20061113PacifiCorp reply comments.pdf

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2006 HOY 13 M" 8: 53
201 South Main , Suite 2300
Salt lake City, Utah 84111
November 9, 2006 IDAHO eUGLIC
UTILITIES COiV1MISSIO,
VIA ELECTRONIC FILING
AND OVERNIGHT DELIVERY
Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702-5983
Attention:Jean D. Jewell
Commission Secretary
Re:Reply Comments ofPacifiCorp in Case No. GNR-06-
PacifiCorp (d.a. Rocky Mountain Power) hereby submits for filing an original and seven (7)
copies of its Reply Comments in Case No. GNR-06-2 In The Matter of the Commission
Consideration ofthe Five Amendments to Section 111 of the Public Utility Regulatory Policies
Act of 1978 (PURPA) Contained in the Energy Policy Act of2005.
Service of pleadings, exhibits, orders and other documents relating to this proceeding should be
served onthe following:
Dean Brockbank
Senior Attorney
Rocky Mountain Power
One Utah Center, Suite 2200
201 South Main
Salt Lake City, UT 84111
dean. brockbank~pacificorp. com
Brian Dickman
Manager, Idaho Regulatory Affairs
Rocky Mountain Power
One Utah Center, Suite 2300
201 South Main
Salt Lake City, UT 84111
brian. dickman~pacificorp. com
It is respectfully requested that all formal correspondence and Staff requests regarding this
material be addressed to:
Bye-mail (preferred):datareq uest~pacifi corp. com
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon, 97232
By fax:[phone]
Sincerely,
J~~i4i
D. Douglas Larso
Vice President, Regulation
Enclosures
Ji~
cc: Service List in Case No. GNR-06-
Dean Brockbank
PacifiCorp
201 S. Main Street, Suite 2200
Salt Lake City, UT 84111
Telephone: [phone]
Fax: [phone]
E-mail: dean.brockbank~pacificorp.com
Attorney for PacifiCorp
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'
CONSIDERATION OF THE FIVE
AMENDMENTS TO SECTION 111 OF THE
PUBLIC UTILITY REGULATORY POLICIES)
ACT OF 1978 (PURP A) CONTAINED IN THE
ENERGY POLICY ACT OF 2005
CASE NO. GNR-06-
REPLY COMMENTS OF
ACIFICORP
COMES NOW PacifiCorp dba Rocky Mountain Power ("PacifiCorp" or the
Company ), by and through its attorney of record, and respectfully submits the
following reply comments in the above referenced matter.
REPLY COMMENTS
The Company generally agrees with Staffs comments and recommendation "that
the Commission find that the utilities' prior submittals , tariffs, prior Orders and this
decision have satisfied all requirements of the (Energy Policy Act of 2005) for current
action by the utilities." Regarding the standards of Net Metering, Diversity of Fuel
Sources, and Fossil Fuel Generation Efficiency, the Company agrees that no further
action is required to satisfy the Act, and does not object to Staffs recommendation that
COMMENTS OF P ACIFICORP
future Integrated Resource Plans explicitly address the issue of generation efficiency as
part of the planning process. With regards to Smart Metering, the Company appreciates
Staffs view that implementation of such programs should be pro-active, but also
measured, cost-effective, and utility-specific. The Company does not object to Staffs
recommendation that the "status of the Company s time of use programs" and "plans to
changes or upgrades for advanced metering" should be addressed by Rocky Mountain
Power in the context of its next general rate case, in conjunction with a proceeding to
address the cost recovery of any advanced metering programs.
For Interconnection, the Company agrees that the spirit and intent ofthe standard
is met by incorporating IEEE 1547, but is unclear how it would implement Staff s
recommendation that the NARUC Model Agreement ("NARUC Model") be used as a
guideline" for interconnection agreements. PacifiCorp seeks clarification as to the
meaning of "guideline" as the Commission considers adopting Staff s recommendation
on the use of the NARUC Model in the interconnection process and agreements with
distributed generation developers. While not a comprehensive list, the following are
examples of questions that might arise when using the NARUC Model:
The NARUC Model contains a super expedited review which contains
specific time performance criteria for the developer and the utility. Is it Staff s
position to mandate such a super expedited process and specific time
performance criteria?
The NARUC Model contains a super expedited review in which certain
interconnections must be approved on the sole basis of passing predetermined
screens. Is it Staffs position to mandate such process without the provision
for an engineering study ofthe impact of the interconnected generation?
The NARUC Model process for applications which do not meet the super
expedited process contains specific time performance criteria for the
developer and the utility. Is it Staffs position to mandate such a specific time
performance criteria?
COMMENTS OF P ACIFICORP
The NARUC Model does not contain an upper limit on generation size while
IEEE 1547 is directed at interconnections of 10 MW and below. Does Staff
propose to use the NARUC Model as a guideline for all state jurisdictional
interconnections in Idaho?
The NARUC Model does not require the interconnection customer to provide
general liability insurance. Is it Staff s position that general liability insurance
not be mandated to generator interconnection customers?
PacifiCorp agrees that the NARUC Model can serve as a tool or reference and the
use of the word "guideline" should be in that frame of reference, and should not be
applied as a rule to the Company s interconnection agreements.
It is respectfully requested that all communications regarding these comments be
directed to Brian Dickman at [phone].
Respectfully submitted this 9th day of November 2006.
?u~~p
Attorney for PacifiCorp
COMMENTS OF P ACIFICORP
PROOF OF SERVICE
I hereby certify that on this 9th day of November, 2006 I caused to be served, via E-
mail, a true and correct copy ofthe foregoing REPL Y COMMENTS OF P ACIFICORP in
Case No. GNR-06-02 to the following parties as shown:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
iiewell~puc.state.id.
Kelly Norwood
Vice President State Regulation
Bruce Folsom, Manager
A vista Utilities
O. Box 3727
Spokane, W A 99220-3727
kelly .norwood~avistacorp.com
bruce. fo lsom~avistacorp. com
David Meyer
P. & Chief Counsel
A vista Corporation
O. Box 3727
Spokane, W A 99220-3727
Email: david.meyer~avistacorp.com
Barton L. Kline, Senior Attorney
Monica B. Moen, Attorney
Lisa Nordstrom, Attorney
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Email: bkline~idahopower.com
mmoen~idahopower .com
lnordstrom~i dahopower. com
John R. Gale, VP-Regulatory Affairs
Maggie Brilz, Director, Pricing
Greg Said, Manager, Revenue Requirement
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Email: rgale~idahopower.com
mbrilz~idahopower.com
gsaid~idahopower.com
Dean Brockbank, Attorney
PacifiCorp/dba Rocky Mountain Power
201 S. Main St. Suite 2200
Salt Lake City, UT 84111
Email: dean.brockbank~pacificorp.com
Brian Dickman, Manager
PacifiCorp/dba Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
Email: brian.dickman~pacificorp.com
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, ID 83720-0074
Email: don.howell~puc.idaho.gov
Harry Hall, Staff Engineer
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, ID 83720-0074
Email: harry.hall~puc.idaho.gov
Ted S. Sorenson, P.
Sorenson Engineering
5203 South 11 th East
Idaho Falls, ID 83404
Email: ted~tsorenson.net
Pam Conley
O. Box 2526
Boise, ID 83701
Email: pgconley~cableone.net
Scott H. DeBroff, Esq.
Smigel, Anderson & Sacks
4431 N. Front Street
Harrisburg, PA 17110
Email: sdebroff~sasllp.com
Ken Miller
Idaho Energy Advocate
NW Energy Coalition
5400 W. Franklin, Suite G
Boise, ID 83705
Email: ken~nwenergy.org
David Hawk
Director, Energy Natural Resources
R. Simplot Company
O. Box 27 (83707)
999 Main Street
Boise, ID 83702
Email: dhawk~simplot.com
Ben Boyd
Director, Regulatory Affairs
Itron, Inc.
5430 Hickory Village Drive
Kingwood, TX 77345
Email: ben.boyd~itron.com
Peter Richardson
Richardson & O'Leary PLLC
515 N. 2ih Street
Boise, ID 83702
Email: peter~richardsonandoleary .com
SupervIsor, Regulations Administration