20070216notice_of_petition_ipc.pdf

Office of the Secretary
Service Date
February 16 2007
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO REVISE THE
PUBLISHED AVOIDED COST RATES TO
INCLUDE A DAILY LOAD SHAPE; AND
TO CLARIFY THE RULES GOVERNING
ENTITLEMENT TO PUBLISHED AVOIDED
COST RATES
CASE NO. IPC-O7-
NOTICE OF PETITION
NOTICE OF
MODIFIED PROCEDURE
NOTICE OF
COMMENT/PROTEST DEADLINE
YOU ARE HEREBY NOTIFIED that on February 6, 2007, Idaho Power Company
(Idaho Power; Company) filed a Petition with the Idaho Public Utilities Commission
(Commission) requesting authority to revise its published avoided cost rates for qualifying
facilities (QFs) under Sections 201 and 210 of the Public Utility Regulatory Policies of 1978
(PURPA) to reflect Idaho Power s daily load shape and recognize the difference in value
between energy delivered by QFs during heavy load hours and energy delivered during light load
hours. As reflected in the Company s Petition, this revision would not change the computation
of avoided cost but it could change the total revenues received by QFs depending on when
during the day they deliver energy.
The Company in its Petition also seeks to clarify the rules governing the entitlement
to published rates to prevent QF projects capable of delivering more than 10 aMW per month
from artificially restructuring into smaller projects in order to qualify for the published avoided
cost rates.
Daily Load Shape Adjustment
Idaho Power reports that since the early 19808, when PURP A was first implemented
in Idaho, the Commission shaped Idaho Power s QF purchase rates to address the difference in
energy values between the various seasons of the year. The seasonalization ofthe avoided cost
rates recognizes that energy delivered by QFs has different values based on when it is delivered.
Similar to seasonalization, Idaho Power contends that energy provided by QFs has
different values based on how it can help meet the Company s daily peaks in load. This
difference in value between heavy load hours and light load hours, the Company states, was the
NOTICE OF PETITION
NOTICE OF MODIFIED PROCEDURE
NOTICE OF COMMENT/PROTEST DEADLINE
basis for the daily shape adjustment that was approved for A vista Corporation in Commission
Order No. 30111 issued in Case No. A VU-06-04. The Company s proposed changes to the
published rates to reflect the daily shape adjustment are reflected in Attachment 1 to its Petition.
Disaggregation of Large QFs Into Smaller Projects
Addressing its concern that QF projects capable of generating more than 10 aMW per
month will choose to create multiple legal entities to reconfigure themselves into multiple
smaller projects in order to qualify for the historically higher published rates, Idaho Power
proposes to clarify its rules for published rate eligibility to preclude disaggregation.
Idaho Power states that the disaggregation issue was recently addressed in the
PURP A avoided cost rate proceedings before the Public Utility Commission of Oregon (Docket
No. UM-1129). The parties to that proceeding, the Company states, settled the disaggregation
issue by negotiating a stipulation which was approved by the parties and presented to the Oregon
PUC for approval. The stipulation was signed by all of the utilities, the Oregon Department of
Energy, the Staff of the Oregon Public Utility Commission, Sherman County and the lR.
Simplot Company. No party to that case, the Company states, opposed the stipulation. In Order
No. 06-538 and Order No. 06-586 , the Oregon PUC approved the settlement stipulation that
defined those small cogeneration facilities or small power production facilities eligible to receive
Oregon "standard rates." Idaho Power submits a proposed rule set forth in Petition Attachment 2
proposing language similar to that approved in Oregon.
YOU ARE FURTHER NOTIFIED that the Commission has reviewed the filings of
record in Case No. IPC-07-04. The Commission has preliminarily found that the public
interest in this matter may not require a hearing to consider the issues presented and that issues
raised by the Company s filing may be processed under Modified Procedure , by written
submission rather than by hearing. Reference Commission Rules of Procedure, IDAP
31.01.01.201-204.
YOU ARE FURTHER NOTIFIED that the deadline for filing written comments or
protests with respect to Idaho Power s Petition and the use of Modified Procedure in Case No.
IPC-07-04 is Friday, March 23, 2007. Persons desiring a hearing must specifically request a
hearing in their written protests or comments.
YOU ARE FURTHER NOTIFIED that if no written comments or protests are
received within the deadline, the Commission may consider the matter on its merits and may
NOTICE OF PETITION
NOTICE OF MODIFIED PROCEDURE
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enter its Order without a formal hearing. If comments or protests are filed within the deadline,
the Commission will consider them and in its discretion may set the matter for hearing or may
decide the matter and issue its Order based on the written positions before it. Reference IDAP
31.01.01.204.
YOU ARE FURTHER NOTIFIED that written comments concerning Case No. IPC-
07-04 should be mailed to the Commission and the Company at the addresses reflected below.
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
Street Address for Express Mail:
Monica Moen, Attorney II
Barton L. Kline, Senior Attorney
Idaho Power Company
1221 W. Idaho Street (83702)
PO Box 70
Boise, ID 83707-0070
E-mail: mmoen(ill,idahopower.com
bkline~idahopower.com472 W. Washington Street
Boise, ID 83702-5983
All comments should contain the case caption and case number shown on the first page of this
document.Persons desiring to submit comments via e-mail may do so by accessing the
Commission s home page located at www.puc.idaho.gov. Click the "Comments and Questions
icon, and complete the comment form, using the case number as it appears on the front of this
document. These comments must also be sent to Idaho Power at the e-mail addresses listed
above.
YOU ARE FURTHER NOTIFIED that the Petition in Case No. IPC-07-04 may be
viewed at www.puc.idaho.gov by clicking on "File Room" and "Electric Cases " or can be
viewed during regular business hours at the Idaho Public Utilities Commission, 472 W.
Washington Street, Boise, Idaho and at the general business office of Idaho Power Company,
1221 West Idaho Street, Boise, Idaho.
DATED at Boise, Idaho this / ~f'I-day of February 2007.
EtAnJe D. Jewell
Co mission Secretary
blsfN:IPC-07-04 sw
NOTICE OF PETITION
NOTICE OF MODIFIED PROCEDURE
NOTICE OF COMMENT/PROTEST DEADLINE