HomeMy WebLinkAbout20131213Workshop Comments.pdf^llml0Npggl6p=
i , l; I ' An lDAcoRP company
?ili: llill l: Pil tr: 3l+
JULIAA. HILTONCorporateCounset i-'';
ihilton@idahopower.com .j'i.;'-i iij:'-; .'1' '' 'r 'i''
December 13,2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, ldaho 83702
Re: Case No. GNR-E-11-03
PURPASAR and IRP Methodologies - Idaho Power Company's Workshop
Comments
Dear Ms. Jewell:
Enclosed forfiling in the above matter are an original and seven (7) copies of ldaho
Power Company's Workshop Comments.
Very truly yours,#ffi
JAH:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
8oise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
JULIA A. HILTON (lSB No. 7740\
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: (208) 388-5317
Facsimile: (208) 388-6936
dwalker@idahopower.com
ih ilton@ idahopower. com
Attorneys for ldaho Power Company
IN THE MATTER OF THE COMMISSION'S
REVIEW OF PURPA QF CONTRACT
PROVISIONS INCLUDING THE
SURROGATE AVOIDED RESOURCE
(SAR) AND INTEGRATED RESOURCE
PLANNTNG (rRP) METHODOLOGIES FOR
CALCULATING AVOIDED COST RATES.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR-E-11-03
IDAHO POWER COMPANY'S
WORKSHOP COMMENTS
ldaho Power Company ("ldaho Powe/' or "Company") hereby respectfully
submits to the ldaho Public Utilities Commission ("Commission") its comments on the
Public Utility Regulatory Policies Act of 1978 ('PURPA') contracting procedures
workshops ("Comments").
I. INTRODUCTION
On December 18, 2012, the Commission issued Order No. 32697 in the above-
captioned case. In that Order, the Commission directed the parties to participate in
workshops "to begin to form a structure for fair and reasonable contracting procedures
IDAHO POWER COMPANY'S WORKSHOP COMMENTS - 1
and rules" and submit a proposal for approval of such terms to the Commission by
December 13,2013. ld.
Several parties to the case participated in workshops on September 17, 2013,
and November 14, 2013, to discuss PURPA contracting procedures. Following the
September workshop, the utilities agreed to draft a proposal for qualifying facilities
('QF") to evaluate prior to the November workshop. Due to differences between the
utilities, the three utilities were not able to agree upon a single proposal. ldaho Power
brought its own draft tariff to the November workshop while Avista and PacifiCorp
brought a single draft tariff that contained some common sections and carved out
sections with language proposed by each utility.
At the November 14 workshop, the parties who were present agreed to certain
limited concepts regarding timing of responses between utilities and QFs and
information provided by a QF prior to receiving indicative pricing and/or draft energy
sales agreements. However, parties did not agree to actual language reflecting such
terms, and several parties sought additional inclusions and omissions that were not
agreed upon. Following the workshop, PacifiCorp drafted a tariff aimed at incorporating
the agreed-upon timelines and information, which was provided to all parties on
December 4,2013 (the "PacifiCorp Draft"). The PacifiCorp Draft appears to be accurate
in those timelines and lists of information discussed in the workshop, but it is not agreed
upon by all parties.
ldaho Power files these Comments in order to describe the limited nature of
agreement, to mention areas of concern and disagreement with the PacifiCorp Draft,
and to raise issues that are necessary to resolve before implementing a PURPA
IDAHO POWER COMPANY'S WORKSHOP COMMENTS - 2
contracting process document. ldaho Power includes, as Attachment 1 to these
Comments, a redlined draft of the extensive changes that the Company believes are
necessary before a contract process document is implemented.
!I. LIMITED AREAS OF AGREEMENT
The parties agreed in concept to some timelines and information to be
exchanged between utilities and QFs. Parties agreed that certain information was
required by each utility prior to providing a QF with pricing information, draft energy
sales agreements, and fina! energy sales agreements. The agreed-upon lists of
information are contained in Sections lll(1), lV(1), and lV(3) of the PacifiCorp Draft and
Sections l(B)(1), I(CX1), and l(CX3) of ldaho Power's draft. While ldaho Power agrees
to these lists of information, some QFs questioned the need to include language that the
proposed draft tariff only applies to sales where a QF connects directly with a utility.
ldaho Power would have different requirements for the provision of required information
in these sections if the process document were to also apply to off-system sales.
The parties also agreed to timelines where a utility will notify parties of
incomplete information within 5 business days, provide pricing information and draft
energy sales agreements within 20 business days of receiving all necessary
information, and provide final, executable energy sales agreements 10 business days
after parties are in full agreement on the terms of the energy sales agreement. These
timelines can be found in Sections ll, lll(2), lV(2), V(4), and V(3) of the PacifiCorp Draft
and Sections l(A), I(BX2), l(CX2), l(CX4), and l(D)(3) of ldaho Power's draft.
The parties agreed to timelines and procedures for negotiations. These timelines
include a requirement that a QF must respond to draft energy sales agreements within
IDAHO POWER COMPANY'S WORKSHOP COMMENTS.3
90 calendar days of its receipt and execute a final energy sales agreement within 10
business days of its receipt. lf a QF does not meet these timelines, the process outlined
in the process document would begin again. These timelines and procedures can be
found in Sections V(1) and V(3) of the PacifiCorp Draft and Sections l(D)(1) and l(DX3)
of ldaho Power's draft. Please note that because the parties did not all agree to the
language in the PacifiCorp Draft, Idaho Power's Section l(DX3) contains an important
clarification that the timelines applicable to the utility and the QF are based upon the
other party's receipt of the document.
III. IDAHO POWER'S PROPOSED PURPA CONTRACTING PROCEDURES
The parties did not agree to other important items such as language on the non-
binding nature of draft contracts and reference to other processes required for a QF to
deliver energy to ldaho Power.
ldaho Power believes that, especially in light of current cases, language
describing the non-binding nature of a draft contract is necessary to include in a
document describing PURPA contracting procedures. ldaho Power believes that
without such language specifically describing the intent of a draft, the QF community will
use draft contracts to attempt to create a legally enforceable obligation in a manner that
is not consistent with Commission orders. ldaho Power will not agree to a tariff that
does not include such language, and QFs have stated that they will not agree to a tariff
that includes it.
Additionally, it is necessary for an ldaho Power contracting process document to
include, at a minimum, a reference to the generation interconnection and designated
network resource processes in order to put QFs on notice that these paralle! tracks exist
IDAHO POWER COMPANY'S WORKSHOP COMMENTS.4
and are required prior to a QF's interconnection and The referenced
generation interconnection and designated network resource processes are procedures
that are required to comply with Idaho Power's Schedule 72 and other Federal Energy
Regulatory Commission regulations.
IV. CONCLUSION
While the workshops were helpful and some progress was made toward
developing a contracting process document, it is apparent that the parties do not agree
to one unified document. There are some aspects that would necessitate each utility to
complete its own utility-specific contracting procedures, and some issues that the
utilities and QF representatives do not, and likely will not, agree upon. ldaho Power
believes that if a process document for PURPA contracting procedures is to be
implemented, it is important that, at a minimum, information about the non-binding
nature of draft energy sales agreements be included, as well as information regarding
the interconnection and designated network resource requirements.
Respectfully submitted this 13th day of Decemb er 2013.
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S WORKSHOP COMMENTS - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of December 2013 | served a true and
correct copy of IDAHO POWER COMPANY'S WORKSHOP COMMENTS upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Avista Corporation
Michael G. Andrea
Avista Corporation
1411 East Mission Avenue, MSC-23
Spokane, Washingto n 99202
Pacificorp d/b/a Rocky Mountain Power
Daniel E. Solander
PacifiCorp dlbla 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 lntermountain
Power Producers Coalition, Board of
Gommissioners of Adams County, ldaho,
and Glearwater Paper Corporation
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Exergy Development Group of ldaho, LLG
James Carkulis, Managing Member
Exergy Development Group of ldaho, LLC
802 West Bannock Street, Suite 1200
Boise, ldaho 83702
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Email michael.andrea@avistacorp.com
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Email daniel.solander@pacificorp.com
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Emai! peter@richardsonadams.com
q reo@ richa rd sonad ams. co m
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Email icarkulis@exerqvdevelopment.com
IDAHO POWER COMPANY'S WORKSHOP COMMENTS.6
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
Grand View Solar ll
Robert A. Paul
Grand View Solar ll
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. Box27
Boise, ldaho 83707 -0027
Northwest and Intermountain Power
Producers Coalition
Robert D. Kahn, Executive Director
Northwest and !ntermountain Power
Producers Coalition
1 1 17 Minor Avenue, Suite 300
Seattle, Washington 981 01
Board of Commissioners of Adams
Gounty, ldaho
Bi!! Brown, Chair
Board of Commissioners of
Adams County, ldaho
P.O. Box 48
Council, ldaho 83612
Glearuvater Paper Corporation
Marv Lewallen
Cleanruater Paper Corporation
601 West Riverside Avenue, Suite 1 100
Spokane, Washington 99201
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_FAXX Email dreadinq@mindsprinq.com
d r@beniohnsonassociates. com
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IDAHO POWER COMPANY'S WORKSHOP COMMENTS - 7
Renewable Energy Goalition and Dynamis
Energy, LLC
Ronald L. Williams
WILLIAMS BRADBURY, P.C.
1015 West Hays Street
Boise, ldaho 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, ldaho 83616
Interconnect Solar Development, LLC
R. Greg Ferney
MIMURA LAW OFFICES, PLLC
2176 East Franklin Road, Suite 120
Meridian, ldaho 83642
Bill Piske, Manager
Interconnect Solar Development, LLC
1303 East Carter
Boise, ldaho 83706
Renewable Northwest Project, ldaho
Windfarms, LLC, and Ridgeline Energy LLG
Dean J. Miller
Chas. F. McDevitt
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, ldaho 83701
Megan Walseth Decker
Senior Staff Counsel
Renewable Northwest Project
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
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_FAXX Email ioe@mcdevitt-miller.com
chas@mcdevitt-m i I ler. co m
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Email meoan@rnp.orq
IDAHO POWER COMPANY'S WORKSHOP COMMENTS - 8
ldaho Windfarms, LLC
Glenn lkemoto
Margaret Rueger
ldaho Windfarms, LLC
672Blair Avenue
Piedmont, California 9461 1
Twin Falls Canal Company, North Side
Canal Company, Big Wood Canal
Company, and American Falls Reservoir
District No.2
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ELECTRONIC SERVICE ONLY
Donald W. Schoenbeck
RCS, lnc.
900 Washington Street, Suite 780
Vancouver, Washington 98660
ELECTRONIC SERVICE ON LY
Twin Falls Ganal Company
Brian Olmstead, General Manager
Twin Falls Canal Company
P.O. Box 326
Twin Falls, ldaho 83303
ELECTRONIC SERVICE ON LY
North Side Canal Gompany
Ted Diehl, General Manager
North Side Canal Company
921 North Lincoln Street
Jerome, ldaho 83338
Birch Power Company
Ted S. Sorenson, P.E.
Birch Power Company
5203 South 11th East
Idaho Falls, ldaho 83404
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FAXX Email qlenni@envisionwind.com
ma rqa ret@envisio nwi nd. co m
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FAXX Email tom.arkoosh@arkoosh.com
eri n. ceci I @arkoosh. com
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IDAHO POWER COMPANY'S WORKSHOP COMMENTS - 9
Blue Ribbon Energy LLC
M. J. Humphries
Blue Ribbon Energy LLC
3470 Rich Lane
Ammon, ldaho 83406-7728
Arron F. Jepson
Blue Ribbon Energy LLC
10660 South 540 East
Sandy, Utah 84070
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, ldaho 83701
Snake River Alliance
Liz Woodruff, Executive Director
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
Energy lntegrity Project
Tauna Christensen
Energy lntegrity Project
769 North 1 100 East
Shelley, ldaho 83274
ldaho Wind Partners !, LLC
Deborah E. Nelson
Kelsey J. Nunez
GIVENS PURSLEY LLP
601 West Bannock Street (83702)
P.O. Box 2720
Boise, ldaho 83701 -2720
Mountain Air Projects, LLC
J. Kahle Becker
The Alaska Center
1020 West Main Street, Suite 400
Boise, ldaho 83702
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Email arronesq@aol.com
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Email lwood ruff@snakeriveralliance.orq
km i I ler@snakeriveral I ia nce. o rq
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_FAXX Email tauna@enerqvinteqrityproiect.orq
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-FAXX Email den@qivenspurslev.com
kin@oivenspurslev.com
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IDAHO POWER COMPANY'S WORKSHOP COMMENTS - 1O
MichaelJ. Uda
UDA LAYT/ FIRM, P.C.
7 West 6h Avenue, Suite 4E
Helena, Montana 59601
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_FAXX Email muda@mthelena.com
IDAHO POWER COMPANYS WORKSHOP COMMENTS . 11
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR.E-I 1.03
IDAHO POWER COMPANY
ATTACHMENT 1
SCHEDULE 73
ENERGY SALES AGREEMENT PROCEDURES
FOR QUALIFYING FACILITIES
STATE OF IDAHO
ies
AVAILABILITY
Service under this schedule is available to Owners of Qualifvinq Facilities (QF) throuohout the
Companv's service area within the State of ldaho.
APPLlCABILIry
ToownersofexistingorpropoSeo@$r+}whodesiretomakeenerqV
sales to fU+iti+Vllhe Sgpeny under the Public Utility Regulatory Policy Act of 1978 at published or
neootiated avoided cost rates, and will deliver the output of such QFs at a point of delivery on
tU+ti+Vllleho_Powel's electrical system that is located in the State of ldaho. Owners shall enter into awrittenagreementwith@pursuanttotheprocedures
set forth below. Additional or different requirements may apply to ldaho QFs seeking to make sales to
third-_parties or out-of-system QFs seeking to wheel power to ldaho for sale to fUtili+y].lSlAho Powef.
I. ENERGY SALES AGREEMENTS
l{- A. Communications
Unless otherwise directed bV tutitityllhe_Cgp3ny, all communications shall be
directed in writing, by mail or email, as follows:
@ldaho PowerCompany
ATTN: Coqeneration and Small Power Production
1221 West ldaho Street
Boise. ldaho 83702
IEMAILI
Where tU+t++Vllhe Sompeny is unable to respond on the basis of incomplete or
missing information from the Owner, tU+tityilhe rcompanV shall, within five (5)
business days, notify the Owner in writing that additional information is required
and identify what additional information is required. Thereafter, [Utility]lhe
Companv shall respond in a timely manner following receipt of all required
information as more fully described below.
€e*inueO)B. Procedures for Obtainino lndicative Pricino and a Draft Perve+Purehase-Enerqv
Sales Aoreement: Standard QFs (Published Rates)
1. To obtain an indicative pricing proposal and a draft pewer-purehase
enerov sales agreement with respect to a proposed Project, the Owner
1
shallprovideto@allgenera!informationregardingthe
Project that is reasonably required for @ to determine
the applicable published rate and to draft ap @
sales agreement. A Project is defined as an existing or proposed QF that
can satisff the applicability requirements of this Schedule -73. General
information regarding a Project shall include, but not be limited to:
1
SCHEDULE 73
ENERGY SALES AGREEMENT PROCEDURES
FOR QUALIFYING FACILITIES
(Continued)
l. ENERGY SALES AGREEMENTS (Continued)
B. Procedures for Obtainino lndicative Pricinq and a Draft Power+ur€ha€e-Enerov
Sales Aoreement: Standard QFs (Published Rates) (Continued)
a) plroject eQwner and contact information;
b) generation and other related technology applicable to the site;
c) design capacity, station service requirements, and the net amount of
power, all in kilowatts (kW), to be delivered to [Utitity]lhe._9@e_ny's
electric system;
d) schedule of estimated power deliveries, in sufficient detail to
determine and to calculate the applicable price;
e)ability,ifany,torespondtodispatchordersfrom@;
0 map of site location, electrical interconnection point, and point of
delivery;g) anticipated commencement date for power deliveries;
h) list of acquired and outstanding Project permits, including a
description of the status and timeline for acquisition of any
outstanding permits;i) demonstration of ability to obtain QF status;j) fuel type(s) and source(s);
k) plans to obtain, or actual, fuel and transportation agreements, if
applicable;l) plans to obtain electricity transmission agreements; (required for any
Project that interconnects electrically with the electrical system other
than @'s electrical system);
m) proposed contract term and proposed pricing structure (levelized price
or non-levelized price);
n) evidence of ability to obtain site control for the entire term of the
power sale;
o) assurance of fuel supply or motive force;p) anticipated timelines for completion of key Project milestones; andq) adequate assurance that plroject interconnection is to occur on or
prior to the requested first delivery date.
2. Following satisfactory receipt of all information required in Paragraph 1,
tU+it+tyilhe Compely shall, within twentv (20) business days, provide the
Owner with an indicative pricing proposal and draft pewe+-pu+enase
enerqv sales agreement containing terms and conditions tailored to the
individual characteristics of the proposed Project. The indicative draft
enerqv sales aqreement will not be final or bindino on either partv. Prices
and other terms and conditions will be final and bindinq onlv upon the
ldaho Public Utilities Commission approval of a fullv executed enerov
sales aqreement.
€en+inueA)
2
SCHEDULE 73
ENERGY SALES AGREEMENT PROCEDURES
FOR QUALIFYING FACILITIES
(Continued)
EtECTRIC SERVICE SCHEDUTE Ne- CentinueC
ENERGY SALES AGREEMENTS (Continued)
C. Procedures for Obtainino lndicative Pricino and a Draft PewerPurehaseEnerqv
Sales -Aoreement: Non-Standard QFs
1. To obtain an indicative pricing proposal with respect to a proposed
Project, the Owner shall provide to ftlt+lity]lhe JamEty all general
information regarding the Project that is reasonably required for ftltili$llhe
Companv to calculate the avoided cost price. A Project is defined as an
existing or proposed QF that can satisfy the applicability requirements of
this Schedule -73. General information regarding a Project shall include,
but not be limited to:
a) pProject eQwner and contact information;
b) generation and other related technology applicable to the site;
c) design capacity, station service requirements, and the net amount of
power, all in kilowatts (kW), to be delivered to [Utiffilhe tQompany's
electric system;
d) schedule of estimated power deliveries, in sufficient detail to
determine and to calculate the applicable price;
e) ability, if any, to respond to dispatch orders from [Utility]lhe-.lCornpgqy;0 map of site location, electrical interconnection point, and point of
delivery;
anticipated commencement date for power deliveries;
list of acquired and outstanding Project permits, including a
description of the status and timeline for acquisition of any
outstanding permits;
demonstration of ability to obtain QF status;
fuel type(s) and source(s);
plans to obtain, or actual, fuel and transportation agreements, if
applicable;l) plans to obtain electricity transmission agreements, (required for any
Project that interconnects electrically with the electrical system other
than fUti{ity}lhe tQg4pgly's electrica I system ); and
m) proposed contract term and proposed pricing structure (levelized price
or non-levelized price).
2. Following satisfactory receipt of all information required in Paragraph 1,
[U+titV[hC Sompely shall, within twentv (20) business days, provide the
Owner with an indicative pricing proposal tailored to the individual
characteristics of the proposed Project. The indicative pricinq proposal
will not be final or bindino on either partv. Prices and other terms and
conditions will be final and bindino onlv upon the ldaho Public Utilities
Commission approval of a fullv executed enerov sales aqreement.
€en+inuee)
s)
h)
i)
i)
k)
SCHEDULE 73
ENERGY SALES AGREEMENT PROCEDURES
FOR QUALIFYING FACILITIES
(Continued)
l. ENERGY SALES AGREEMENTS (Continued)
C. Procedures for Obtainino Indicative Pricinq and a Draft Enerov Sales Aqreement:
Non-Standard QFs (Continued)
3. !f the Owner desires to proceed with the Project after reviewing ftJ+ili+y]lhe
Companv's indicative pricing proposal, it shall request in writing that
tU+tityl!f;g Jom@y prepare a draft
agreement to serve as the basis for negotiations between the parties. ln
connection with such request, the Owner shall provide tU+iti+Vfihe
Companv with any additional Project information that [U+ilftg1ne Cr*r*
reasonably determines to be necessary for the preparation of a draft
@ agreement, which includes, but shall not be
limited to:
any additional information that was requested in tu{il+ty}the
Company's indicative pricing proposal;
updated information of the categories described in Section lVQ.
Paragraph 1;
c) evidence of ability to obtain site control for the entire term of the
power sale;d) assurance of fuel supply or motive force;
e) anticipated timelines for completion of key Project milestones; and
0 adequate assurance that plroject interconnection is to occur on or
prior to the requested first delivery date.
4. Once the Owner has satisfied the requirement to provide all requested
information, fUt+lity]lhe JqpanV shall, within twentv (20) business days,
provide the Owner with a draft agreement
containing a comprehensive set of proposed terms and conditions. Such
draft shall serve as the basis for subsequent negotiations between the
parties and. unless clearlv indicated. shall not be construed as a bindinq
proposal bv the Companv. Prices and other terms and conditions will be
final and bindinq onlv upon the ldaho Public Utilities Commission
approval of a fullv executed enerov sales aoreement.
D. Procedures for Neootiatino an PewerPn+ehaseEnerqv Sales Aoreement: All QFs
1. After reviewing the draft agreement, the
Owner shal{ngy prepare an initial set of written comments and proposals
regarding the draft agreement and shall
provide such comments and proposals, or notice that it has none, to
tU+ti+V]!he rcompeny tU+ti+Vflhe Jomgty shall not be obligated to
commence negotiations with an Owner until {Uti{ityfll has received an
initial set of written comments and proposals from the Owner, or notice
a)
b)
4
from the Owner that it has no such comments or proposals. Following
tU+ti$[hglgrngly's receipt of such comments and proposals from the
Owner, or notice from the Owner that it has no such comments or
proposals, the Owner shall contact [tltili*]lhelerngly to schedule
contract
€en+inuea)
negotiations
SCHEDULE 73
ENERGY SALES AGREEMENT PROCEDURES
FOR QUALIFYING FACILITIES
(Continued)
l. ENERGY SALES AGREEMENTS (Continued)
D. Procedures for Neqotiatino an Enerov Sales Aqreement: All QFs (Continued)
such times and places as are mutually agreeable to the parties. lf fu{ili+y}tne
Companv has not received written comments and proposals from the Owner, or
notice from the Owner that it has no such comments or proposals, within ninetv
(90) calendar days of the receipt of a draft
agreement from {Utility}lhe tCompany, fUtility]lhC Jq-panV shall have no further
obligation to such Owner under this tariff unless or until such time Owner
resubmits the Project to fUtility]lhe tQgApgly in accordance with this sSchedule
73.
ln connection with any contract negotiations between fut+lity]lhe Ce11pgly
and the Owner, futility]thg tompely:
a) shall not unreasonably delay negotiations and shall respond in good
faith to any additions, deletionsr or modifications to the draft pewer
@ agreement that are proposed by the Owner;
b) may request to visit the site of the proposed Projectif+ueh-a-visitSas
@;c) shall update its pricing proposals at appropriate intervals to
accommodate any changes to {U+i{ity}!he tQgapggy's avoided-_cost
calculations, the proposed Project, or proposed terms of the draft
@agreement;d) may request any additional information from the Owner necessary to
finalize the terms of the @ agreement and
satisfy tUt+t++Vilhelg4pany's due diligence with respect to the Project.
When both parties are in full agreement as to all terms and conditions of
the draft agreement, fUtili{y}lhg Jq.pany
shall prepare and forward to the Owner, within ten (10) business days, a
final, executable version of the @ agreement.
Within ten (10) business davs of receipt of the final. executable version.
Owner shall sign and fonuard to {U+ility}lhe tQg4pany w*nin-+en--(+g)
Uusiness-aap-a fully executed version of the @sales agreement. lf the fully executed version of the power
@ agreement is not @
tU+tityilhe Jgrngly within ten (10) business days, @
obligations under this Schedule -73 shall be deemed complete and
Owner must initiate a new request under Section l#E or Section lVe. The
timelines in this section may be modified by mutual consent of the parties.
2.
3.
v+.!.l. pRocESS FoR NEGOTTATTNG TNTERCONNECTTON AGREEMENTS
lnadditiontonegotiatingan@agreement,QFsintendingto
of ldaho must enter into an interconnection agreement governing the physical
interconnection of the Project to [t+ili*]!he-.lQ9moa!y or a€c--[hi4[party's electrica!
system pursuant to the Companv's Schedule 72 (lnterconnections to Non-Utilitv
Generation). jUtili$].Ihe Co1ppgly's obligation to purchase from a QF will be
conditioned on the consummation of all necessary interconnection arrangements
'
5
SCHEDULE 73
ENERGY SALES AGREEMENT PROCEDURES
FOR QUALI FY]NG FACILITI ES
(Continued)
ll. PROCESS FOR NEGOTIATING INTERCONNECTION AGREEMENTS (Continued)
It is recommended that the Owner initiate its request for interconnection as earlv in the
plannino process as oossible to ensure that necessarv interconnection arranoements
and understandino of potential costs and schedules oroceed on a oarallel track with
neootiation of the enerov sales aqreement.
Please refer to the Companv's Schedule 72 (lnterconnection to Non-Utilitv Generation)
for procedures and contact information.
I!I. DESIGNATION AS A NETWORK RESOURCE
ln addition to comoletion of an enerqv sales aoreement and a interconnection
aoreement. the QF Owner is also responsible for all network transmission modifications
or uporades reouired to enable the QF Proiect's enerov to be delivered to a point on
ldaho Power's electrical svstem that enables the QF Proiect's enerov to be consumed by
ldaho Power customers and to be classified as a Companv Desionated Network
Resource (DNR).
A. Communications
lnitial communications reqardino the Desionated Network Resource process
should be directed to the Companv in writinq as follows:
ldaho Power Companv
ATTN: Cooeneration and Small Power Production
B. Procedures
The Companv shall provide the Owner with a transmission capacitv
questionnaire. Onlv after the Owner has provided (1) an accurate and complete
questionnaire. (2) evidence that the proposed Proiect Owner has filed an
application for interconnection and (3) made substantial proqress in
understanding and neqotiatinq an eneroy sales aoreement shall the Companv
submit a Transmission Service Request (TSR) to the Companv's transmission
business unit. The most efficient processino of the TSR is to simultaneouslv
process this request with the interconnection aoplication: therefore it is
recommended that the Owner complete the necessarv requirements to enable
this to occur.
Results of the network transmission studies initiated bv the TSR will be
communicated to the Owner in a timelv manner and will be included in the finalGlA. Upon successfu! comoletion of the GIA requirements includino any
Companv network transmission modifications or additions. and the first enerov
0
date requirements within the enerqv sales aqreement. the Proiect will be elioible
to receive ldaho Power DNR status.