20130108Petition for Clarification.pdf

Williams • Bradbury
A T T 0 R N E Y S A T L A
4 ;.j4-8 p3O
Iss IQ, January 8, 2013
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Re: GNR-E-11-03
Dear Ms. Jewell:
Please find enclosed an original and seven copies of the following for filing in the
above referenced case:
1.Petition of the Renewable Energy Coalition for Clarification of Order No. 32697;
2.Affidavit of John Lowe on behalf of Renewable Energy Coalition; and
3.Certificate of Delivery.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Si erely, Si

Ronald L. Williams
RLW/jr
Enclosures
1015 W. Hays Street - Boise, ID 83702
Phone: [phone] - Fax: [phone] - www.williamsbradbury.com
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
ronwilliamsbradbury.com
ZtIBJAH-8 PM 3:09
Attorneys for Renewable Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITES 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 '
PETITION OF THE RENEWABLE
ENERGY COALITION FOR
CLARIFICATION OF ORDER NO.
32697
COMES NOW the Renewable Energy Coalition ("REC") and pursuant to Idaho Code
§61-626 and Idaho Administrative Procedures Act §31.01.01.331, petitions the Commission for
Clarification of Attachment A to Order No. 32697 as to applicability of published rates for
existing QF projects and clarification of the "Note" concerning the definitional of a "canal drop
hydro project."
PETITION FOR CLARIFICATION
OF ATTACHMENT A RATE SCHEDULES
A. Published Rates for Existing Projects
Order No. 32697 determines that new qualifying facilities should "not receive
compensation for capacity until the utility is capacity deficit." However, the Order also
determines that existing "QFs entering into contract extensions or renewals [] be paid capacity
1 Order No. 32697, Case No. GNR-E-1 1-03, p. 52.
Petition of the Renewable Energy Coalition for Clarification of Order No. 32697, Page 1
for the full term of the extension or renewal."2 Attachment A to Order No. 32697 shows the
avoided cost rates for all three utilities, for a variety of different QF resources types, but only for
new QFs.
Idaho REC members have existing QF contracts with either Idaho Power or PacifiCorp
which will be expiring in the next several years. The Attachment A published avoided cost rates
do not reflect either the levelized or non-levelized rates that would apply to existing QFs seeking
to renew or extend their QF contracts with the respective utilities.
REC seeks clarification as to the published avoided cost rates for QFs that have existing
contracts that will be expiring with Idaho Power and PacifiCorp. REC believes this clarification
could be accomplished by providing a separate Attachment, similar to Attachment A, showing
published rates for existing QFs seeking a contract renewal or extension, and which would
include capacity payments in the initial years of capacity sufficiency. The schedule should also
clearly state is it only available for projects that have existing/prior QF contracts with the
respective utility.
B. Definition of Canal Drop Hydro Project
The first "Note" on the Attachment A published rate schedule for Canal Drop Hydro
Projects defines a canal drop hydro project "as a generation facility which produces a majority of
its generation during the irrigation season and is located on a man-made waterway that conveys
water primarily intended for irrigation or that primarily conveys irrigation return flows."' REC
respectfully requests the Commission further clarify this definition, for the reason discussed
below.
at p.22
Id.
Petition of the Renewable Energy Coalition for Clarification of Order No. 32697, Page 2
First, REC does not believe that there is any definition contained in the record or offered
by any party in this case, as to what is should be the proper definition of a "canal project," an
"irrigation related project" or a "canal drop project." Consequently, REC offers the attached
affidavit of John Lowe, Executive Director of REC, as evidence of what could or should be
considered in developing a definition for such an "irrigation related hydro project."
Second, REC agrees with the first part of this definition of an irrigation or a canal project
- that the majority of the generation occur during the irrigation season - for the reason that this
generation season more closely matches the system peaks for Idaho Power and PacifiCorp and is
the reason that the avoided cost rates for this type of hydro project are enhanced. In essence,
REC believes that this is the core of the definition, and may, by itself, be all that is needed.
Finally, the requirement that a "canal drop hydro project" must meet a physical
requirement that water be conveyed through or over "a man-made waterway" does not have any
meaningful correlation to the timing of when the power is produced, and the value of the power.
Instead, this requirement could bar some hydroelectric projects from qualifying under this rate
schedule, even though they utilize stored and conveyed water intended for irrigation.
The Malad River, the Little Wood River and Rock Creek in south central Idaho are three
examples of how irrigation based hydro generation occurs without the use of irrigation canals.
For example, the hydroelectric facility at the Magic Reservoir Dam, at the head of the Malad
River (or the end of the Wood River), is not a man-made waterway, but instead is an irrigation
impoundment and storage facility. Likewise, several small hydro facilities located on the Malad
River below Magic, or on the Little Wood River above Magic, are 80% or more irrigation
related, but are not located on irrigation canals. Similarly, a vast majority of the annual flow in
Rock Creek to the south of the Snake River, on which there is a hydroelectric facility, is
Petition of the Renewable Energy Coalition for Clarification of Order No. 32697, Page 3
primarily irrigation return water. However, there is no irrigation canal at Rock Creek. While
these facilities have generation profiles that are no different than a hydro facility located on a
canal, they could arguably be described as run-of-river hydro facilities.
For the reasons outlined above, REC requests that the definition in the first Note to the
Attachment A for Canal Drop Hydro Projects be clarified, by restating is something similar to
the following:
An "canal drop irri2ation related hydro project" is defined as a generation
facility which produces a majority of its generation during the irrigation season
and is located on a man made waterway that conveys or impounds water
primarily intended for irrigation or that primarily conveys irrigation return
flows.
As Mr. Lowe also recommends in his affidavit, the name or title of this particular
schedule could also be changed by substituting the words "irrigation related" for the words
"canal drop," or other words to the same effect, so as to avoid the possibility that this
schedule not be interpreted as to require that a project must be located on a canal drop, in
order to qualify for this avoided cost rate.
RESPECFULLY SUBMITTED this day of January, 2013.
WILLIAMS BRADBURY, P.C. z ol~~—
Ronald L. Williams
Attorney for the Renewable Energy Coalition
Petition of the Renewable Energy Coalition for Clarification of Order No. 32697, Page 4
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W.. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
ron®williamsbradbury.com
201JAN-8 PM 3: 10
MMIS it _i
Attorneys for Renewable Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE COMMISSION'S) Case No. GNR-E-1 1-03
REVIEW OF PURPA QF CONTRACT )
PROVISIONS INCLUDING THE ) AFFIDAVIT OF JOHN LOWE ON
SURROGATE AVOIDED RESOURCE (SAR)) BEHALF OF THE RENEWABLE
AND INTEGRATED RESOURCE ) ENERGY COALITION
PLANNING (1RP) METHODOLOGIES FOR )
CALCULATING AVOIDED COST RATES )
STATE OF Oregon )
:ss.
County of Washington )
I, John Lowe, do declare the following and if called to testify, would and could testify as
follows:
1.I am the Executive Director of the Renewable Energy Coalition ("REC"), based
in Portland Oregon. The address of REC is 12050 SW Tremont St., Portland OR,, 97225.
2.REC consists of more than 35 existing and several proposed non-intermittent
renewable energy projects located in Idaho, Washington, Oregon, Wyoming and Utah. There are
13 REC members with 20 existing projects located in Idaho, which currently have QF contracts
with either PacifiCorp or Idaho Power. All existing and proposed projects by REC members in
Idaho are small hydro. The names of the existing projects and/or their owners and the project
size are shown on Attachment 1 to this Affidavit.
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3. I have reviewed Order No. 32697 and Attachment A establishing avoided cost
rates for "canal drop hydro projects." I also have reviewed the first "Note" to this avoided cost
rate schedule and the definition for a "canal drop hydra project" I am concerned that the
definition as written may not clearly and accurately express the intent of the applicability of the
avoided cost rate schedule, thus leading to unnecessary confusion. The most effective and
uncontroversial interpretation of what constitutes a "canal drop hydro project' would be a
definition exclusively based upon a majority of the project production occurring during the
months of the irrigation season. Any further definition or criteria for application of the "canal
drop hydra project" avoided cost rate schedule should be limited to the use of water for such
project generation that has been used upstream (return flows) or will be used downstream for
irrigation purposes. Any reference to man-made waterways should be eliminated from the
definition, since virtually every hydra project utilizes some form of man-made waterway, i.e.
canal, pipelines, penstocks, afterbays, etc. and the use of such man-made waterway criteria as
part of any definition becomes the focus of potential controversy and misinterpretation of the
avoided cost rate schedule. In addition, re-naming the avoided cost rate schedule to "irrigation
season hydro" or something similar would more accurately reflect its intended application.
4. It is my understanding that "canal drop hydro project" avoided cost rates are
higher than other hydra projects since such projects produce a majority of their energy and
capacity during the periods of highest utility need and demand for PaciflCorp and Idaho Power
Company. The months of the irrigation season in Idaho have a close match to the peak needs of
these two utilities Completely unrelated to the value of generation to these utilities provided by
"canal drop hydro projects" is whether or not such generation occurred as a result of the type of
structure that conveys the water flows before, during or after generation, In addition, where the
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water flows originated from, is moving to, or where is goes and for what purpose before and
after generation, has no relationship to the value of such generation by the purchasing utility.
5.There are numerous REC members' projects delivering or planning to deliver
generation output to PaciflCorp and Idaho Power Company that could be impacted by the
potential misinterpretation of the application of the "canal drop hydro project" avoided cost rate
schedule, as the definition of such is currently written. I do not believe it is the Commission's
intent to disallow the application of such "canal drop hydro project" avoided cost rate schedule
to such projects that produce the majority of their output during the irrigation season and utilize
or convey irrigation water flows used or to be used downstream, when such projects are not
precisely configured or located as a drop in an irrigation canal. Several examples of projects
which could be impacted by an unintended limiting interpretation of the currently written "canal
drop hydro project" definition are discussed below.
6.The Shoshone Hydroelectric Project complex, located directly on the Little Wood
River, totals 975 kW. This complex, which is not located on a canal, is comprised of two
projects of similar characteristics, each with the output purchased under separate contracts with
Idaho Power. However, over 80 percent of the water passing through this facility on an annual
basis does so during the irrigation season and is irrigation water conveyed to the Little Wood
River via the Gooding-Milner canal. The remaining 20 percent of the water flow is natural to the
Little Wood River. In essence, the Little Wood River is used during the irrigation season as if it
was an irrigation canal.
7.The Little Wood River Hydro complex', also consisting of two projects, is located
just downstream from the Shoshone Hydroelectric Project complex. This second complex is also
not canal based, but over 80 percent of the water for these two projects comes to the Little Wood
'Little Wood River Ranch Hydroelectric Projects I and II, owned by the Arkoosh ftmlly.
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River during the irrigation season. After passing through the two hydro complexes on the Little
Wood River, the irrigation water is diverted back out of the Little Wood to the South Gooding
Math Canal.
8.The Ravenscroft Hydroelectric Project is located directly on the Malad River and
not on a canal, with a rated capacity of 1. 15 MW Approximately 902 percent of the generation
from this project occurs during the irrigation season using irrigation water being released from
multiple irrigation related facilities upstream.
9.The Rock Creek Hydroelectric Project, a 2.1 MW facility, is located directly on
Rock Creek and not on a canal Approximately 70 percent of the water flows for the Rock Creek
Hydroelectric Project occur during the irrigation season and are primarily related to irrigation
water returning to the Snake River.
10.If the Commission (a) eliminated the reference to a "man-made waterway," in the
Note on this particular schedule, (b) substituted the words "irrigation related" for the words
"canal drop" in the name or title of this particular schedule, and (c) indicated on the schedule or
in an Order on Clarification that such a project does not have to be physically located "on a
canal," such clarifications would help avert possible future controversies related to the type of
hydro projects that qualify for this avoided cost schedule.
[remainder of this page left blank]
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I declare under penalty of perjury that, to the best of my knowledge and belief, the
forgoing is true and correct.
IM— DATED This_day of January 2013
C\- 9,~
John Lo

SUBSCRIBED AND SWORN to before me this day of January, 2013

E4kV'G0WM=MEXPME8XM 28,M4 Residing at Oregon
My Commission Expires: .r4C tet4
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ATTACHMENT 1 TO AFFIDAVIT OF JOHN LOWE
Renewable Energy Coalition
Idaho Members and Projects
Summary- Thirteen members representing 22 projects with 20 existing projects and 3 proposed
projects. *Note one existing project is located outside Idaho but selling to IPCO. ** Proposed
projects. HI-lifted projects sell to Idaho Power and remainder to PaclfiCorp.
1. Ted Sorenson
a. Dry Creek, 3.2MW
b Birch Creek, 27MW
c.Marsh Valley, 1.9MW
d.Pancheri Hydro, 290 kW
e.Lemhi Hydro, 450 kW
f.St. Anthony, 700kW**
g.Tuber Hydro, 7MW*
2. Rob Fackefi
Mink Creek, 3.1MW
3. Maher Wissa
Portneuf Hydro, 1MW
4. Mitch Arkoosh
GeoBon II, 1MW
S. Jordan Whittaker
Whittaker Hydro, 300kW**
6. David Snedigar
a.Snedigar Hydro, 500kW
b.OJ Hydro, 170 kW
7. ShoRock Hydro
a. Shoshone Hydro phase I and II, 975kW
b Rock Creek Hydro, 2 5MW
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8. Allan Ravenscroft
Ravenscroft Hydro, 1.1MW
9. Bill Arkoosh
a.Little Wood River Ranch, 920kW
b.Little Wood River Ranch II, 1.1MW**
10. Allen Koyle
Koyle Hydra, 1.3 MW
11. Scott Kaster
a.BC Hydra, 250kW
b.Hl( Hydro, 500kW
12. Jack Amy
Amy Ranch Hydro, 600 kW
13. Orville Nicholson
Nicholson's Hydro, 45kW
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CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 8th day of January, 2013, I caused to be served a
true and correct copy of the Petition of the Renewable Energy Coalition for Clarification of
Order No. 32697 and Affidavit of John Lowe on behalf of Renewable Energy Coalition upon
the following individuals in the manner indicated below:
Donovan E. Walker
Jason B. Williams
Idaho Power Company
P0 Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
Hand Delivery
L US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
Michael G. Andrea Hand Delivery Avista Corporation
1411 E. Mission Avenue - MSC-23 US Mail (postage prepaid)
Spokane, WA 99202 fl Facsimile Transmission
michael.andreaavistacorp.com Federal Express
Electronic Transmission
Daniel E. Solander n Hand Delivery
PacifiCorp dba Rocky Mountain Power US Mail (postage prepaid)
201 South Main, Suite 2300 Facsimile Transmission
Salt Lake City, UT 84111 D Federal Express
daniel.solanderpacificorp.com Z Electronic Transmission
Kristine A. Sasser Hand Delivery Idaho Public Utilities Commission fl US Mail (postage prepaid) 472 W. Washington (zip: 83702) Facsimile Transmission P0 Box 83720 Federal Express Boise, ID 83720-0074 Electronic Transmission kris.sasserpuc.idaho.gov
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
P0 Box 7218
Boise, ID 83702
[e-mail]
gregrichardsonandoleary.com
Attorneys for NIPPC, J.R. Simplot Co.,
Grand View, Exergy Development Group,
Board of County Commissioners of
Adams County, Idaho and Clearwater
Paper Corporation
O Hand Delivery
O US Mail (postage prepaid)
0 Facsimile Transmission
0 Federal Express
Electronic Transmission
Certificate of Delivery, Page 1
Robert D. Kahn LI Hand Delivery NIPPC, Executive Director E] US Mail (postage prepaid) 1117 Minor Ave., Suite 300 LI Facsimile Transmission Seattle, WA 98101 LI Federal Express [e-mail] Electronic Transmission
Don Sturtevant LI Hand Deliver' Energy Director
J.R. Simplot Company LI US Mail (postage prepaid)
P.O. Box 27 F-1 Facsimile Transmission
Boise, ID 83707-0027 F-1 Federal Express
Electronic Transmission don.sturtevantsimplot.com
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Springs, CA 92241
robertapau108ginail.com
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
James Carkulis
M Managing Member LI Hand Deliver'
Exergy Development Group of Idaho, LLC LI
LI
US Mail (postage prepaid)
Facsimile Transmission 802 West Bannock Street, Suite 1200 LI Federal Express Boise, ID 83702
[e-mail] Electronic Transmission
Dr. Don Reading LI Hand Delivery Exergy Development Group of Idaho, LLC LI US Mail (postage prepaid) 6070 Hill Road LI Facsimile Transmission Boise, ID 83703 LI Federal Express [e-mail] Electronic Transmission
Bill Brown, Chair LI Hand Delivery Board of Commissioners of Adams Count' LI US Mail (postage prepaid) P0 Box 48 LI Facsimile Transmission Council, ID 83612 LI Federal Express [e-mail] Electronic Transmission
Mary Lewallen
Clearwater Paper Corporation
601 W. Riverside Ave., Suite 1100
Spokane, WA 99201
[e-mail]
LI Hand Delivery
LI US Mail (postage prepaid)
LI Facsimile Transmission
LI Federal Express
Electronic Transmission
Certificate of Delivery, Page 2
John R. Lowe Hand Delivery Consultant to
Renewable Energy Coalition US Mail (postage prepaid)
12050 SW Tremont Street Facsimile Transmission
Portland, OR 97225 Federal Express
Electronic Transmission [e-mail]
R. Greg Ferney Hand Delivery Mimura Law Offices, PLLC fl US Mail (postage prepaid) 2176 B. Franklin Road, Suite 120 LI Facsimile Transmission Meridian, ID 83642 F-1 Federal Express g [e-mail] Electronic Transmission Attorneys for Interconnect Solar
Bill Piske, Manager F-1 Hand Delivery Interconnect Solar Development, LLC E] US Mail (postage prepaid) 1303 E. Carter
Boise, ID 83706 LI Facsimile Transmission
[e-mail] LI Federal Express
Electronic Transmission
Wade Thomas F-1 Hand Delivery General Counsel LI US Mail (postage prepaid) Dynamis Energy, LLC F-1 Facsimile Transmission 776 E. Riverside Drive, Suite 150
Eagle, ID 83616
F-1 FederalExpress
[e-mail] Electronic Transmission
C. Thomas Arkoosh LI Hand Delivery Capitol Law Group, PLLC
205 N. 10th St., 4th Floor LI US Mail (postage prepaid)
P0 Box 2598 LI Facsimile Transmission
Boise, ID 83701 F-1 Federal Express
Electronic Transmission [e-mail]
Attorneys for Twin Falls Canal Company,
North Side Canal Company, Big Wood
Canal Company and American Falls
Reservoir District No. 2
Brian Olmstead ELECTRONIC SERVICE ONLY: General Manager
Twin Falls Canal Company Electronic Transmission
[e-mail]
Certificate of Delivery, Page 3
Don Schoenbeck
RCS
[e-mail]
ELECTRONIC SERVICE ONLY:
Electronic Transmission
Lori Thomas
Capitol Law Group, PLLC
[e-mail]
ELECTRONIC SERVICE ONLY:
Electronic Transmission
Ted Diehl
General Manager
North Side Canal Company
[e-mail]
ELECTRONIC SERVICE ONLY:
Electronic Transmission
Ted S. Sorenson Hand Deliver' Birch Power Company
5203 South 11th East 0 US Mail (postage prepaid)
Idaho Falls, ID 83404 0 Facsimile Transmission
[e-mail] Federal Express
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Dean J. Miller
Chas. F. McDevitt F-1 Hand Delivery
McDevitt & Miller, LLP fl
0
US Mail (postage prepaid)
Facsimile Transmission 420 W. Bannock Street (zip: 83702) 0 P0 Box 2564 Federal Express
Electronic Transmission Boise, ID 83701
[e-mail]
[e-mail]
Attorneys for Idaho Windfarms, LLC,
Renewable Northwest Project and
Ridgeline Energy LLC
Glenn Ikemoto Hand Delivery Margaret Rueger 0 US Mail (postage prepaid) Idaho Windfarms, LLC LI Facsimile Transmission 672 Blair Avenue 0 Federal Express Piedmont, CA 94611
glennienvisionwind.com Electronic Transmission
margaretenvisionwind.com
Megan Walseth Decker fl Hand Delivery Senior Staff Counsel
Renewable Northwest Project fl US Mail (postage prepaid)
421 SW 6th Avenue, Suite 1125 0
0
Facsimile Transmission
Portland, OR 97204 Federal Express
Electronic Transmission meganrnp.org
Certificate of Delivery, Page 4
M. J. Humphries LI Hand Delivery Blue Ribbon Energy LLC
4515 S. Ammon Road r-1 USMail (postage prepaid)
Facsimile Transmission Ammon, ID 83406 LI Federal Express blueribbonenergygmail.com Electronic Transmission
Anon F. Jepson LI Hand Deliver' Blue Ribbon Energy LLC LI US Mail (postage prepaid) 10660 South 540 East LI Facsimile Transmission Sandy, UT 84070 F1 Federal Express [e-mail] Electronic Transmission
Benjamin J. Otto LI Hand Deliver' Idaho Conservation League E] US Mail (postage prepaid) 710 N. Sixth Street (zip: 83702) LI Facsimile Transmission P0 Box 844 F-1 Federal Express Boise, ID 83701 Electronic Transmission [e-mail]
Liz Woodruff
Ken Miller F-1 HandDelivery
Snake River Alliance [7 US Mail (postage prepaid)
P0 Box 1731 F1 Facsimile Transmission
Boise, ID 83701 LI Federal Express
Electronic Transmission [e-mail]
kmillersnakeriveralliance.org
Tauna Christensen F-1 Hand Delivery Energy Integrity Project LI US Mail (postage prepaid) 769 N. 1100 E.
Shelley, ID 83274 LI Facsimile Transmission
taunaenergyintegrityproject.org F-1 Federal Express
Electronic Transmission
Deborah E. Nelson
K LI Hand Delivery Kelsey J. Nunez
Givens Pursley LLP LI US Mail (postage prepaid)
601 W. Bannock Street (83702) LI Facsimile Transmission
P0 Box 2720 LI Federal Express
Boise, ID 83701-2720 Electronic Transmission
[e-mail]
[e-mail]
Attorneys for Idaho Wind Partners I, LLC
Certificate of Delivery, Page 5
J. Kahle Becker
The Alaska Center
1020 W. Main St., Suite 400
Boise, ID 83702
[e-mail]
Attorney for Mountain Air Projects, LLC
Michael J. Uda
Uda Law Firm, P.C.
7 W. 6t1 Avenue, Suite 4E
Helena, MT 59601
[e-mail]
Attorney for Mountain Air Projects, LLC
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
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F-1 Hand Delivery
L US Mail (postage prepaid)
0 Facsimile Transmission o Federal Express
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Ronald L. Williams
Certificate of Delivery, Page 6