20061109PacifiCorp reply comments.pdf

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November 8, 2006
RECEIVED
200& NOV -9 AM 10: 07
201 South Main , Suite 2300
Salt lake City, Utah 84111
Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702-5983
IDflHO ;)u0L\G
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UTILITIES COMMISSIOc~
Attention:Jean D. Jewell
Commission Secretary
Re:Reply Comments ofPacifiCorp in Case No. IPC-06-
PacifiCorp (d.a. Rocky Mountain Power) hereby submits for filing an original and eight (8)
copies of its Reply Comments in Case No. IPC-06-, Cassia Gulch Wind Park, LLC and
Cassia Wind Farm, LLC.
Service of pleadings, exhibits, orders and other documents relating to this proceeding should be
served on the following:
Dean Brockbank
Senior Attorney
Rocky Mountain Power
One Utah Center, Suite 2200
201 South Main
Salt Lake City, UT 84111
dean. brockbank~pacificorp.com
Brian Dickman
Manager, Idaho Regulatory Affairs
Rocky Mountain Power
One Utah Center, Suite 2300
201 South Main
Salt Lake City, UT 84111
brian. dickman~pacificorp. com
It is respectfully requested that all formal correspondence and Staff requests regarding this
material be addressed to:
Bye-mail (preferred):datareq uest~pacifi corp. com
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon, 97232
By fax:[phone]
Sincerely,fJ~~/v/)D. Douglas Larson
Vice President, Regulation
Enclosures
cc: Service List in Docket No. IPC-06-
Dean Brockbank
PacifiCorp
201 S. Main Street, Suite 2200
Salt Lake City, UT 84111
Telephone: [phone]
Fax: [phone]
E-mail: dean. brockbank~pacificorp.com
RECEIVED
200& NO'i -9 An \0: 08
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UTILlT \\:S COMiv\lSSIOr-j
Attorney for PacifiCorp
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASSIA GULCH WIND PARK, LLC AND
CASSIA WIND FARM, LLC
REPLY COMMENTS OF
ACIFICORP
CASE NO. IPC-O6-
COMPLAINANTS,
IDAHO POWER COMPANY
RESPONDENT.
COMES NOW PacifiCorp dba Rocky Mountain Power ("PacifiCorp" or the
Company ), by and through its attorney of record, and respectfully submits the
following reply comments in the above referenced matter.
REP~ Y COMMENTS
As noted in the Answer and Comments of Idaho Power filed with the Idaho
Public Utilities Commission ("Commission ) on October 27, 2006, Idaho Power has
presented a compromise proposal to Cassia Gulch Wind Park, LLC and Cassia Wind
Farm, LLC ("Cassia" or the "Projects ) to address the funding of system upgrades
REPL Y COMMENTS OF P ACIFICORP
occasioned by the proposed interconnection of the Projects. The Idaho Power proposal
includes treating payments by resource developers for transmission upgrades as advances
in aid of construction, with the advances to be repaid in full with interest to the developer
over a period of time not to exceed the term of the contract between the developer and the
utility. PacifiCorp recognizes that the proposal was made in an attempt to arrive at a
mutually-agreeable solution to the issue at hand and that such a proposal has not been
approved by the Commission. That said, PacifiCorp believes the Idaho Power offer to
Cassia is overly generous. By offering to allow Cassia to finance the transmission
upgrades and subsequently receive transmission credits, the Idaho Power proposal
obligates retail customers to endure rate impacts associated with the new transmission
investment over time as credits are returned to Cassia. PacifiCorp believes that if a
developer wants the safe harbor of utility avoided costs rates, the developer should be
obligated to pay for all the interconnection and integration transmission upgrades
required. This is the only way to give incentive for developers to make proper and cost
effective generation siting decisions while maintaining ratepayer indifference.
Conversely, ifthe developer wishes to sell its facility s output at market rates on a
competitive basis and comparable to other independent power producers, it should be
treated similar to other independent power producers and receive the financial treatment
under the current FERC procedures. Developers should not be offered the best of both-
to do so would violate the ratepayer neutrality principle.
REPLY COMMENTS OF P ACIFICORP
CONCLUSION
PacifiCorp reiterates its position previously filed with the Commission in its
October 27 2006 comments and respectfully requests that the Commission require QF
developers to pay for all interconnection and system upgrade costs associated with their
respective projects. All communications regarding these comments should be directed to
Brian Dickman at [phone].
Respectfully submitted this 8th day of November, 2006.
J)~f,-
Dean Brockbank
Attorney for PacifiCorp
--'
REPL Y COMMENTS OF P ACIFICORP
PROOF OF SERVICE
I hereby certify that on this 8th day of November 2006 I caused to be served, via E-mail and
S. mail, a true and correct copy ofthe foregoing REPLY COMMENTS OF PACIFICORP in Case
No. IPC-06-21 to the following parties as shown:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
Email: iiewell~puc.state.id.
Dean J. Miller
McDevitt & Miller, LLP
420 W. Bannock Street
PO Box 2564 (83701)
Boise, ID 83702
Email: ioe~mcdevitt -milleLcom
Barton L. Kline
Lisa Nordstrom
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Email: bkline~idahopoweLcom
lnordstrom~idahopower. com
Ronald K. Arrington
Associate Chief Counsel
John Deere Credit
6400 NW 86th Street
Johnston, IA 50131
Email: arringtonronaldk~i ohndeere. com
David Sikes
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Email: dsikes~idahopower. com
David J. Meyer
Vice President, Chief Counsel for
Regulatory and Governmental Affairs
O. Box 3727
1411 E. Mission Avenue
Spokane, W A 99220-3727
Email: dmever~avistacorp. com
Brian Dickman
Dean Brockbank
PacifiCorp/dba Rocky Mountain Power
201 S. Main St. Suite 2200
Salt Lake City, UT 84111
Email: brian.dickman~pacificorp.com
dean. brockbank~pacificorp.com
Lawrence R. Lieb
Exergy Development Group of Idaho LLC
910 W. Main Street, Ste. 310
Boise, ID 83702
Telephone: [phone]
Fax: [phone]
Email:sbcglobal.net
Peter Richardson
Richardson & O'Leary
515 N. 27th Street
Boise, Idaho 83702
[phone]
Email: peter~richardsonandoleary.com