20210525Exhibit 15.pdf

Exhibit 15

May 11, 2020
Letter from Greg Adams

May 11, 2020

Via E-Mail

Jacob A. McDermott
Senior Counsel
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
[e-mail]

Kyle Moore
Rocky Mountain Power
Manager - QF Contracts
825 NE Multnomah St, Suite 600
Portland, Oregon 97232
[e-mail]

RE: Fall River Rural Electric Cooperative, Inc.’s Proposed Power Purchase Agreement for
Chester Diversion Hydroelectric Project

Jake and Kyle:
I write to follow up on our prior correspondence related to the Chester Diversion Project.
Fall River Rural Electric Cooperative (Fall River) has investigated options for moving forward
with the power purchase agreement (PPA) negotiations in an amicable way. Kyle Moore’s prior
email dated March 13, 2020, communicated that PacifiCorp would not agree to discuss a PPA
for the Chester Diversion Project that relied upon completion of interconnection facilities to
PacifiCorp’s system due to the fact that PacifiCorp is not currently processing Fall River’s
interconnection request. Instead, Kyle suggested that Fall River should consider a “transmission
arrangement to deliver the output to a point of delivery on PacifiCorp’s system in Idaho”, which
would necessitate a so-called off-system PPA as opposed to the on-system PPA we had proposed
to PacifiCorp.
While Fall River disagrees with PacifiCorp’s refusal to discuss the on-system PPA, Fall
River has further investigated its ability to transmit the power to PacifiCorp’s system without an
interconnection from the facility to PacifiCorp’s system, and Fall River has determined that it
will amend its PPA request to request that PacifiCorp provide the “off-system” PPA for delivery
of the Chester Diversion Project’s power. Fall River is able to deliver the power over Bonneville
Power Administration’s (BPA) system to PacifiCorp’s Goshen Substation. Accordingly, the
prior PPA request sent on September 12, 2019, is amended in items e) and k) as follows to
Exhibit 15 Page 1
Rocky Mountain Power
May 11, 2020
Page 2

change the information related to the interconnection facilities and the transmission
arrangements to PacifiCorp’s system (with alterations in underline and strikethrough):
e) proposed site location and electrical interconnection point:

The Chester Diversion Project is located in Fremont County, Idaho, and utilizes
Fremont-Madison Irrigation District’s pre-existing Cross Cut Diversion Dam on the
Henry’s Fork of the Snake River, immediately downstream of the confluence with the
Falls River. The site location is between the towns of St. Anthony and Ashton, Idaho.
The geographic coordinates are N 44°01.014' W 111°35.005'.

The Chester Diversion Project is already interconnected to Fall River’s electrical
distribution system near the facility. As described in the FERC license, the
interconnection facilities include a 15-kilovolt primary transmission line that
extends about 1.4-miles from the powerhouse along the access road right-of-way
to connect to Fall River’s existing substation.

Fall River proposes to deliver the electricity from the Chester Diversion Project to the
closest feasible point of interconnection on PacifiCorp’s system. The closest
PacifiCorp pole to the Chester Diversion Project and Fall River’s existing
infrastructure is pole 31 08 041, # 347900, and Fall River therefore proposes to
deliver the electricity to that pole as the point of interconnection, if interconnection is
feasible at that location. Fall River will work with PacifiCorp Transmission to secure
this, or another suitable, point of interconnection.

k) status of transmission interconnection arrangements including interconnection queue
number:

The facility is currently interconnected to Fall River’s system, and Fall River will
transmit the output to PacifiCorp’s Goshen Substation via a long-term firm point-
to-point transmission service agreement with BPA. BPA refers to this POD as the
“Goshen 161 kV – PAC” POD, and “BPAT.PACW” reservation point. Fall River
has been in contact with BPA, and BPA has confirmed the output of the Chester
Diversion Project can be delivered to PacifiCorp at the Goshen Substation. Fall
River has begun the process of securing the point-to-point transmission rights.
but Fall River intends to complete an interconnection to deliver the entire net
output to Rocky Mountain Power’s system. There is not yet a queue number.
Fall River requests a draft PPA for an on system facility interconnecting directly
to PacifiCorp’s system.

Aside from the off-system delivery terms, we propose that the terms of the PPA be
consistent with those we have negotiated for the Felt Project so that the two PPAs are generally
consistent. Because the pro forma PPA that you sent to us does not include provisions for an off-
system delivery, we request that you please provide a version containing your preferred off-
Exhibit 15 Page 2
Rocky Mountain Power
May 11, 2020
Page 3

system PPA provisions for discussion. We can make the edits to include the relevant agreed-to
provisions under discussion in the Felt Project’s PPA if you would like us to do so.

Please contact me with any questions.

Sincerely,

Gregory M. Adams
Attorney for Fall River Rural Electric Cooperative, Inc.

cc: Bryan Case, Fall River Rural Electric Cooperative, Inc. (e-mail only)
Thomas Woodworth, Counsel for PacifiCorp (e-mail only)

Exhibit 15 Page 3