20070621Decision memo disaggregation.pdf

DECISION MEMORANDUM
TO:CO MMISSI 0 NER KJELLAND ER
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
COMMISSION STAFF
LEG AL
FROM:SCOTT WOODBURY
DATE:JUNE 21, 2007
SUBJECT:CASE NO. PAC-07-07 (PacifiCorp)
PETITION REGARDING PURP A WIND QFS: TO REVISE PUBLISHED
AVOIDED COST RATES; TO ELIMINATE 90%/110% PERFORMANCE
BAND; AND TO AMEND PUBLISHED RATE ELIGIBILITY RULES -
(DISAGGREGATION)
CASE NO. A VU-07-02 (Avista)
PETITION REGARDING PURP A WIND QFS: TO REVISE PUBLISHED
AVOIDED COST RATES; TO ELIMINATE 90%/110% PERFORMANCE
BAND; AND TO AMEND PUBLISHED RATE ELIGIBILITY RULES -
(DISAGGREGATION)
A common issue in each case is "disaggregation " a utility proposal to prevent QFs
from disaggregating large QF wind projects into smaller projects to qualify for published
avoided cost rates available to QFs smaller than 10 MW.
Staff (with utility acquiescence) proposes to process the disaggregation issue
pursuant to Modified Procedure; i., by written submission rather than by hearing. IDAP A
31.01.01.201-204.
CO MMISSI ON D ECISI
Staff recommends that the "disaggregation" issue in the above cases be processed
pursuant to Modified Procedure. Does the Commission agree with the recommended procedure?
Scott Woodbury
bls/M:PAC-O7-07 A VU-O7-02 sw