HomeMy WebLinkAbout20101109_3145.pdfDECISION MEMORANDUM
TO: COMMISSIONER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
DATE: NOVEMBER 5, 2010
SUBJECT: CASE NO. GNR-E-09-03
REVIEW OF SURROGATE AVOIDED RESOURCE (SAR) METHODOLOGY
STAFF PROPOSAL TO VACATE SCHEDULING
BACKGROUND
On August 6, 2009, the Idaho Public Utilities Commission (Commission) opened a
generic docket (Case No. GNR-E-09-03) to assess the continued viability of the Commission’s
existing proxy unit or surrogate avoided resource (SAR) methodology for calculating published
avoided cost rates. Specifically, the Commission noticed its intent to explore the continued
reasonableness of using published avoided cost rates as presently calculated for all Qualifying
Cogeneration and Small Power Production Facility (QF) resource types. 18 C.F.R. § 292.101(6).
As reflected in the Commission’s August 6, 2009 Notice, the appropriateness of a single
avoided cost SAR methodology for published rates is being re-examined in the context of PURPA
and FERC requirements1 and the comparative and different generation and operation capabilities of
resources being offered to Idaho utilities, e.g., capacity factor, dispatchability, intermittency. Written
comments were solicited. Reply comments were authorized. All comments are available for review
at the Commission’s office, 472 W. Washington Street, Boise, Idaho and on the Commission’s web
site www.puc.idaho.gov by clicking on “File Room” and then “Electric Cases.”
At the direction of the Commission, Staff prepared a straw man wind SAR proposal
earlier this year and distributed it to a small universe of interested parties (QFs and utilities) for their
review and comment. (The straw man proposal was attached to the Commission’s earlier Notice of
1 The Public Utility Regulatory Policies Act of 1978 (PURPA) and the implementing regulations of the Federal Energy
Regulatory Commission (FERC) (18 C.F.R. § 292).
Public Workshop issued October 6, 2010, and is now available attached to that Notice on the
Commission’s web site.) It was a starting point proposal intended to generate discussion of its
strengths and weaknesses and to provoke the formulation of new and better proposals. Those
comments are also available for review at the Commission’s offices and on its web site.
WORKSHOP AND SCHEDULING
On October 6, 2010, the Commission formally noticed the straw man proposal and
scheduled a public workshop regarding same. By Amended Notice the workshop was rescheduled
for November 3, 2010. The purpose of the workshop was to discuss the strengths and weaknesses of
the straw man proposal and to discuss other proposals of the parties.
Staff represents to the Commission that at the conclusion of the November 3, 2010
workshop while it seems the parties were in agreement that continued discussions should occur on
some level it was agreed that there was no appetite for further discussions of Staff’s straw man
proposal. Staff accordingly recommends that the November 23, 2010 deadline for filing written
comments be vacated. Further procedural recommendations will be presented to the Commission at a
later date.
COMMISSION DECISION
Staff recommends for reasons set forth above that the deadline for filing written comments
regarding the straw man wind SAR proposal currently scheduled for November 23, 2010 be vacated.
Does the Commission agree with Staff’s recommendation?
Scott Woodbury
Deputy Attorney General
bls/M:GNR-E-09-03_sw2