PacifiCorp’s
transmission personnel, it appeared that this should be a relatively easy interconnectionwithout any insurmountable obstacles.
With respect to PacifiCorp’s inquiry as to why Fall River proposes to interconnect to
PacifiCorp’s system as opposed to wheeling the power to PacifiCorp’s system from theexisting interconnection point on Fall River’s system, Fall River has considered this
option and believes that the proposal to interconnect to PacifiCorp’s system is the moreefficient and reasonable option from a contractual and engineering standpoint. The
Exhibit 14 Page 2
alternative that Fall River has considered is that the parties could attempt to wheel thepower over Fall River’s system to the point of interconnection between the two utilities
in the Rexburg substation. However, there are engineering and contractual obstacles tothis alternative, including: (i) the entire wheeling arrangement would be located within
PacifiCorp’s balancing authority; therefore it is not a standard interchange transactionand it may be difficult for the parties to agree on the proper way to meter and track the
delivery to the Rexburg substation; and (ii) Fall River’s system does not currentlyoperate in such a way that there is an open connection to the Rexburg substation from
the Chester facility at all times of the year – In engineering terms, the Chester project’soutput feeds into Fall River’s Daw Substation, and the Daw Substation is connected to
the Rexburg substation (to which PacifiCorp’s system is connected); but while FallRiver does not operate its distribution systems in a looped configuration, meaning the
two feeders from two different substations are electrically connected 24/7/365, thisconnection is occasionally closed and an open point established in another location
during outages or for maintenance. This is depicted on the attached map/one-linediagram of the relevant facilities.
In light of these facts, Fall River has proposed the simpler solution of a direct
interconnection to PacifiCorp’s system.
(2) Can you please provide the documentation you’ve exchanged with PacifiCorp’sTransmission Function that relates to your interconnection application and request?
Fall River’s Response: We have attached the following documents:

· Fall River’s Interconnection Request, dated October 3, 2019, with check for
$1,000;
· Fall River and PacifiCorp Transmission held a scoping meeting on October 31,
2019, and it appeared that there should be no major obstacles to achieving
interconnection of the facility; thus, Fall River agreed to waive the FeasibilityStudy to expedite the process;
· Fall River’s email dated November 12, 2019, containing additional project
information, executed System Impact Study Agreement, and $10,000 studydeposit, which PacifiCorp has cashed;
· Fully executed System Impact Study Agreement, dated Nov. 22, 2019;
· Letter from PacifiCorp Transmission dated November 25, 2020, stating that
the study could not be completed on time.
(3) Finally, you mention you’ve previously provided PAC the QF self-certification for thisproject. We’re unable to locate in our records and are unable to access on the FERCeLibrary. Can you please provide us a copy?
Fall River’s Response: The facility has been certified in FERC Docket QF10-337.
We have attached the most recently filed recertification form. Please note that FallRiver intends to file a recertification form to include the plans to sell to PacifiCorp and
to update some other information, such as the facility’s ownership. If you have anyquestions about the facility’s ability to meet the qualification criteria, please let me
know.
Exhibit 14 Page 3

Greg AdamsRichardson Adams, PLLC
515 N. 27th StreetBoise, Idaho 83702
Voice: 208.938.2236Facsimile: 208.938.7904
Information contained in this electronic message and in any attachments hereto may contain information that is
confidential, protected by the attorney/client privilege and/or attorney work product doctrine. Inadvertent disclosure
of the contents of this email or its attachments to unintended recipients is not intended to and does not constitute a
waiver of the attorney/client privilege and/or attorney work product doctrine. If you have received this email in
error, please immediately notify the sender of the erroneous receipt and destroy this email and any attachments of
the same either electronic or printed. Thank you.

From: Moore, Kyle {Mkt Function} <[e-mail]>
Sent: Thursday, March 05, 2020 4:52 PM
To: Bryan Case <[e-mail]>
Cc: Greg Adams <[e-mail]>; McDermott, Jacob
<[e-mail]>; Woodworth, Thomas <[e-mail]>
Subject: RE: Fall River's Proposed PPA for Chester Diversion Hydro Project

Bryan,

We are in receipt of your latest February 19, 2020 correspondence. As discussed previously,
consistent with the Company’s Idaho Schedule 38 (Part I.B.5), we’re not able to commence
negotiations on the PPA until such time as we can review your available
transmission/interconnection materials to reasonably confirm that the project is able to deliver
power on the date you indicated, which informs your eligibility for the current avoided cost rate.
We’re happy to continue to evaluate the situation with this project, but we need more information.
Please see below:

(1) While we understand from your original information provided in September 2019 that the
Chester Diversion Project is already operating, you also mention that you are seeking an
interconnection to PacifiCorp’s system. Considering these two statements together, we
assume this means the project is already interconnected to another system and delivering
power. Can you please confirm and elaborate so we may understand the situation better?
Assuming we understand the situation correctly, have you considered purchasing
transmission to deliver the output to PacifiCorp’s system? That would seem to avoid the
interconnection study delays you indicate you are experiencing.

(2) Can you please provide the documentation you’ve exchanged with PacifiCorp’s Transmission
Function that relates to your interconnection application and request?

(3) Finally, you mention you’ve previously provided PAC the QF self-certification for this
project. We’re unable to locate in our records and are unable to access on the FERC
eLibrary. Can you please provide us a copy?
Exhibit 14 Page 4

Thanks,

Kyle Moore
Rocky Mountain Power
Commercial Services
O 801.220.4467
C 385.210.4209

From: Greg Adams [mailto:[e-mail]]
Sent: Wednesday, February 19, 2020 9:34 AM
To: McDermott, Jacob <[e-mail]>; Moore, Kyle {Mkt Function}
<[e-mail]>
Cc: Bryan Case <[e-mail]>
Subject: [INTERNET] Fall River's Proposed PPA for Chester Diversion Hydro Project

** REMEMBER SAIL WHEN READING EMAIL **
Sender The sender of this email is [e-mail] using a friendly name ofGreg Adams .
Are you expecting the message? Is this different from the message sender
displayed above?
Attachments Does this message contain attachments? Yes If yes, are you expecting them?Fall River Letter Re Chester PPA 2-19-2020.pdf, Form of Idaho Small Hydro PPA
_ 1.2.20 _Fall River -Chester Edits_2.18.2020.docx, Chester to PAC one line.pdf
Internet Tag Messages from the Internet should have [INTERNET] added to the subject.
Links Does this message contain links? YesCheck links before clicking them or removing BLOCKED in the browser.
Cybersecurity risk assessment: Medium

Jacob and Kyle, Please see that attached cover letter and draft PPA that we are sending in
US Mail today. Please contact me with any questions.

Greg AdamsRichardson Adams, PLLC
515 N. 27th StreetBoise, Idaho 83702
Voice: 208.938.2236Facsimile: 208.938.7904
Information contained in this electronic message and in any attachments hereto may contain information that is
confidential, protected by the attorney/client privilege and/or attorney work product doctrine. Inadvertent disclosure
of the contents of this email or its attachments to unintended recipients is not intended to and does not constitute a
waiver of the attorney/client privilege and/or attorney work product doctrine. If you have received this email in
error, please immediately notify the sender of the erroneous receipt and destroy this email and any attachments of
the same either electronic or printed. Thank you.

Exhibit 14 Page 5