20090227Answer to Motion.pdf

Glenn Ikemoto
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Tel: [phone]
Fax: [phone]
glennicmpacbell.net
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MAnER OF THE JOINT PETITION
TO APPROVE A STIPULATION TO
ADJUST PUBLISHED AVODED COST
RATES
ANNUAL ADJUSTMENT TO AVOIDED
COST RATES
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CASE NO. GNR-E-08-02
ANSWER OF IDAHO
WINDFARMS, LLC TO ROCKY
MOUNTAIN POWER'S MOTION
TO CONTINUE
CASE NO. GNR-E-09-01
Idaho Windfarms, LLC ("IWF") is a greenfield wind energy developer in Idaho
and has successfully developed the Bennett Creek and Hot SpringsWindfarms near
Mountain Home. IWF was an active participant in the workshops on avoided cost
assumptions and was a party to the resulting stipulation agreement.
IWF wishes to thank Staff and Idaho Power for fully honoring the process and
their commitments in the stipulation agreement.
We also thank Avista for kinda, sorta, mostly honoring their commitment. As
to their comments, we would note that although the final Northwest Power and
Conservation Council (the "NWPCC" or "Council") assumption on capital costs is higher
than the stipulation, the fixed and variable O&M assumptions are lower. It isn't
appropriate to cherry pick assumptions. Also, the mechanism for incorporating final
NWPCC assumptions into avoided costs was part of the stipulation agreement.
Now we come to Rocky Mountain Power. Their Motion to Continue
represents bad faith. Less than four months ago, they wilingly signed the stipulation
,.
agreement, which included the statement, "The Parties also expect the Council to issue
new forecasts of fuel-related SAR costs this year (2008)" (Paragraph 7). Now they are
reneging. Their argument is that the NWPCC forecast that was approved less than two
months ago is out of date. However, the forecast was known to all parties at the time.
In fact, Staff circulated projected avoided costs based on this forecast prior to the
agreement. These projected values were essentially the same as the ones proposed in
these proceedings.
In addition, the appropriateness of the Council's gas forecast was specifically
addressed during the negotiations. IWF raised the issue itself. Our concern was that
the forecast is not produced on a scheduled basis. Both Staff and the utilities said that
this issue was settled in Order No. 29029 issued on May 21, 2002. Therefore, the
workshop was limited to updating non-fuel assumptions. We would note that since the
last avoided cost update, Rocky Mountain Power has never once petitioned the
Commission because the forecast was out of date and too low.
In Case No. IPC-E-07-15 regarding the methodology for modeling fuel costs,
Rocky Mountain Power made the following comment:
"The Company believes, however, that the correct and ultimate
procedure for fuel cost calculation in the SAR methodology should
use NWPCC's final 2007 median 20-year natural price forecast . ... "
(emphasis added).
Sadly, IWF will end it's comments in these proceedings by simply restating
it's comments in the above case. The editing changes were intentionally left in to
emphasize how little things have changed:
"Since (the Commission) issued Order No. 29029 on May 21, 2002,
which re-established long term contracts for PURPA projects, the
wind industry has had to fight one regulatory battle after another. It
has addressed the issues of firm energy (90/110 Performance Band),
integration costs, aA transmission system upgrades, fuel forecast
modeling and non-fuel cost assumptions. In the more than six fi
years since the Commission's decision to movè forward with PURPA
" .
projects, wind projects have effectively only had access to Published
Prices for six months.
Now, on the eve of completing the latest 16 month two year
suspension to resolve the non-fuel integration cost issue, Rocky
Mountain Power Idaho PO'Ner raises yet another new issue. The
continuous regulatory delays are simply killing the wind industry in
Idaho and costing the ratepayers real money. IWF hopes the
Commission sees through this attempt to continue the suspension of
PURPA wind projects " (Additions are underlined and deletions
have strikethroughs)
Respectfully submitted this 20th day of February, 2009:
Ri:,.i:'vr::nCERTIFICATE OF SERVICE ! c,_'. ...1" f.ú
I hereby certify that on the 20th day of February, 2009, trJJ~~E1ct BMpi&!i
the COMMENTS OF IDAHO WINDFARMS, LLC were delivered by
Jean Jewell, Secretary
Scott Woodbury
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
jjewellcmpuc. state. id. us
Scott. woodburycmpuc. idaho. gov
David J. Meyer, Vice President
Clint Kalich
Michael Andrea
Avisita Utilities
P.O. Box 3727
1411 E. Mission Ave
Spokane, WA 99220-3727
clint. kalichcmavistacorp. com
david. meyercmavistacorp. com
michael.andrea~avistacorp.com
Mark Moench
Daniel Solander
Greg Duvall
Ted Weston
Rocky Mountain Power
One Utah Center
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
daniel. solander~pacificorp. com
mark. moench~pacificorp.com
greg.duvall~pacificorp.com
ted. weston~pacificorp.com
Peter J. Richardson, Esq.
Richardson & O'Leary PLLC
515 N. 27th Street (83702)
P.O. Box 7218
Boise, ID 83707-1218
peter~richardsonandoleary. com
, .
Barton L. Kline
Randy Allphin
Donovan Walker
Idaho Power Company
P.O. Box 70
1221 W. Idaho Street (83702)
Boise, ID 83707-0070
bkline~idahopower. com
rallphin~idahopower.com
DWalker~ldahopower.com
John R. Hammond Jr., Esq.
Fisher Pusch & Alderman
US Bank Plaza, sth Floor
101 South Capital Boulevard
P.O. Box 1308
Boise, ID 83701
jrh~fpa-Iaw.com
--B~~~Principal
Idaho Windfarms, LLC