250419

The provided excerpts do not contain a specific timeline of key events or submissions that have happened or been scheduled in this proceeding. The excerpts focus on the contractual requirements, procedures for achieving milestones, notices, dispute resolution, and confidentiality provisions, but they do not provide a chronological list or schedule of actual events or filings that have occurred in this particular regulatory proceeding.

The docket discusses several financial and timeline risks and concerns:

Financial Risks and Concerns:
- Delay damages: If the seller fails to achieve the commercial operation date by the scheduled date, they must pay delay damages to PacifiCorp. These damages are agreed upon as a fair calculation due to the difficulty of predicting actual losses from such delays 1.
- Seller is responsible for all risks related to eligibility for production tax credits (PTCs), investment tax credits (ITCs), or accelerated depreciation, regardless of whether these benefits are ultimately realized during the term 1.
- Incremental costs: The incremental cost of eligible renewable resources is calculated as the difference between the levelized delivered cost of the renewable resource and the lowest-reasonable-cost substitute. These costs, along with the costs of Renewable Energy Credits (RECs), must be reported as a percentage of the utility's total annual retail revenue requirement 2.
- Resource costs versus revenue requirement: For example, PacifiCorp's Washington revenue requirement for 2025 is $427,744,464, and the report compares this to the expected allocated resource costs for renewable compliance 2.
- Seller must reimburse PacifiCorp for certain costs (for example, if PacifiCorp is deemed responsible for seller's performance under interconnection agreements due to seller lacking "scheduling coordinator" status, seller must reimburse PacifiCorp for these costs) 3.
- Security and damages: Seller's aggregate liability for damages prior to commercial operation date is limited to the amount of project development security posted 1.
- The agreement includes requirements for liquidated damages, which are not considered punitive or consequential damages, but rather a reasonable calculation of anticipated losses 1.

Timeline Risks and Concerns:
- Delay in achieving commercial operation date: If milestones, especially the commercial operation date, are not timely met, financial penalties (delay damages) accrue and can lead to contract termination 1.
- Seller must provide regular updates on construction progress and notify PacifiCorp of any delays or significant developments affecting the timeline 1.
- Uncertainty in permitting: For example, the timeline for permit issuance (such as for Clean Water Act compliance) is uncertain due to regulatory backlogs, which can delay the start of construction or operations 4.
- Force majeure: The agreement defines force majeure events (natural disasters, war, government action, etc.) that could prevent timely performance of obligations; however, certain risks such as economic hardship or inability to obtain supplies (unless caused by force majeure) are explicitly excluded from force majeure protection 1, 1.
- Seller must inform PacifiCorp of forced outages, deratings, or any limitations on facility output, and must take reasonable actions to minimize the duration and frequency of such events to avoid further risk to the output and compliance timelines 3.

In summary, the key financial risks are related to delay damages, incremental resource costs, responsibility for tax incentive realization, and cost reimbursement obligations. Timeline risks center on delays in project milestones, regulatory permitting uncertainty, and events of force majeure that could impact timely completion and operation.

The docket identifies the following areas of growth:

1. Increase in Renewable Energy Portfolio
- Pacific Power (PacifiCorp) will supply at least 15 percent of its average Washington load in 2025 with eligible renewable resources and renewable energy credits (RECs), an increase consistent with Washington’s Renewable Portfolio Standard (RPS) requirements. The company met its 2024 target and plans to meet the 2025 target using a combination of eligible RECs, company- and third-party-owned wind resources, and hydroelectric facilities with upgrades completed after March 1999 1, 1.
- Key Considerations: Compliance with RCW 19.285 and WAC 480-109, accurate calculation of average annual load, and ensuring eligibility of renewable resources and RECs. The company does not plan to use alternative compliance mechanisms for 2024 or 2025.

2. Expansion and Repowering of Renewable Resources
- Growth is noted in the repowering of twelve wind resources (e.g., Dunlap, Glenrock I/III, Goodnoe Hills, High Plains, Leaning Juniper, Marengo I/II, McFadden Ridge, Rolling Hills, Seven Mile Hill I/II) during 2019 and 2020. Repowering involves capital upgrades that extend plant life, change capacity value, and alter costs 1, 1.
- Key Considerations: Application of a stakeholder-agreed cost methodology, compliance with commission rules, and recalculation of incremental costs post-repowering. Methodologies must be filed and sometimes require waivers from existing rules.

3. Incremental Hydroelectric Upgrades
- Efficiency upgrades at selected hydropower units after March 1999 are a specific growth area. These are included as part of eligible renewable resources under the RPS 1, 1.
- Key Considerations: The incremental cost for these upgrades is calculated as the difference in levelized delivered cost versus a comparable non-eligible resource at the time of investment. Only upgrades post-March 1999 are eligible, and historic methodology is applied for cost assessments.

4. Acquisition of Renewable Energy Credits (RECs)
- The use and acquisition of both bundled and unbundled RECs from various eligible resource types (water, wind, solar, geothermal, landfill gas, etc.) continue to grow as mechanisms for RPS compliance 1, 1.
- Key Considerations: REC costs for REC-only purchases are based on contract prices; the company needs to ensure proper tracking and documentation for compliance and reporting.

Each area requires strict adherence to regulatory requirements, accurate cost methodology, and ongoing reporting to demonstrate compliance and cost-effectiveness relative to annual revenue requirements 1.

The excerpts provided do not contain information specifying the stakeholders' positions (for or against) on any proposals in the referenced docket. The only explicit stakeholders identified in the docket are:

- PacifiCorp (Applicant)
- Assistant Attorney General Jeff Roberson, Office of the Attorney General, Public Counsel

No other stakeholders or their positions regarding any proposals are detailed in the provided excerpts 1.

Docket 250419 concerns PacifiCorp's compliance with Washington's Renewable Portfolio Standard (RPS) for 2025. PacifiCorp, operating as Pacific Power & Light Company, submitted its 2025 annual RPS report to the Washington Utilities and Transportation Commission and the Washington Department of Commerce. The report demonstrates how PacifiCorp met the 2024 renewable energy target and outlines plans to meet the 2025 target.

Key points:
- PacifiCorp is required to supply at least 15 percent of its average Washington load from eligible renewable resources or equivalent renewable energy credits (RECs) in 2025.
- For 2024, average retail sales were 4,112,311 MWh with a renewable target of 623,495 MWh. For 2025, average retail sales are projected at 4,032,026 MWh with a renewable target of 618,337 MWh. PacifiCorp expects to supply 1,027,278 MWh of qualifying resources and RECs for 2025.
- The company uses a combination of eligible renewables and RECs to achieve compliance and does not intend to use alternative compliance mechanisms.
- The report includes detailed methodologies for calculating incremental costs of renewable resources and RECs, as required by state law and administrative code. For 2025, PacifiCorp’s Washington revenue requirement is $427,744,464.
- Attachments include methodology descriptions, incremental cost reports, and correspondence related to hydroelectric upgrades 1, 1, 1, 1, 1.

The docket also references regulatory compliance history, allocation protocols, and major repowering projects for renewable resources.