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Home My WebLink About20090921Idaho Forest Group Motion, Concurrence.pdfORIGINAL Dean J. Miler (ISB No. 1968) McDEVITT & MILLER LLP 420 West Bannock Street P.O. BOX 2564-83701 Boise, Idaho 83702 Tel: 208-343-7500 Fax: 208-336-6912 j oe(âmcdevitt - miler .com RECC'\ 'en~~i .J t. ,,) 2009 SEP 21 AM II: I , D .. LJO l" F''¡ ,/'1.: ;U..rt.. i..1Jt~j~,,"'l\.~.. .._~;" j UTILITiES CO~IiMIS::iu~ì Attorney for Idaho Forest GroupLLC BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF A REVIEW OF THE SURROGATE AVOIDABLE RESOURCE (SAR) METHODOLOGY FOR CALCULATING PUBLISHED AVOIDED COST RATES CASE NO. GNR-E-09-03 MOTION TO PERMIT LATE FILING OF COMMENTS COMES NOW Idaho Forest Group LLC and pursuant to RP 56 moves the Commission for an Order permitting the late fiing of the attached Concurrence of Idaho Forest Group, and in support thereof respectfully shows as follows: The attached Concurrence was drafted and prepared to be fied on Friday, September 18,2009, as required by the Commission Notice and Order No. 30873. Idaho Forest Group authorized the fiing of the attached Concurrence late in the day of September 18,2009. Due, however to an interption in electronic mail service, the undersigned did not receive from Idaho Forest Group authorization to file the attached Concurrence until after 5:00 pm on September 12, 2009. Permitting the late filing of the attached concurrence wil not prejudice the rights of any party or cause undue delay to this proceeding. MOTION TO PERMIT LATE FILING OF COMMENTS-l WHEREFORE, Idaho Forest Group respectfully requests that the attached Concurence be accepted for late filing. DATED this~day of September, 2009. IDAHO FOREST GROUP LLC BY:~LW ~ Dean J. Miller Attorney for Idaho Forest Group LLC MOTION TO PERMIT LATE FILING OF COMMENTS-2 CERTIFICATE OF SERVICE I hereby certify that on the £ day of September, 2009, I caused to be served, via the methodes) indicated below, true and correct copies ofthe foregoing document, upon: Jean Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, ID 83720-0074 j j eweU(âpuc.state.id.us Hand Delivered U.S. Mail Fax Fed. Express Email Scott Woodbur Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, ID 83720-0074 scott. woodbury(âpuc.idaho.gov Hand Delivered U.S. Mail Fax Fed. Express Email Bar Kline, Esq. Lisa Nordstrom, Esq. Idaho Power P.O. Box 70 Boise, ID 83702 bkline(âidahopower .com lnordstrom(áidahopower .com Hand Delivered U.S. Mail Fax Fed. Express Email Dean Brockban Daniel Solander Mark Moench Rocky Mountain Power One Utah Center 201 S. Main Street, Suite 2300 Salt Lake City, UT 84111 datareguest(á.pacifcorp.com Hand Delivered U.S. Mail Fax Fed. Express Email Michael G. Andrea Senior Counsel A vista Corporation 1411 E. Mission Avenue, MSC-23 Spokane, W A 99202 michael.andrea(álavistacorp.com Hand Delivered U.S. Mail Fax Fed. Express Email ~~"- ~"- ~"- ~"- ~"-J' ~"-t ~"-J£ ~"- U )4 ~"- A ~"- A uß-~"- ~"- It MOTION TO PERMIT LATE FILING OF COMMENTS-3 " ')ORIGINAL Dean J. Miler (ISB No. 1968) McDEVITT & MILLER LLP 420 West Bannock Street P.O. BOX 2564-83701 Boise, Idaho 83702 Tel: 208-343-7500 Fax: 208-336-6912 j oe(âmcdevitt - miller .com R.ECEIVt'I"" ,..1. 2009 SEP 2' AM' I: 01 Attorney for Idaho Forest Group BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF A REVIEW OF THE SURROGATE AVOIDABLE RESOURCE (SAR) METHODOLOGY FOR CALCULATING PUBLISHED AVOIDED COST RATES CASE NO. GNR-E-09-03 CONCURRNCE OF IDAHO FOREST GROUP IN COMMENTS OF SAGEBRUSH ENERGY COMES NOW Idaho Forest Group (Idaho Forest) and concurs in the Comments of Sagebrush Energy LLC as follows: Idaho Forest is engaged in the business of growing, harvesting and processing trees and forest products. It operates four lumber mils in North Idaho. Idaho Forest is in the process of developing a qualifying facility biomass cogeneration facility at its mil located in Grangevile, Idaho. Idaho Forest is actively negotiating with Avista Corporation for a purchase power agreement for the Grangevile facility. Idaho Forest estimates that the Grangevile cogeneration facility wil have an anual capacity factor of approximately 90%. The Sagebrush Energy Comments correctly observe that avoided cost rates produced the current CCCT surogate avoided resource have been de-rated for wind QF's to take into account wind varability and lower capacity factor. CONCURRNCE OF IDAHO FOREST GROUP IN COMMENTS OF SAGEBRUSH ENERGY-l As noted above, the expected capacity factor of Idaho Forest's intended biomass facility is approximately equal to that of the CCCT surrogate resource. By party of reasoning, just as the CCCT SAR has been de-rated for wind projects, a wind SAR would somehow have to be up-rated for high capacity factor QF's such as Idaho Forest's planned facility. To Idaho Forest's knowledge there is no known methodology for accomplishing this necessar adjustment. Alternatively, the Commission would be faced with having two (or maybe more) surogate avoided resources, with the attendant expense and effort of maintaining and updating two SAR models in paralleL. Finally, if the Commission does decide to fuer investigate the feasibility of a wind SAR, in any Order initiating fuher proceedings, the Commission should re-affirm its declaration in the Notice that the current avoided costs "remain presumptively reasonable and available to QFs until changed". (Notice and Order No. 30873, pg 3). DATED this ~ day of September, 2009. IDAHO FOREST GROUP By:DiWL-. \Dean J. Miler Attorney for Idaho Forest Group CONCURNCE OF IDAHO FOREST GROUP IN COMMENTS OF SAGEBRUSH ENERGY-2 ~. 'i , .. CERTIFICATE OF SERVICE I hereby certify that on the ~day of September, 2009, I caused to be served, via the methodes) indicated below, true and correct copies of the foregoing document, upon: Jean Jewell, Secretar Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise,ID 83720-0074 j j ew ell(âp uc.state.id. us Hand Delivered U.S. Mail Fax Fed. Express Email Scott Woodbur Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, ID 83720-0074 scott. woodbury(âpuc.idaho.gov Hand Delivered U.S. Mail Fax Fed. Express Email Bar Kline, Esq. Lisa Nordstrom, Esq. Idaho Power P.O. Box 70 Boise, ID 83702 bklne(âidahopower .com lnordstrom(âidahopower .com Hand Delivered U.S. Mail Fax Fed. Express Email Dean Brockban Daniel Solander Mark Moench Rocky Mountain Power One Utah Center 201 S. Main Street, Suite 2300 Salt Lake City, UT 84111 datareguest(âpacificorp.com Hand Delivered U.S. Mail Fax Fed. Express Email Michael G. Andrea Senior Counsel A vista Corporation 1411 E. Mission Avenue, MSC-23 Spokane, W A 99202 michael.andrea(âavistacorp.com Hand Delivered U.S. Mail Fax Fed. Express Email ~"-~ ~"- t: u~u ~"- ;L ~"- ~"- JL t ~"- ~"- "- ~"- J4~"- ~"-Jt CONCURENCE OF IDAHO FOREST GROUP IN COMMENTS OF SAGEBRUSH ENERGY-3