HomeMy WebLinkAbout20130108Petition for Clarification Reconsideration.pdfIDAHO 91131OWER0
An IDACORP company
20:JAfl -8 PM 4: 01
DONOVAN E. WALKER
Lead Counsel LJTtL1TFS CC'}U
dwalker(idahopower.com
January 8, 2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. GNR-E-11-03
PURPA SAR and IRP Methodologies - Idaho Power Company's Petition for
Clarification and/or Reconsideration
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and seven (7) copies of Idaho
Power Company's Petition for Clarification and/or Reconsideration.
Z yours,
van E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5317
Facsimile: (208) 388-6936
dwaIker(ãidahopower.com
rrtarr rr
2013 JAN -3 PM 1: 07
UTILITIES COMMISSG
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
REVIEW OF PURPA QF CONTRACT
PROVISIONS INCLUDING THE
SURROGATE AVOIDED RESOURCE
(SAR) AND INTEGRATED RESOURCE
PLANNING (IRP) METHODOLOGIES FOR
CALCULATING AVOIDED COST RATES.
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY'S
PETITION FOR CLARIFICATION
AND/OR RECONSIDERATION
Idaho Power Company ("Idaho Power" or "Company"), petitioner herein, pursuant
to RP 33, 325, and 331, et seq., and Idaho Code § 61-626, respectfully petitions the
Idaho Public Utilities Commission ("Commission") for clarification and/or reconsideration
of final Order No. 32697, dated December 18, 2012, as well as the errata to Order No.
32697, dated January 2, 2013, issued in Case No. GNR-E-1 1-03 ("the Order"). Idaho
Power seeks clarification regarding: (1) the methodology and inputs utilized to establish
the published avoided cost rates that appear as Attachments A, B, and C to the Order;
(2) the Commission's finding that curtailment under 18 C.F.R. § 304(f) "was not
reasonably contemplated when the parties entered into their agreements"; (3) the
Commission's use of the terms "contract extensions or renewals"; and (4) whether the
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -1
June 1 date for the update of the surrogate avoided resource ("SAR") published rates
and the integrated resource plan ("IRP") fuel price and load forecasts is the most
appropriate date.
To the extent that the Commission feels the requested clarifications go beyond
the scope of a clarification, Idaho Power then respectfully requests reconsideration of
the issues identified herein. See RP 325.
I. BACKGROUND
This matter originated with a November 5, 2010, filing by Idaho Power, Avista
Corporation, and Rocky Mountain Power requesting that the Commission investigate
various Public Utility Regulatory Policies Act of 1978 ("PURPA") avoided cost rate and
contracting issues. Phase I (GNR-E-10-04) considered a PURPA qualifying facility's
("QF") eligibility for published avoided cost rates. Phase II (GNR-E-1 1-01) investigated
disaggregation and its effect on published avoided cost rates. This proceeding, Phase
Ill, was initiated on September 1, 2011, to investigate the avoided cost methodologies,
the contracting terms contained in PURPA power purchase agreements, and several
other issues related to the implementation of PURPA in the state of Idaho.
Parties to this proceeding filed direct and rebuttal testimony, submitted legal
briefs, and participated in a three-day technical hearing commenced on August 7, 2012.
The Commission issued final Order No. 32697 on December 18, 2012, which modified
published avoided cost rates established with the SAR methodology and negotiated
avoided cost rates established with an IRP methodology. The Commission also
addressed, established, and adopted several other terms for power purchase
agreements entered into between regulated utilities and PURPA QFs.
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -2
II. SAR PUBLISHED RATES
Since December 18, 2012, when the Order was issued, Idaho Power has been
reviewing the published rate calculations that are expressed in Attachment A to the
Order, and communicating with Commission Staff regarding the details to how those
rates, expressed in the Attachment, are calculated. With this Petition for Clarification
and/or Reconsideration, Idaho Power is not taking issue with how the Commission
directed that published rates be established, but is seeking clarification as to the details
of how those rates were calculated. Possibly because of the intervening Christmas and
New Year's holidays, Idaho Power has not yet been able through its inquiries with
Commission Staff to re-create the published rate calculations, nor to verify the details of
the inputs to the SAR methodology.
Idaho Power assumes that the Order directs the continued use of the previously
implemented SAR avoided cost pricing model utilized by Commission Staff to calculate
and publish rate charts, similar to those that appear in the Attachments to the Order,
each time that the published rates were previously updated upon the release of the
Northwest Power Planning Council's natural gas forecast. That model contains certain
non-fuel related SAR cost inputs for a combined cycle combustion turbine (e.g., heat
rate, capital cost, operations and maintenance, etc.) that have been set by separate
proceedings and order by the Commission. See Order No. 30738, Case No. GNR-E-
08-02. Idaho Power requests clarification that the Commission's existing SAR model,
along with its associated non-fuel cost inputs/variables, will continue to be utilized.
Additionally, with the Order, the Commission has directed that a separate
resource-specific capacity factor be used to establish resource-specific published rates.
Consequently, Idaho Power has the separate published rate charts for each utility for
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -3
wind, solar, hydro, canal drop hydro, and other QF resource types. Idaho Power
requests clarification as to what source was utilized to determine the individual resource
capacity factors, or how the individual resource capacity factors were determined.
To the extent that the SAR pricing methodology model, with verification of its
inputs and variables, is clarified to the extent that the rate calculations in Attachment A
can be reproduced by Idaho Power, the Company seeks no other
clarification/reconsideration of the SAR pricing methodology here. However, Idaho
Power hereby reserves its rights to seek further clarification, reconsideration, or hearing
to the extent that the inputs, variables, and, ultimately, the published rates cannot be
clarified to the point where the calculations are transparent and can be reproduced.
The Company believes it to be to all parties benefit to have the Commission expressly
verify upon this Petition for Clarification and/or Reconsideration the details of the SAR
published avoided cost rate model utilized by the Order to arrive at the rate charts
shown in Attachments A, B, and C.
III. § 304(f) FINDING
Idaho Power seeks clarification as to the Commission's finding on page 36 of the
Order related to its review of existing power purchase agreements:
We further find that, while each power purchase agreement
(PPA) that we have reviewed contains a general reference to
18 C.F.R. § 292.304(f), curtailment under this section was
not reasonably contemplated when the parties entered into
their agreements. The apparent need for such authority to
curtail under these circumstances has only presented itself
within the last several years in Idaho - and, as evidenced by
the testimony, seems to be a problem only on Idaho Power's
system.
Order No. 32697, p. 36.
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -4
Certainly, the parties to any PURPA power purchase agreement (the QF and the
regulated utility) contemplate that the agreement is entered into subject to the
regulations of the Federal Energy Regulatory Commission ("FERC"). To say otherwise,
is to say that the parties did not contemplate compliance with the law when they entered
into their contract. Idaho Power put forth evidence, testimony, and argument in the
proceeding that an express reference to FERC rules and regulations in any QF power
purchase agreement was not necessary for the applicability of FERC rules and
regulations to that agreement. The evidence further showed that each contract
contained a specific reference to 18 C.F.R. § 304 and its applicability to that particular
power purchase agreement. Whether or not there is a disagreement about the meaning
of § 304(f) or not is irrelevant to whether the parties contemplate, when entering into a
power purchase agreement pursuant to PURPA, that their agreement is entered into
subject to the possible application of that particular FERC regulation to it. Idaho Power
does not believe the Commission intended to state that the parties did not contemplate
compliance with the law—with FERC rules and regulation—when entering into their
respective power purchase agreements under PURPA. Perhaps the Commission
intended to state that the factual circumstances, that operational circumstances, and
conditions that exist, or may exist, today on Idaho Power's system that may invoke the
application of 18 C.F.R. § 304(f) were not contemplated by the parties when they
entered into their agreements, but certainly the parties contemplated compliance with
the federal law and regulations—whatever that may be—to those agreements.
Idaho Power asks the Commission to clarify that its finding that curtailment under
18 C.F.R. § 304(f) "was not reasonably contemplated when the parties entered into their
agreements" refers only to the factual, operation circumstances that exist today, that
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -5
may not have existed at the time of contracting, and specifically does not mean that the
parties did not contemplate the application of FERC regulations or federal law to their
PURPA contracts when entering into those agreements, including 18 C.F.R. § 304(f).
IV. NEW CONTRACTS FOR EXISTING PROJECTS
Idaho Power seeks clarification of the Commission's use in several instances,
primarily on page 21 of the Order, of the terms "contract extensions" or "renewals."
Idaho Power does not believe that the Commission actually intended to authorize any
PURPA contract to be "extended" or "renewed." None of Idaho Power's PURPA
contracts contain any provisions that allow for the extension or renewal of that particular
contract, nor for the extension or renewal of any particular rate or term that is contained
in an existing contract. Idaho Power believes that a renewal or extension of an expiring
long-term contract is contrary to the public interest. Certainly, PURPA's must purchase
obligation continues to exist for QF projects that have a contract whose term is expired,
or about to expire. However, those QF projects must enter into a new PURPA contract,
and be subject to the current avoided cost pricing and terms at the time of contracting,
not simply be able to renew the old rate and terms contained in their old contract, which
in many instances will contain extremely out-of-date prices and terms from up to 20
years ago.
Idaho Power believes the Commission's reference to "Us entering into contract
extensions or renewals" on page 21 of the Order means a reference to QF's whose
contract term has expired or is about to expire, and who desire to enter into a new
PURPA QF contract for that same QF project, with the same regulated utility. Idaho
Power seeks clarification that this was the Commission's intent, and further that the
Commission did not intend to authorize any contract extensions or renewals, where
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -6
those contracts do not provide for any renewal or extension of the term of the
agreement.
V. THE JUNE IDATE
The Order sets forth June 1 of each year as the date at which items will be
updated on an annual basis. This includes an update of the SAR published avoided
cost rates with EIA's updated natural gas forecast and update of the fuel price forecast
and load forecast utilized in the IRP methodology. Idaho Power is not aware of any
significance attached to the date of June 1 for this annual update, other than to have the
certainty that these items will be updated on a date certain on an annual basis. Idaho
Power agrees that it is important to have the certainty that these items will update on a
annual basis but asks here for clarification/reconsideration to possibly choose a different
date upon which the updates will be established and take effect.
For example, under Idaho Power's current IRP processes, the fuel price and load
forecasts are final and completed in October of each year. If the Company used the
information as of June 1, it would be out of date. If there is significance to updating on
June 1 of each year, Idaho Power may have to modify the timing by which it currently
compiles the fuel and load forecast. Additionally, Idaho Power is unaware of how the
June 1 date fits in with the existing processes at Avista Corporation and Rocky
Mountain Power for compiling those forecasts as part of their own IRP processes.
Additionally, and somewhat more significantly, is how the available data from EIA
and the timing of its release of its annual natural gas price forecast that will be utilized
by Commission Staff in its update of published rates relates to the June 1 date. Idaho
Power's information is that historically the EIA natural gas forecast has been released in
February, March, April, May, and June from year to year. Additionally, EIA typically
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -7
releases an "early bird" version of its final annual gas forecast several months in
advance. Idaho Power believes that it is extremely important that the published avoided
cost rates based upon this forecast be updated and effective immediately upon the
release of the relevant EIA gas forecast. If there is any amount of time between release
of the gas forecast and the update to published avoided cost rates, particularly when
there will be a resulting reduction in avoided cost rates as a result, there is the potential
for gamesmanship with the system whereby potential QF projects may seek to obligate
the utility and its customers to a higher rate in a long-term contract. Consequently,
Idaho Power contends that it would be more proper to update published avoided cost
rates on an annual basis immediately upon release of the specifically designated EIA
natural gas price forecast.
Therefore, Idaho Power asks for clarification/reconsideration that the published
avoided cost rates will update on an annual basis immediately upon release of the
specifically designated EIA natural gas price forecast—and that the fuel price and load
forecast inputs into the IRP methodology be allowed to be set at a different date, other
than June 1, that Commission Staff and the three regulated utilities agree will enable the
provision of the most complete and up-to-date information on an annual basis, and that
coincides with the utility's preparation of those forecasts for their IRP processes.
VI. NATURE AND EXTENT OF EVIDENCE AND ARGUMENT
TO BE OFFERED ON RECONSIDERATION
Commission Rule of Procedure 331 requires that Idaho Power state the nature
and extent of evidence or argument it will present or offer if reconsideration is granted.
Should the Commission determine that any of the requested issues for clarification are
more appropriate for reconsideration, Idaho Power believes that the evidentiary record
should be augmented :by additional legal briefing, testimony, exhibits, and hearing at the
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -8
discretion of the Commission. The Company is prepared to present additional
testimony and/or argument in support of each of the items it has identified as requiring
clarification set forth in this Petition for Clarification and/or Reconsideration.
VII. CONCLUSION
Idaho Power respectfully requests that the Commission issue an order: (1)
clarifying the methodology and inputs utilized to establish the published avoided cost
rates that appear as Attachments A, B, and C to the Order; (2) clarifying that the
Commission's finding that curtailment under 18 C.F.R. § 304(f) "was not reasonably
contemplated when the parties entered into their agreements" refers only to the factual,
operation circumstances that exist today, that may not have existed at the time of
contracting, and specifically does not mean that the parties did not contemplate the
application of FERC regulations or federal law to their PURPA contracts when entering
into those agreements, including 18 C.F.R. § 304(f); (3) the Commission did not intend
by its use of the terms "contract extensions or renewals" to authorize any PURPA QF to
renew or extend its contract; and (4) clarify/reconsider whether the June 1 date for the
update of the SAR published rates and the IRP fuel price and load forecasts is the most
appropriate date.
Respectfully submitted this 8th day of January 2013.
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8 th day of January 2013 I served a true and
correct copy of the IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION
AND/OR RECONSIDERATION upon the following named parties by the method
indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Donald L. Howell, II
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
Spokane, Washington 99202
PacifiCorp dibla Rocky Mountain Power
Daniel E. Solander
PacifiCorp d/b/a Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Exergy Development, Grand View Solar II,
J.R. Simplot, Northwest and Intermountain
Power Producers Coalition, Board of
Commissioners of Adams County, Idaho,
and Clearwater Paper Corporation
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
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Exergy Development Group of Idaho, LLC Hand Delivered
James Carkulis, Managing Member X U.S. Mail
Exergy Development Group of Idaho, LLC Overnight Mail
802 West Bannock Street, Suite 1200 FAX
Boise, Idaho 83702 X Email icarkulisexerQvdevelopment.com
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -10
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Grand View Solar II
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Springs, California 92241
J.R. Simplot Company
Don Sturtevant, Energy Director
J.R. Simplot Company
One Capital Center
999 Main Street
P.O. Box 27
Boise, Idaho 83707-0027
Northwest and Intermountain Power
Producers Coalition
Robert D. Kahn, Executive Director
Northwest and Intermountain Power
Producers Coalition
1117 Minor Avenue, Suite 300
Seattle, Washington 98101
Board of Commissioners of Adams
County, Idaho
Bill Brown, Chair
Board of Commissioners of
Adams County, Idaho
P.O. Box 48
Council, Idaho 83612
Clearwater Paper Corporation
Mary Lewallen
Clearwater Paper Corporation
601 West Riverside Avenue, Suite 1100
Spokane, Washington 99201
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IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -11
Renewable Energy Coalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Flays Street
Boise, Idaho 83702
Renewable Energy Coalition
John R. Lowe, Consultant
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Dynamis Energy, LLC
Wade Thomas, General Counsel
Dynamis Energy, LLC
776 East Riverside Drive, Suite 150
Eagle, Idaho 83616
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, Idaho 83642
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, Idaho 83706
Renewable Northwest Project, Idaho
Windfarms, LLC, and Ridgeline Energy LLC
Dean J. Miller
Chas. F. McDevitt
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, Idaho 83701
Megan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
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IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -12
Idaho Windfarms, LLC
Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, California 94611
Twin Falls Canal Company, North Side
Canal Company, Big Wood Canal
Company, and American Falls Reservoir
District No. 2
C. Thomas Arkoosh
ARKOOSH EIGUREN LLC
802 West Bannock, 9 th Floor
P.O. Box 2900
Boise, Idaho 83701
ELECTRONIC SERVICE ONLY
Donald W. Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, Washington 98660
ELECTRONIC SERVICE ONLY
Twin Falls Canal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, Idaho 83303
ELECTRONIC SERVICE ONLY
North Side Canal Company
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, Idaho 83338
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11th East
Idaho Falls, Idaho 83404
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IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION 13
Blue Ribbon Energy LLC
M.J. Humphries
Blue Ribbon Energy LLC
3470 Rich Lane
Ammon, Idaho 83406-7728
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, Idaho 83701
Snake River Alliance
Liz Woodruff, Executive Director
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Energy Integrity Project
Tauna Christensen
Energy Integrity Project
769 North 1100 East
Shelley, Idaho 83274
Idaho Wind Partners I, LLC
Deborah E. Nelson
Kelsey J. Nunez
GIVENS PURSLEY LLP
601 West Bannock Street (83702)
P.O. Box 2720
Boise, Idaho 83701-2720
Mountain Air Projects, LLC
J. Kahle Becker
The Alaska Center
1020 West Main Street, Suite 400
Boise, Idaho 83702
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IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -14
Michael J. Uda
UDA LAW FIRM, P.C.
7 West 6th Avenue, Suite 4E
Helena, Montana 59601
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0
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QL(L
Christa Bearry, Legal Assistant Cj
IDAHO POWER COMPANY'S PETITION FOR CLARIFICATION AND/OR RECONSIDERATION -15