20061031Comments.pdf

DONOY AN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
RECEIVED
200& OCT 3\ f\t\ 10: 32
IDAHO PtNL\~:c
UTILITIES CO;'ii\~;I~v IOI'
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
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.
CASE NO. IPC-O6-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through its Attorney of record
Donovan E. Walker, Deputy Attorney General, in response to Order No. 30143 , the Notice of
Application and Notice of Modified Procedure issued on October 5 2006, respectfully submits the
following comments.
BACKGROUND
On September 1 , 2006 , Idaho Power Company (Idaho Power; Company) filed an
Application seeking authority to revise its Schedule 72 (Interconnections to Non-Utility
Generation) to include a Uniform Interconnection Agreement and to make the associated tariff
language changes. In addition, the Company is proposing to add language to the tariff explicitly
adopting the Institute of Electrical and Electronics Engineers Standard 1547 (IEEE Standard 1547)
for interconnection. Idaho Power states that it is not proposing any major changes to the terms and
STAFF COMMENTS OCTOBER 31 , 2006
conditions of Schedule 72 other than referencing the Uniform Interconnection Agreement and
adding language explicitly adopting the IEEE Standard 1547 for interconnection.
ANALYSIS
Uniform Interconnection Agreement
In its Application, Idaho Power states that when non-utility projects, such as PURP A
qualifying 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. However, interconnection is managed by Idaho Power
Power Delivery (transmission) business unit, while power purchase agreements are within the
purview ofIdaho Power s Power Supply (marketing) business unit. The Federal Energy
Regulatory Commission (FERC) now requires a functional separation between the activities of
these two business units, so it is no longer possible for the marketing business unit to negotiate
interconnection terms and conditions as part of the power purchase agreement. In order to
maintain the required functional separation between the two business units, Idaho Power is
proposing to create a Uniform Interconnection Agreement that is separate from the power purchase
agreement. Each agreement would be pursued simultaneously but separately by the respective
business units within Idaho Power.
Idaho Power s proposed Schedule 72 Uniform Interconnection Agreement addresses the
terms and conditions of interconnection and integration to the Company s transmission/distribution
system. In preparing the proposed Schedule 72 Uniform Interconnection Agreement, Idaho Power
reviewed the NARUC Model Interconnection Procedures Agreement as well as the FERC's Large
Generator Interconnection Agreement (LGIA) and Small Generation Interconnection Agreement
(SGIA). The Company also included contract provisions that have been accepted by the
Commission in dozens of firm energy sales agreements over the years. For example, some of
these provisions relate to termination, disconnection, emergencies, maintenance, land rights
liability, force majeure, default, and insurance.
As previously noted, Idaho Power is proposing these changes to Schedule 72 to respond to
FERC's Standards of Conduct and not because it believes there are any defects in the
interconnection process that require "fixing See Case No. GNR-06-, Comments ofIdaho
Power Company at page 19. The Company states that the Uniform Agreement is in keeping with
utility industry efforts to standardize interconnection procedures and facilitate investment in
STAFF COMMENTS OCTOBER 31 , 2006
needed utility infrastructures. The proposed Uniform Interconnection Agreement is included
Attachment I to the Company s proposed tariff.
Staff acknowledges the functional separation requirements ofFERC and recognizes that it
may now be advantageous for the Company to require separate agreements for power purchase and
interconnection. Staff does not believe that by requiring two separate agreements, it will be any
more burdensome for non-utility generators to develop projects. Staff has reviewed the Uniform
Interconnection Agreement and believes that the terms and conditions contained therein are
reasonable. Staff recommends, however, that additional 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 recommends that the A V AILABILITY paragraph of Schedule
72 be modified to add additional language as follows:
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 recommended language.
Schedule 72 Amendments
Idaho Power also proposes to add language to Schedule 72 explicitly adopting IEEE
Standard 1547 for interconnection for all net metering facilities and for PURP A proj ects with a
nameplate rating less than 1 MW. The PURP A section of the Energy Policy Act of 2005 proposes
five new ratemaking standards for consideration by each utility s regulatory body. One ofthose
standards proposes an interconnection standard for customers with on-site generating facilities.
Specifically, 16 U.C. 92621 proposes the following: Interconnection services shall be offered
based upon the standards developed by the Institute of Electrical and Electronics Engineers: IEEE
Standard 1547 for Interconnecting Distributed Resources with Electric Power Systems, as they
may be amended from time to time. Idaho Power states that it has adopted IEEE 1547 internally
and believes non-utility generation interconnection should adhere to these "industry best practices
as well.
STAFF COMMENTS OCTOBER 31 , 2006
In a separate case now before the Commission to consider the five new ratemaking
standards in the Energy Policy Act of2005 , Idaho Power indicated that it would seek to explicitly
include IEEE 1547 in its Schedule 72. Case No. GNR-06-2. The Company notes that the
standards and best practices included in the IEEE 1547 are currently part ofIdaho Power
interconnection procedures for PURP A QFs. In its comments in Case No. GNR-06-, Avista
recommended that the Commission adopt IEEE Standard 1547. Avista, moreover, recently
amended its interconnection requirements to include IEEE Standard 1547. See Order No. 30111
Case No. A VU-06-4. PacifiCorp stated the following in its comments:
It is not necessary for the Commission to mandate either the IEEE 1547
Standard or the National Association of Regulatory Commissioners
(NARUC) Interconnection Model for all distribution level
interconnections of on-site generating facilities. PacifiCorp already
applies the IEEE 1547 Standards to interconnection engineering studies to
determine safety and reliability of the proposed generation. Those
standards, however, may not be applicable to all interconnections and
specific deviations may be required due to specific circumstances
surrounding the generator design or local system.
Case No. GNR-06-, Comments ofPacifiCorp at page 10. The Company went on to state
PacifiCorp currently uses IEEE Standard 1547 in its study process to protect the safety and
reliability of the generator, other customers attached to the local network, utility workers and the
public. PacifiCorp has no concerns regarding the adoption by reference to generally applicable
industry standards.Id. at page 13.
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 a megawatt because it is one technical standard among many. Idaho Power states 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.
RECOMMENDATIONS
Staffhas no objection to Idaho Power instituting a Uniform Interconnection Agreement
a part of its Schedule 72 Interconnections to Non-Utility Generation tariff. Staff recommends
however, 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. In addition, Staff
STAFF COMMENTS OCTOBER 31 , 2006
recommends approval of the Company s request to adopt IEEE 1547 as a standard for
interconnections for all net metering facilities and for PURP A projects with a nameplate rating less
than 1 MW.
Respectfully submitted thiS
~(
day of October 2006.
Deputy Attorney General
Technical Staff:Rick Sterling
i:umisc/comments/ipceO6. 1 8dwrps
STAFF COMMENTS OCTOBER 31 , 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 31ST DAY OF OCTOBER 2006
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
DA VID SIKES
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
~,.J2 \(0/' Q.
SECRETARY
CERTIFICATE OF SERVICE