20100209_2852.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:MATT ELAM
DATE:FEBRUARY 8, 2010
SUBJECT:TARIFF ADVICE OF ROCKY MOUNTAIN POWER COMPANY FOR
AUTHORITY TO ADD A SPECIFIC GENERATION TECHNOLOGY TO
THE LIST OF RESOURCES THAT ARE ELIGIBLE FOR SUPPORT
UNDER THE BLUE SKY PROGRAM; TARIFF ADVICE NO. 10-01.
On January 13 2010, Rocky Mountain Power requested the addition of language that
would include "pipeline or irrigation canal hydroelectric systems" to the list of generation
resources eligible under Schedule 70 and 73.
THE APPLICATION
The Company s Blue Sky Program provides customers in Idaho the opportunity to support
the development of renewable energy beyond what is included in the Company s general resource
portfolio. Through the Program, the Company purchases renewable energy credits ("RECs ) to
match customer subscriptions. After customers subscriptions are satisfied, and the programs
administrative costs are covered, the remaining funds are used for community-based renewable
energy projects.
Schedules 70 and 73 have a list of renewable energy technologies eligible for support
through the Blue Sky Program. Currently this list does not include pipeline or irrigation canal
hydroelectric systems. In its Application, the Company says "many water and irrigation systems
utilize pressure reducing valves to control pressure as water flows from higher to lower elevation
zones. These valves can be replaced with or substituted by hydro turbines which accomplish the
same task and convert the reduction in pressure to electricity." The Company also attests that
these generation systems are certifiable by Green-e Energy, the nation s leading independent
DECISION MEMORANDUM FEBRUARY 8 , 2010
certification and verification program for renewable energy. According to Green-e Energy,
turbines have no negative impact on water quality relative to the pressure reducing valves.
Therefore, the Company requests that the environmental impacts of these generation systems be
treated as equivocal to other eligible hydro resources under the Blue Sky program.
Under the current tariffs, hydro generation projects are eligible for program support only if
they are certified by the Low Impact Hydropower Institute ("LIHI") or are wave or tidal action
projects. The Company claims that even though the pipeline and irrigation canal generation
systems are LIHI certifiable, the complex administrative burden and cost to obtain certification is
often prohibitive for these smaller facilities. The Company believes that the LIHI certification
process may discourage entities from seeking Blue Sky program funding for these types of projects
as long as LIHI certification is required. Therefore, the Company requests the addition of the
pipeline and irrigation canal generation systems as a Blue Sky program resource, without the
requirement of a LIHI certification.
STAFF REVIEW
Staff reviewed the Company s proposal to include pipeline or irrigation canal hydroelectric
systems in the Blue Sky programs list of generation resources. Specifically Staff reviewed the
Low Impact Hydropower Institute ("LIHI") application process, and Green-e Energy s acceptance
of the technology without certification by the Low Impact Hydropower Institute ("LIHI"
Staff has confirmed that the Low Impact Hydropower Institute ("LIHI") will certify
pipeline or irrigation canal hydroelectric systems given they meet specific environmental
standards. The Company contends that the LIHI certification process might discourage entities
from seeking Blue Sky program funding, after reviewing the certification process, Staff agrees that
it has the potential to discourage entities from seeking Blue Sky program funding. Since LIHI
certification for smaller facilities could become cost prohibitive and administratively burdensome
and given Green-e Energy qualifies the resource for RECs regardless of LIHI certification, Staff
recommends approving the resource for the Blue Sky program.
DECISION MEMORANDUM FEBRUARY 8, 2010
ST AFF RECOMMENDATION
Staff has reviewed the proposal and recommends that the changes to Schedules 70 and 73
be approved.
COMMISSION DECISION
Does the Commission wish to approve the changes to Schedules 70 and 73?
Matt Elam
i:udmemos/Advice No. 10-01 Addition to Resource Listdoc
DECISION MEMORANDUM FEBRUARY 8, 2010