20110307AVU Response to Reconsideration Petition.pdf

March 2011
-..
~
Retponse of Avista Corporation to NIPPC's Petition for Reconsideration tlfOrder
No. 32176
IPUC Docket No. GNR-E-I0-4
Please find enclosed for filing an original and seven copies of the Response of A vista
Corpration in Opposition to Petition for Reconsideration of Northwest Intermountain Power
Producers Coalition in the above-referenced docket Please let me know iryou have any
questions regarding this fiing.
Sincerely,
Michael G.
Senior Counsel
'"
8308)
)
) CASE NO.
)
)
)
)
) OF THE NORTHWEST AND
) fNTERMOUNTATN POWER
) PRODUCERS
.- )
Nortwest an Intermountain
In its Petition. NllPC requests that the Commission:
changes to the Integred Resource Plan Methodology
the i 0 aMW published avoided cost rate eligibilty cap for wind and solar projects.
2.take any position with regard to NIPlC's request that the Commission take
offcial notice of oortain documents. NIPPC's remaining requests included its Petiton,
RESPONSE OF AVISTA CORPORATION IN OPPOSTION TO PET1TION FOR
RECONSIDERATION
Baekgund
2010, A vista Corpration along with Idao
Rocky Mountain Power, (collectively, the "Utilities") filed a
requesting the Commission to initiate an investigation into various avoided cost issues regarng
Facilties ("QFs") under the Public Utilty Regulatory
raised in the Joint Petition, the Utilties requested that the
order adjusting the published avoided cost fate eligibilty
1 0 average megawatts ("aMW") to 1 00 kilowatts t'k W") effective immediately.
COlnmÌssion issued the Notice in which it,
to lower the published avoided rostrate
. Parties wereaftbrded an opportunity fie comments and
comments (m the issue of whether the Commission should lower
published avoided cost rates. Oral argument on that issue was held on i.
the Commission issued Order 32176. In Order No.
Commission, among other things, (1) rejected, in part, NIPPC's request tht the Commission
for wind and
100 kW;and (3) initiated additional proceedings to investigate and
determine, in a finite timeframe, requirements by which \vind and solar a
without allowing large QFs to obtain a rate that
such projects. To that end, the Commission a
In that proceeding, the parties wil havc thc opportunity to
Page RESPONSE OF A VISTA CORPORA nON IN OPPOSTION TO PE'I1TION FOR
RECONSIDERATION
n. Response to NIPPC's Petition
NIPPC requests that the Commission: (1) take offcial notice
documents; (2) hold an evidentiàr hearing on the issues addrcssed in Order No. 32176;
10 aMW published aVQided
with regard to NIPPC's request
NIPPC's remaining request%
be denied.
NIPPC's Request for an Evidentiary Hearing Should be Denied as Möot.
Commission hold an evidentiary hearing on
The issues set for consideration in GNR-E-l 0-04 the
reduced. the appropriateness of exempting non-wind QF projects from
5. Following the submission of written comments and
for published avoided cost rates from 10 aMW to 100 k W for wind and solar "while
the implications ofdisaggregaied QFprojects."
32176 at 9 (emphasis added) (footnote omitted).
In order to furher investigate the implications of disaggregated QF projects, the
which it
RESPONSE OF A VISTA CORPORA nON IN OPPOSTION TO PETnl0N FOR
avoided cost rate eligibilty cap structure (I) allows
small wind and solar QFs to avail themselves of published fates 10aMW
disaggregating in order to obtain a published avoided
32176 at i L The Commission fuher
abîlty to a
during the week of May 9,201 I. ld, The
for that purpse.
eveti assuming (without conceding) tht an evidentiary hearing is necessary, determne issues
regarding the eligibilty cap for published avoided cost rates, the Commission has provided for
Therefore, in light of the process provided
01.request fur is unnecessary and, in any event,
B~ NIPPC's Requetted Order Requiriug the Invettor..Owued Utilties in Idaho
to Implement Changet to the IRP Methodolog Shmild Be Denied.
in Idaho to immcdiately
implement chages to the IRP Methodology. Petition at 2. NIPPC argues that the IRP
Methodology is flawed because it.fails to take into account
tht it produces "wildly inaccurte
As an initial matter, NIPPC's request for immediate chanes to the investor-owned
is beyond the scope of the proceeding.
for consideration in GNR.E.. i 0.;04 where
cap; and (3) the consequences
A VISTA CORPORATION TN OPPOS'I10N TO
TION
IO aMW projects to utilze the published rate. i Id. NIPPC's request for an
utilities to immediately implement changes to the IRP
is beyond
the investor-owned utilty's IRP
NIPPC admits as much in its Petition.NIPPC
any support, that it has "proved that (the IR
Petition at 1 1. Simply stated, NIPPC cannot have it both In
At most, NIPPC has asserted unsubstantiated allegations
Pctition at i 0-14. Such unsubstantiated allegations
byNIPPC.
C. NJPPC's Reqest to Reiustate the 10 aMW Eligibilty Cap for Pu.blihed
Avoided Cost Rates Shou.ld Be ~ied.
state utilty commissions to "require the utilties
"NIPPC
IRP Methodology, as currently implemented. produces rates below the
., Petition at 14 (emphasis in original).
allegation that the IRP Methodology produces fates below the full
Such unsubstantiated allegations provide no basis for NIPPC's request
i In Order No. 32176 at 10. the Commission stated: "We note that paties have
challenged the accuracy oftbe lRP Methodology. We believe that the IRP Methodology
appropriately assess when the QF is capable of delivering its resources against when the
most in need of such resources. The resultat pricing is 1'~flective
thè utilty. TIs comment by the Commission did not serve to expand the
proceeding.
RESPONSE OF A VIST A CORPORATION iN OPPOSTlON TO PE1ITION
RECONSIDERATION
Accrdingly, NIPPC's request to have the i 0 aMW eligibìlty cap for published avoided cost
III. Conclusion
Avista respectfuly submits this response to NIPPC'sPetition for Reconsideration of
As discussed herein, Avista does not take any position with regard to
request that the Commission take offcial notice of cerain documents.
order requiring the investor-owned utilties Idaho to
10 aMW eligibilty cap for avoided cost rates, should be
RESPONSE OF AVISTA CORPORA nON IN OPPOSTlON TOPE'DTION
CERTICATE OF SERVICE
7th day of Marh 20 i i. tre and corrt copies of
the foregoing Response of A vista Corration were delivere to the following persons
via Em (unless otherwise indicated).
Jean Jewell
Danel E. Solanr
Senor Couns
Donovan E. Waler
Lisa Nordtrom
5203 So
Idab Fals. ID 8340
Pag l-CTIICATE OF SERVICE
Donad L. Howell. n
Krs Susa
Deuty Attorneys Gener
Ida Publi Utilities Commssion
472 W. Washingtn St.
Boise. ID 83702
Emal: don.howell~puc.idao.gov
krissa~~r(Ønucjdaho.gov
Peter Richardson
Gregory M. Adams
Richason & Of Le
ID 83702
R. Greg Ferney
Mimura Law Ofces, PLL
2176 E. Frain Rd.. Suite 120
Meridian. ID 83642
Eml:
RobrtD. Kan
E~ccutive Di
Nortwes and Interountain Power
Pruce Coaltion
i i i 7 Minor Ave.. Suite 300
Glen lko
Mart Ruger
Ida Windfar. LLC
672 Blar Ave,
Piedont,
E-mal:
Dan Zentz
VP. Summit Power Group, Inc.
Westmnster
WA9923
JamCarlis
Membe
DEVEOPMEN GROUP
OF IDAHO. LLC
802 West Banock Strt, Ste. 1200
Pae 2--ERT1FICATB OF SERVICE
Seatte. W A 9810
Eml:
Thma.i; H. Nelson
Attrney for Renewable Energ Coalition
POBox 1211
Welches,
Eml:
Bill Piske. Manager
Interconnect Solar Development. LLC
i 303 E. Carer
Boise. ID 83706
Emal:
8m Brown, Cha
Boar of Commissione of Adas COUlty,
Idao
PO Box 48
Scott Montgome
Prident. Ced Crk Wind.
668 Rockwoo Drve
Nort Salt Lae. Uta 8454
Emal:
Wade Tboma
Gener.i Counsel. Dynais Energy
776 E, Riverside Drve, Suite 15
Eae. ID 83616Eml:
Robert A. Paul
Ord View Solar U
Email:
Renewable Energy
Street
Email: jravenesanarcos(!yahoo.com
nservation.ùrg
OF SERVICE
Don Sturtevant
Energy Director
J. R. Simplot Company
ONE CAPri AL CENTER
999 Main Street~ P.O. Box
Boise, Idaho 83707-0027
don.sturevantØ)simplot.eom
Nort Side Canal Company
Diehl~ General Manager
Lincoln St.
MJ Humphries
Blue Ribbon Energy LLC
Ammon Road
Ammon, ID 83406
blueribbonenergyØ)gmail.com
Greg Seifert
Kur Meyers
Idaho National Laboratory
Conventional Renewable Energy
Ken Miler
Clea Energy Program Director
Snake River AHance
Box 1731
Boise, 10 83701