20080425Comments.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
RECEiVED
I, F.I: ¿
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY TO AMEND )
SCHEDULE 72 - INTERCONNECTIONS TO )NON-UTILITY GENERATION )
)
)
)
CASE NO. IPC-E-08-5
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice of
Application, Notice of Modified Procedure and Notice of Comment/Protest Deadline issued on
April 2, 2008, submits the following comments.
BACKGROUND
On March 18, 2008, Idaho Power Company (Idaho Power; Company) fied an
Application with the Idaho Public Utilties Commission (Commission) proposing additional
language for inclusion in its Schedule 72 - Interconnections to Non-Utilty Generation taiff.
The Company's fiing is in response to the Commission's directive in Order No. 30493 issued on
January 31, 2008 in Case No. IPC-E-07-13 (Exergy v. Idaho Power) wherein the Commission
stated:
STAFF COMMENTS 1 APRIL 25, 2008
The additional language (to the Company's Schedule 72 tariffJ should
describe in general the three-step study process that the Company follows
including (1) opportunities to pay for additional required studies on
incremental amounts, (2) opportunities to exit the interconnection process, and
(3) opportunities to qualify for and provide alternative financial guarantees in
lieu of full prepayment of the initial cost estimate.
Order No. 30493 pp. 6-7. The subject matter of Exergy's complaint in Case No. IPC-E-07-13
was Idaho Power's requirements for generation interconnection for qualifying facilties (QFs)
under the Public Utilty Regulatory Policies Act of 1978 (PURP A).
As defined by the Company, the non-utility "generator interconnection process" is the
Company's generation facility interconnection application, engineering review and construction
process. The intent of the generator interconnection process is to ensure a safe and reliable
generation interconnection and compliance with all applicable regulatory requirements, good
utility practices, and national safety standards. The language submitted by the Company
includes further description of the generator interconnection process including the application
stage and the three-step study process (i.e., the feasibility study; the system impact study and the
facility study). The Company's tariff proposal also sets forth the payment and securty
requirements for the costs of interconnection.
STAFF ANALYSIS
With its Application, Idaho Power submits proposed language additions to its Schedule
72 that address those issues identified by the Commission in Order No. 30493. Staffhas
reviewed the Company's proposed changes to the taiff and identifies three concerns: 1) Staff
believes the Schedule 72 tariff should include language stating that the Company's FERC-
approved Large Generator Interconnection Procedures and Small Generator Interconnection
Procedures posted on Idaho Power's website wil apply for all generator interconnection requests
except as modified by the provisions of Schedule 72; 2) Deposit requirements for
interconnection studies for projects 30 MW and larger should be clearly stated in Schedule 72,
and 3) Staff believes language should be inserted in Schedule 72 stating that interconnection
customers must pay the full cost of all required interconnection studies, and that a deposit
sufficient to cover the cost of the studies must be maintained in order for Idaho Power to
continue to perform work on the studies.
STAFF COMMENTS 2 APRIL 25, 2008
Staff discussed its concerns with Idaho Power and offered suggested language changes.
After some consultation, Idaho Power and Staff developed revised tariff language that is
acceptable to both paries. A redline version of tariff pages incorporating the revised language is
attached.
Besides language additions to the tariff intended primarily for clarification puroses, the
only other material change being proposed by Idaho Power is a reduction in the deposit
requirements for Facility Studies. The proposed maximum deposit amount is less than the
maximum deposit the Company previously charged. This lesser deposit amount is based on
recent analysis in which Idaho Power reviewed the actual costs of constructing small generation
interconnections. Staff reviewed the Company's analysis and agrees that a lesser maximum
deposit amount is waranted, provided language is added to the tariff authorizing Idaho Power to
require that a deposit suffcient to cover the cost of the studies must be maintained during the
course of preparation of the study. Such language has been included in the attached revised tariff
pages.
STAFF RECOMMENDATIONS
Staff believes that the revised tariff pages developed jointly by Idaho Power and Staff,
combined with the unevised tariff pages included in the Company's initial Application, comport
with the Commission's directives in Order No. 30493. Staff recommends approval of the
amendments to Schedule 72 as proposed by Idaho Power and as jointly modified by Staff and the
Company. Staff recommends an immediate effective date.
Respectfully submitted this ~ l' day of April 2008.
cx
Technical Staff; Rick Sterling
i:/umisc/comments/ipce08.5swrps comments
STAFF COMMENTS 3 APRIL 25, 2008
Idaho Power Company First Revised Sheet No. 72-3
Cancels
Original Sheet No. 72-3I.P.U.C. No. 28, Tariff No. 101
SCHEDULE 72
INTERCONNECTIONS TO
NON-UTILITY GENERATION
(Continued)
DEFINITIONS (Continued)
Vested Interest is the claim for refund that a Seller or Additional Applicant holds in a specific
portion of Company-owned Interconnection Facilities. The Vested Interest expires 5 years from the
date the Company completes construction of its portion of the Interconnection Facilties unless fully
refunded earlier. Vested Interests do not apply to Schedule 84 net metering projects.
GENERATOR INTERCONNECTION PROCESS
(a) Seller shall pay the actual costs of all required interconnection studies. Any difference
between the deposit (if required) and the actual cost of the study shall be paid by or refunded to Seller,
as appropriate. If, during the course of preparing a study, the Company incurs costs in excess of the
deposit amount. the Company may require that the deposit amount be replenished in an amount equal
to the estimated costs for completion of the study. If a deposit amount sufficient to pay for completion
of the study is not maintained, the Company may suspend work on the study.
(b) Unless modified by the provisions of this schedule, the FERC-approved Large Generator
Interconnection Procedures and Small Generator Interconnection Procedures posted on the
Company's website will apply to the Generator Interconnection Process.
(c) The deposit amounts for Generation Facilities up to 30 MW are specified in this
schedule. Deposit amounts for Generation Facilities larger than 30 MW are covered by the FERC-
approved Large Generator Interconnection Procedures posted on the Company's website.
(g) Application. The Seller will submit a completed interconnection application in the form
posted on the Company's website. The application form includes a general description of the
Generation Facility and its location. The application includes payment of an application fee to be
applied against costs the Company incurs to perform the Feasibility Study described below. The
amount of the application fee is $1,000 for a Generation Facility up to 30 MW.
(~) Study Agreements. If the Seller desires to proceed beyond the Application stage, the
Seller wil be offered a series of study agreements. The individual study agreements establish the time
to perform the study and the deposit the Seller is to provide prior to commencement of the study. The
deposit amount may be waived if a Seller meets the Company's credit worthiness standards for
unsecured credit specified in Attachment L to the Company's OA TT. The studies consist of:
1 ) The Feasibilty Study: The Feasibility Study includes a general review of project impact,
e.g. exceeding equipment capabilities and violation of electrical performance
requirements. The Feasibility Study Agreement states that no deposit is required, since
the deposit is covered by the application fee.
2)
Mtr ""
The System Impact Study: The System Impact Study provides a detailed assessment of 00 0
the distribution and/or transmission system adequacy to accommodate the Generation ~ ii ~
Facility through the evaluation of equipment capabilities and electrical performance:: ~ ~ æc.. '"II . i: 00Issued by IDAHO POWER COMPANY .. z 8 S2
John R. Gale, Vice President, Regulatory Affairs ~ ~ ~ !3
1221 West Idaho Street, Boise, Idaho ~ 8 iñ a
IDAHO
Issued Per IPUC Order No. 30179
Effective - November 20, 2006
Idaho Power Company First Revised Sheet No. 72-3
Cancels
I.P.U.C. No. 28, Tariff No. 101 Original Sheet No. 72-3
requirements. This step may not be necessary for some projects depending on the size
and location of the project. The System Impact Study Agreement includes a deposit of
$2,000 for a distribution system impact study or a $10,000 deposit for a transmission
system impact study.
3) The Facility Study: The Facilty Study includes the engineering to determine the design
specifications of the project. The Facility Study Agreement includes a deposit of 5% of
the total project costs that were determined in the System Impact Study Report ("SISR")
or the Feasibility Study Report if a SISR is not required, capped at $30,000.
At the end of each stage of the three-step study process, the Company will provide the Seller with an
increasingly more refined and detailed report that, among other things, wil present a list of required
Interconnection Facilities and a non-binding, good faith estimate of Seller's cost responsibility for the
Interconnection Facilities. If long-lead time equipment items need to be ordered to meet Seller's
construction schedule, the Company will request advance funding by the Seller to cover these
equipment costs.
(c) Generator Interconnection Agreement. The Generator Interconnection Agreement
("GIA"), wil be offered to Seller following completion of the Facility Study. The GIA will utilize the
Uniform Interconnection Agreement template included in this schedule.
COST OF INTERCONNECTION FACILITIES
All Interconnection Facilities provided under this schedule wil be valued at the Company's
Construction Cost and/or the Transfer Cost for vesting purposes as well as for operation and
maintenance payment obligations.
PAYMENT FOR INTERCONNECTION FACILITIES
Unless specifically agreed otherwise by written agreement between the Seller and the Company,
the Seller wil pay all costs of interconnecting a Generation Facility to the Company's system. Costs of
interconnection include the costs of furnishing and constructing required Interconnection Facilities and
Upgrades.
Each request for interconnection wil go through the Generator Interconnection Process.
Throughout the Generator Interconnection Process, the Company wil periodically bil the Seller for
costs incurred. Failure to pay an invoice within the time specified in the invoice wil result in suspension
of work on the interconnection and if the suspension of work extends beyond 30 calendar days, the
Generation Facility will be removed from the interconnection queue. Seller can end the Generator
Interconnection Process at any time. If Seller decides to end the Generator Interconnection Process
prior to completion, the Company will either refund any monies held for security that have not been
spent or obligated, or issue an invoice to Seller for costs incurred prior to cancellation.
SECURITY FOR PAYMENT OF INTERCONNECTION COSTS
Sellers wil provide adequate security for payment of the costs of the Generator Interconnection
Process. Adequate security for Generation Facilities larger than 30 MW can be provided in accordance
with the Large Generator Interconnection Procedures contained in Attachment M to the Company's
OATT. Adequate security for Generation Facilties up to 30 MW can be provided in one of the fOII()\Jingways: Attachment 1
Case No. IPC-E-08-5
Staff Comments
0412510S Page 2 of 3
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho
IDAHO
Issued Per IPUC Order No. 30179
Effective - November 20, 2006
Idaho Power Company First Revised Sheet No. 72-3
Cancels
I.P.U.C. No. 28, Tariff No. 101 Original Sheet No. 72-3
1. Sellers that meet the Company's credit worthiness standards for unsecured credit are
not required to provide additional security. The Company's minimum credit standards for unsecured
credit are described in Attachment L to the OA TT.
2. Sellers that do not meet the credit worthiness standards for unsecured credit will be
notified of the reason for the determination and shall be given the option to provide alternative security
acceptable to Idaho Power. In lieu of providing a cash deposit, Seller may establish an escrow
account, provide a letter of credit or provide guarantee of payment by another person or entity which
meets the credit worthiness standards for unsecured credit. Arrangements for alternative security must
be acceptable to Idaho Power.
CONSTRUCTION AND OPERATION OF INTERCONNECTION FACILITIES
All Seller-Furnished Interconnection Facilities wil be constructed and maintained in a manner to
be in full compliance with all good utility practices, National Electric Safety Code, and all other
applicable Federal, state, and local safety and electrical codes and standards at all times.
The Seller shall:
1. Submit proof to the Company that all licenses, permits, inspections and approvals
necessary for the construction and operation of the Seller's Generation and Interconnection Facilties
under this schedule have been obtained from applicable Federal, state, or local authorities.
IDAHO
Issued Per IPUC Order No. 30179
Effective - November 20, 2006
AttäcIiineiif 1
Case No. IPC-E-08-5
Staff Comments
Q4125/08 Page 3 of 3
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF APRIL 2008,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-08-5, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
BARTON L KLINE
DONOV AN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bkline(ßidahopower.com
dwalker(ßidahopower.com
JOHNRGALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rgale(ßidahopower.com
SECRl~
CERTIFICATE OF SERVICE