20070806PacifiCorp Reply Comments.pdf

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Salt Lake City, Utah 84111
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Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702-5983
Attention:Jean D. Jewell
Commission Secretary
Re:Reply Comments ofPacifiCorp in Case No. IPC-06-
Rocky Mountain Power, a division ofPacifiCorp, 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): datarequest~pacificorp.com
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon, 97232
By fax:[phone]
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Vice President, Regulation
Enclosures
cc: Service List in Docket No. IPC-06-
Dean Brockbank
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Fax: [phone]
E-mail: dean.brockbank(ll),pacificoro.com
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UTILi IES CCfA;V\ISSIC,
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASSIA GULCH WIND PARK, LLC AND
CASSIA WIND FARM, LLC,
REPLY COMMENTS OF
ROCKY MOUNTAIN
POWER
CASE NO. IPC-O6-
COMPLAIN ANTS,
IDAHO POWER COMPANY
RESPONDENT.
COMES NOW PacifiCorp dba Rocky Mountain Power ("Rocky Mountain
Power" or the "Company ), by and through its attorney of record, and respectfully
submits the following reply comments in the above referenced matter.
REPLY COMMENTS
As noted in the Comments of Commission Staff filed with the Idaho Public
Utilities Commission ("Commission ) on July 25 2007, the Commission Staff has
evaluated and recommended approval of the Settlement Stipulation between Idaho Power
Company and Cassia Gulch Wind Park, LLC and Cassia Wind Farm, LLC ("Cassia" or
the "Projects ).
REPLY COMMENTS OF ROCKY MOUNTAIN POWER
Applicability of the Settlement Stipulation to Other QFs and Other Utilities
In the Commission Staffs Comments, they review the applicability ofthe
Settlement Stipulation to other qualifying facilities ("QF") and other utilities in Idaho
including A vista and Rocky Mountain Power and recommend that the approach taken by
Idaho Power and these settlement terms and conditions are reasonable and be considered
when the other utilities face transmission constraints due to QF interconnection and
associated transmission system upgrades.
Rocky Mountain Power disagrees with Commission Staff on their recommendation to
make a broader application of this settlement to other utilities outside of Idaho Power for
the following reasons:
1. Rocky Mountain Power was not a party to any settlement discussions or to the
Settlement Stipulation and the transmission study undertaken by Idaho Power in
the Twin Falls area. even though the Company s Midpoint-Summer lake
transmission line is part of the electrical system where these QFs are
interconnecting with Idaho Power. The Exhibit C in the Settlement Stipulation
only lists the underlying system of Idaho Power and is not inclusive of other
utilities that may be impacted by the system upgrades and redispatch scenarios
proposed.
2. Rocky Mountain Power is concerned that by Idaho Power agreeing to a settlement
where they pay up front for the network upgrade cost of an interconnection
request, it will cause an increase in Idaho Power s revenue requirements and may
REPLY COMMENTS OF ROCKY MOUNTAIN POWER
cause a change in Idaho Power s FERC filed tariff rate. Rocky Mountain Power
as a user ofIdaho Power s transmission system, would likely be subject to
increased transmission costs necessary to serve its retail customers. Rocky
Mountain Power is concerned that a broad rule implementing the Settlement
Stipulation could set a precedent that Rocky Mountain Power might be forced to
follow if a QF connects to the Company s system in the Goshen area where
constraints exist and involves multiple utilities.
3. The Settlement Stipulation provisions do not take into consideration any impact to
existing customers or to legacy transmission agreements such as the Restated
Transmission Services Agreement ("RTSA") between the Company and Idaho
Power. For example, in the RTSA, the Company can utilize the reserve
capability of the Company s west side hydro system in its east side control area.
Up to 100 MW of east control area spinning reserves can be met from resources
in the west control area as well as bi -directional transfers of 104 MW of power
and energy between the Company s west side and east side control areas. Rocky
Mountain Power is concerned, and would like to ensure that the Settlement
Stipulation does not impact its ability to continue operating under the RTSA as it
has historically.
4. The Company incorporates by reference its initial Comments ofPacifiCorp, filed
with the Commission on October 27 2006. Rather than re-address those issues in
these Reply Comments, the Company requests that the Commission consider the
REPLY COMMENTS OF ROCKY MOUNTAIN POWER
same points that the Company made in those original Comments when evaluating
these Reply Comments.
CONCLUSION
For the reasons set forth above, Rocky Mountain Power recommends the general
terms and conditions or methodology of the Settlement Stipulation only apply to the
specific facts ofthe case with Idaho Power and Cassia Wind, and not to other utilities in
Idaho in other situations. All communications regarding these comments should be
directed to Brian Dickman at [phone].
Respectfully submitted this 6th day of August, 2007.
~/pp
Dean Brockbank
Attorney for Rocky Mountain Power
REPLY COMMENTS OF ROCKY MOUNTAIN POWER
PROOF OF SERVICE
I hereby certify that on this 6rd day of August 2007 I caused to be served, via E-mail and u.s.
mail, a true and correct copy of the foregoing REPLY COMMENTS OF P ACIFICORP 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(ll),puc.state.id.
Dean J. Miller
McDevitt & Miller, LLP
420 W. Bannock Street
PO Box 2564 (83701)
Boise, ID 83702
Email: ioecq2mcdevitt-miller.com
Barton L. Kline
Lisa Nordstrom
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Email: bkline(ll),idahopower.com
lnordstrom(ll),i dahopower. com
Ronald K. Arrington
Associate Chief Counsel
John Deere Credit
6400 NW 86th Street
Johnston, IA 50131
Email: arringtonronaldkcq2i ohndeere. com
David Sikes
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Email: dsikescq2idahopower. 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. brockbankcq2pacifi corp. 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: dmevercq2avistacorp. 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: petercq2richardsonandolearv.com OJL~
Debbie DePetris
Supervisor , Regulatory Administration