20061117final_order_no_30179.pdf

Office of the Secretary
Service Date
November 17, 2006
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INSTITUTE A UNIFORM
SCHEDULE 72 INTERCONNECTION
AGREEMENT AND AMEND TARIFF
LANGUAGE
ORDER NO. 30179
CASE NO. IPC-06-
On September 1 , 2006, Idaho Power Company filed an Application seeking authority
to revise its Schedule 72 to include a Uniform Interconnection Agreement and to make the
associated tariff language changes. On October 5, 2006, the Commission issued a Notice of
Application and Notice of Modified Procedure with a deadline of October 31 , 2006 for written
comments and/or protests. The only comments filed were those of Commission Staff. With this
Order the Commission approves the Company s Application as more fully stated below.
THE APPLICATION
The Company proposes to implement a separate Uniform Interconnection Agreement
to improve its internal processes and ensure the functional separation between power supply and
delivery mandated by the Federal Energy Regulatory Commission (FERC). The Company states
that when non-utility projects, such as PURP A qualified facilities (QFs), request interconnection
to Idaho Power s distribution/transmission system the current practice is to address those issues
in the power purchase agreement document and in conjunction with Schedule 72
(Interconnections to Non-Utility Generation). However, because interconnection is managed by
Idaho Power s Power Delivery (Transmission) business unit, while power purchase agreements
are within the purview of Idaho Power s Power Supply (Marketing) business unit, and FERC
now requires a functional separation between the activities of these two business units, it is no
longer possible for the marketing business unit to negotiate interconnection terms and conditions
as part of the power purchase agreement.
Idaho Power s proposed Uniform Interconnection Agreement addresses the terms
and conditions of interconnection and integration to the Company s transmission/distribution
system, incorporates portions of the Company s template power purchase agreement, and is
patterned after FERC's standard Small Generator Interconnection Agreement. The Company
states that the Uniform Agreement is in keeping with utility industry efforts to standardize
ORDER NO. 30179
interconnection procedures and facilitate investment in needed utility infrastructures.The
proposed Uniform Interconnection Agreement is included in the Company s proposed tariff.
Idaho Power states that it is not proposing any major changes to the terms and
conditions of Schedule 72 other than referencing the Uniform Interconnection Agreement and
adding language explicitly adopting the Institute of Electrical and Electronic Engineers: IEEE
Standard 1547 (IEEE 1547) for interconnection. The Company states that it has adopted IEEE
1547 internally and believes non-utility generation interconnection should adhere to these
industry best practices as well.
ST AFF COMMENTS
Staff reviewed the Company s Application as well as Schedule 72 and some related
Commission cases. Staff stated that it has no objection to Idaho Power instituting a Uniform
Interconnection Agreement as part of its Schedule 72 tariff, Interconnections to Non-Utility
Generation. However, Staff recommended that language be added to Schedule 72 to clarify that
generation facilities that qualify for Schedule 84 will not be required to sign a Uniform
Interconnection Agreement. Staff also recommended approval of the Company s request to
adopt IEEE 1547 as a standard for interconnections for all net metering facilities and for PURP
projects with a nameplate rating less than 1 MW.
Staff reported that Idaho Power s Schedule 72 Uniform Interconnection Agreement
addresses the terms and conditions of interconnection and integration to the Company
transmission/distribution system. Idaho Power reviewed the NARUC Model Interconnection
Procedures Agreement, as well as FERC's Large and Small Generator Interconnection
Agreement (LGIA and SGIA, respectively). The Company also included several contract
provisions that have been accepted by the Commission in dozens of firm energy sales
agreements over the years, including provisions relating to termination, disconnection
emergencies, maintenance, land rights, liability, force majeure, default, and insurance.
Staff recognized the functional separation requirements of FERC and that it may be
advantageous for the Company to have separate agreements for power purchase and for
interconnection. Staff does not believe that requiring two separate agreements will make it any
more burdensome for non-utility generators to develop projects.
Staff reviewed the proposed Uniform Interconnection Agreement and believes that
the terms and conditions contained in it are reasonable. However, Staff recommended that
ORDER NO. 30179
additional language be added to Schedule 72 to clarify that generation facilities that qualify for
Schedule 84 (Customer Energy Production Net Metering) will not be required to sign a Uniform
Interconnection Agreement. Specifically, Staff recommends that the A V AILABILITY
paragraph of Schedule 72 be modified to add the following language:
Service under this schedule is available throughout the Company s service
area within the State of Idaho to Sellers owning or operating Qualifying
Facilities that sign a Uniform Interconnection Agreement or Generation
Facilities that qualify for Schedule 84. Generation Facilities that qualify for
Schedule 84 are not required to sign a Uniform Interconnection Agreement.
Idaho Power has indicated to Staff that it has no objection to adding the above-recommended
language.
Staff supports Idaho Power s request to explicitly adopt IEEE Standard 1547 for all
net metering facilities and for PURP A projects with a nameplate rating less than 1 MW. The
Company informed Staff that it did not include IEEE 1547 as an explicit requirement for projects
larger than 1 MW because it is merely one technical standard among many for those projects.
Idaho Power stated that it decided not to incorporate IEEE 1547 by reference so that if it changes
over time or if some portion of it is not appropriate for a particular application, a built-in conflict
is not created. Staff noted that Idaho Power had indicated in a separate case now before the
Commission concerning the consideration of the five new ratemaking standards in the Energy
Policy Act of 2005 , Case No. GNR-06-, that it would seek to explicitly include IEEE 1547
in its Schedule 72.
FINDINGS
We have reviewed the record for this case, including the Application and comments.
No protests to the Commission s use of Modified Procedure were filed. We continue to find that
the public interest does not require a hearing to consider the issues presented in this case and that
Modified Procedure is appropriate. IDAP A 31.01.01.204. The Commission has jurisdiction
over Idaho Power, its Application seeking authority to revise its Schedule 72 to include a
Uniform Interconnection Agreement and to make the associated tariff language changes, and the
issues involved in this case by virtue of Title 61 , Idaho Code, specifically including Idaho Code
~~ 61-129 61-119 61-301 61-302 61-303 61-305, and 61-501 , and the Commission s Rules of
Procedure, IDAPA 31.01.01.000 et seq.
ORDER NO. 30179
We find that the Company s request to revise its Schedule 72 to include a Uniform
Interconnection Agreement and to make the associated tariff language changes is reasonable.
The Company s proposed Uniform Interconnection Agreement is based upon its review of model
agreements from both NARUC and FERC. It appears that having separate agreements for
interconnection and for power purchase is required by the functional separation requirements of
FERC. It does not appear requiring two separate agreements will make it any more burdensome
for non-utility generators to develop projects. Adoption of IEEE Standard 1547 for all net
metering facilities and for PURP A projects with a nameplate rating less than 1 MW is consistent
with the Company s internal practice, as well as the Company s position in Case No. GNR-06-
, concerning the consideration of the five new ratemaking standards in the Energy Policy Act
of 2005. Consequently, we find it reasonable and prudent to approve the Company
Application. Additionally, we approve the additional language recommended above by Staff for
inclusion in the AVAILABILITY paragraph of Schedule 72.
ORDER
IT IS HEREBY ORDERED that Idaho Power s Application to institute a Uniform
Interconnection Agreement, to adopt IEEE 1547, and to adopt the associated tariff language
changes is granted. The additional language recommended above by Staff for inclusion in the
A V AILABILITY paragraph of Schedule 72 shall also be included in the tariff language changes.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order with regard to any
matter decided in this Order. Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code ~ 61-
626.
ORDER NO. 30179
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this /7tA
day of November 2006.
PAU
LJ~
MARSHA H. SMITH, COMMISSIONER
ATTEST:
mmlSSlOn Secretary
O:IPC-O6-dw2
ORDER NO. 30179