20130325Reconsideration Comments.pdf

Williams • Bradbury
A T T 0 R N E Y S A T L A W RECE
20t14AR25 PM 1: 24
IDAHO Ptl.L v rr -r
March25,2013 4
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 Reconsideration Comments of the
Renewable Energy Coalition for filing in the above referenced case.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,
41dL. illiams
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]
[e-mail]
2UflR25 PM 1:214
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 '
Case No. GNR-E-1 1-03
RECONSIDERATION COMMENTS
OF THE RENEWABLE ENERGY
[I61IPtIIS)I
COMES NOW the Renewable Energy Coalition ("REC"), by and through its counsel of
record, Ronald L. Williams of Williams Bradbury, P.C., and provides these comments.
A. Definition of Canal Drop. REC provided previous comments as to what it
considers a more appropriate definition of a canal drop project. Those comments, and the
affidavit of John Lowe, are adopted herein and made a part of these Comments.
While other commenters disagreed with REC's proposed definition, the point REC was
attempting to make is that justification for the higher rate should be based on the correlation
between the generation delivered and the utility's system peak month or months, and not the
physical features of the water delivery system. For Idaho Power, this correlation may be
appropriately tied to the irrigation season in southern Idaho and the peak month of July.
Conversely, eligibility for the canal drop avoided cost rate should not be left for the utility to
Reconsideration Comments Of The Renewable Energy Coalition, Page 1
determine in the first instance, with the QF forced to negotiate on a case-by-cases basis, as
recommended by Idaho Power.
It also seems that this debate has almost exclusively focused on Idaho Power and its July
system peak. PacifiCorp, with numerous small hydro QFs operating within its Idaho service
territory, appears to have a much different system peak than Idaho Power, as evidenced by its
December seasonality adjustment being significantly higher than any other month. Yet, it also
appears that PacifiCorp's canal drop avoided cost prices have been significantly influenced by
Idaho Power's July system peak. It is therefore important to confirm that the irrigation and non-
irrigation related hydro avoided cost rate schedules established for PacifiCorp correctly take into
PacifiCorp's system peak[s] that may be different than Idaho Power's.
B.Capacity Factor of Canal Drop Projects: REC has reviewed the Comments
of North Side Canal Company, Twin Falls Canal Company, Big Wood Canal Company, and
American Falls Reservoir District No. 2 (the "Canal Companies"), concurs in Comments of the
Canal Companies and adopts them as its own Comments with respect to the capacity factor for
projects ultimately determined to be eligible as canal drop projects.
C.Capacity Factors and Contract Seasonality Adjustments: Some REC members
have recently requested and received from Idaho investor owned utilities draft power purchase
agreements (PPAs) for hydroelectric and/or canal drop QF projects, or have requested avoided
cost information regarding the same. Those draft PPAs or rate information continue to make
seasonality adjustments previously approved by the Commission and applied to the generic SAR
calculated standard avoided cost rate.
Such prior adjustments were necessary and appropriate to account for seasonal
differences in capacity and energy values, when there was only one standard avoided cost rate
Reconsideration Comments Of The Renewable Energy Coalition, Page 2
available to the many different types of QF' s. However, to continue to apply the same
seasonality adjustment to, for example, a canal drop project that has already had its capacity
value and eligibility to canal drop avoided cost prices established based on the utility's system
peak month or months, appears to be redundant and inappropriate. Clarification on this point
would be helpful to REC members currently discussing or contemplating renewal contracts with
utilities. As stated before, it is REC's goal in these proceedings to minimize areas of ambiguity
and future disagreement in the PPA negotiating process.
RESPECFULLY SUBMITTED this __day of March, 2013.
WILLIAMS BRADBURY, P.C.
Ronald L. Williams
Attorney for the Renewable Energy Coalition
Reconsideration Comments Of The Renewable Energy Coalition, Page 3
CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 25th day of March, 2013, I caused to be served a true and
correct copy of the Reconsideration Comments of the 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]
Michael G. Andrea
Avista Corporation
1411 E. Mission Avenue - MSC-23
Spokane, WA 99202
[e-mail]
Daniel E. Solander
PaciflCorp dba Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
[e-mail]
LI Hand Delivery
LI US Mail(postage prepaid)
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LI US Mail (postage prepaid)
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Kristine A. Sasser LI Hand Delivery Idaho Public Utilities Commission LI US Mail (postage prepaid) 472 W. Washington (zip: 83702) LI Facsimile Transmission P0 Box 83720 LI Federal Express Boise, ID 83720-0074 Electronic Transmission [e-mail]
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
P0 Box 7218
Boise, ID 83702
peterrichardsonandoleary.com
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
LI Hand Delivery
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Reconsideration Comments Of The Renewable Energy Coalition, Page 4
Robert D. Kahn LI Hand Delivery NIPPC, Executive Director LI US Mail (postage prepaid) 1117 Minor Ave., Suite 300 LI Facsimile Transmission Seattle, WA 98101 LI Federal Express [e-mail] Electronic Transmission
Don Sturtevant
Energy Director
J.R. Simplot Company
P.O. Box 27
Boise, ID 83707-0027
[e-mail]
Robert A. Paul
Grand View Solar II
15690 Vista Circle
Desert Hot Springs, CA 92241
robertapau108gmail.com
James Carkulis
Managing Member
Exergy Development Group of Idaho, LLC
802 West Bannock Street, Suite 1200
Boise, ID 83702
[e-mail]
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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 dreadingmindspring.com Electronic Transmission
Bill Brown, Chair LI Hand Delivery Board of Commissioners of Adams County 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
Marv.lewallenc1earwaterpaper.com
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Reconsideration Comments Of The Renewable Energy Coalition, Page 5
John R. Lowe
Consultant to LI Hand Delivery
US Mail (postage prepaid) Renewable Energy Coalition LI
12050 SW Tremont Street LI Facsimile Transmission
Portland, OR 97225 LI Federal Express
jravenesanmarcosyahoo.com Electronic Transmission
R. Greg Ferney
Mimura Law Offices, PLLC LI Hand Delivery
2176 E. Franklin Road, Suite 120 LI US Mail (postage prepaid)
LI Facsimile Transmission Meridian, ID 83642 Federal Express [e-mail] LI
Electronic Transmission Attorneys for Interconnect Solar
Bill Piske, Manager LI Hand Delivery Interconnect Solar Development, LLC LI US Mail (postage prepaid) 1303 E. Carter
Boise, ID 83706 LI Facsimile Transmission
[e-mail] LI Federal Express
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Wade Thomas
General Counsel LI Hand Delivery
LI US Mail (postage prepaid) Dynamis Energy, LLC F-1 Facsimile Transmission 776 E. Riverside Drive, Suite 150
Eagle, ID 83616 LI Federal Express
[e-mail] Electronic Transmission
C. Thomas Arkoosh
Capitol Law Group, PLLC F-1 Hand Delivery
205 N. 10th St., 4th Floor
E] US Mail (postage prepaid)
P0 Box 2598 LI Facsimile Transmission
Boise, ID 83701 LI Federal Express
tarkooshcapitollawgroup.com Electronic Transmission
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 Electronic Transmission Twin Falls Canal Company
[e-mail]
Reconsideration Comments Of The Renewable Energy Coalition, Page 6
Ted Diehl
General Manager
North Side Canal Company
[e-mail]
ELECTRONIC SERVICE ONLY:
Electronic Transmission
Don Schoenbeck
RCS
[e-mail]
ELECTRONIC SERVICE ONLY:
Electronic Transmission
Lori Thomas
Capitol Law Group, PLLC ELECTRONIC SERVICE ONLY:
[e-mail] Electronic Transmission
Ted S. Sorenson F-1 Hand Deliver)' Birch Power Company
5203 South 1 1th East E] US Mail (postage prepaid)
Idaho Falls, ID 83404 LI F-1
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[e-mail]
FederalExpress
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Dean J. Miller
Chas. F. McDevitt
McDevitt & Miller, LLP
420 W. Bannock Street (zip: 83702)
P0 Box 2564
Boise, ID 83701
[e-mail]
[e-mail]
Attorneys for Idaho Windfarms, LLC,
Renewable Northwest Project and
Ridgeline Energy LLC
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Glenn Ikemoto
Margaret Rueger
Idaho Windfarms, LLC
672 Blair Avenue
Piedmont, CA 94611
glennienvisionwind.com
margaretenvisionwind.com
LI Hand Delivery
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Megan Walseth Decker LI Hand Delivery Senior Staff Counsel E] US Mail (postage prepaid) Renewable Northwest Project
421 SW 6th Avenue, Suite 1125 LI Facsimile Transmission
Portland, OR 97204 LI Federal Express
Electronic Transmission [e-mail]
Reconsideration Comments Of The Renewable Energy Coalition, Page 7
M. J. Humphries
Blue Ribbon Energy LLC
4515 S. Ammon Road
Ammon, ID 83406
blueribbonenergygmail.com
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
0 Federal Express
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Arron F. Jepson F-1 Hand Delivery Blue Ribbon Energy LLC 0 US Mail (postage prepaid) 10660 South 540 East 0 Facsimile Transmission Sandy, UT 84070 Federal Express [e-mail] Electronic Transmission
Benjamin J. Otto 0 Hand Delivery Idaho Conservation League fl US Mail (postage prepaid) 710 N. Sixth Street (zip: 83702) 0 Facsimile Transmission P0 Box 844 Federal Express Boise, ID 83701
[e-mail] Electronic Transmission
Liz Woodruff Hand Delivery Ken Miller
Snake River Alliance 0 US Mail (postage prepaid)
P0 Box 1731 0 Facsimile Transmission
Boise, ID 83701 0 Federal Express
Electronic Transmission [e-mail]
[e-mail]
Tauna Christensen Hand Delivery Energy Integrity Project 0 US Mail (postage prepaid) 769 N. 1100 E. 0 Facsimile Transmission Shelley, ID 83274 0 Federal Express [e-mail] Electronic Transmission
Deborah E. Nelson 0 Hand Delivery Kelsey J. Nunez
Givens Pursley LLP R US Mail (postage prepaid)
601 W. Bannock Street (83702) 0
fl
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P0 Box 2720 Federal Express
Electronic Transmission Boise, ID 83701-2720
[e-mail]
[e-mail]
Attorneys for Idaho Wind Partners I, LLC
Reconsideration Comments Of The Renewable Energy Coalition, Page 8
J. Kahle Becker E Hand Delivery The Alaska Center E US Mail (postage prepaid) 1020 W. Main St., Suite 400 Facsimile Transmission Boise, ID 83702 Federal Express [e-mail] Electronic Transmission Attorney for Mountain Air Projects, LLC
Michael J. Uda
Uda Law Firm, P.C.
7 W. 6th Avenue, Suite 4E
Helena, MT 59601
[e-mail]
Attorney for Mountain Air Projects, LLC
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US Mail (postage prepaid)
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Ronald L. Williams
Reconsideration Comments Of The Renewable Energy Coalition, Page 9