20070323Comments.pdf

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201 South Main, Suite 2300
Salt lake City, Utah 84111
March 23 2007
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Ms. Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
Re:Comments of Rocky Mountain Power in Case No. IPC-O7-
Dear Ms. Jewell:
Rocky Mountain Power
, ("
RMP" or the "Company ), hereby submits for filing an original and
seven copies of Comments of Rocky Mountain Power in Case No. IPC-07-04.
Communications relating to this proceeding should be served on the following:
Dean Brockbank
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Dean. Brockbank~Pacifi Corp. com
Brian Dickman
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 84111
Brian.Dickman~Pacifi Corp. com
In addition, it is respectfully requested that all formal correspondence and Staff requests
regarding this material be addressed to:
By E-mail (preferred):datareq uest~pac ifi corp. com
By Fax:[phone]
By Regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Sincerely,
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Jeffrey K. Larsen
Vice President, Regulation
Enclosure
Dean Brockbank
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
FAX: [phone]
Dean.Brockbank ~ PacifiCorp.com
Attorney for Rocky Mountain Power
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO REVISE THE
PUBLISHED A VOIDED COST RATES TO
INCLUDE A DAILY LOAD SHAPE; AND
TO CLARIFY THE RULES GOVERNING
ETITLEMENT TO PUBLISHED AVOIDED)COST RATES
CASE NO. IPC-O7-
COMMENTS OF ROCKY
MOUNTAIN POWER
COMES NOW Rocky Mountain Power, a division of PacifiCorp ("RMP" or the
Company ), by and through its attorney of record, and respectfully submits the following
comments in response to the Idaho Public Utilities Commission s ("Commission ) Notice of
Comment Deadline in the above referenced matter.
BACKGROUND
Idaho Power Company ("Idaho Power ) has requested that the Commission issue an order:
(1) Revising Idaho Power s published avoided cost rates paid to Qualifying Facilities ("QF'
to recognize the difference in value between energy delivered by QFs during heavy load
hours and energy delivered during light load hours; and
(2) Clarifying 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.
COMMENTS OF ROCKY MOUNTAIN POWER
The Company files these comments in support of Idaho Power s Petition. In the near future,
the Company will seek approval of similar changes, which are necessary to protect its Idaho
customers from paying too much for wind QF generation.
COMMENTS
Revising the published rates to include payment differentials for energy delivered during
heavy load hours and light load hours.
Rocky Mountain Power agrees with Idaho Power that energy has a different value based
on seasonal and time of day deliveries. Currently, both the Company and Idaho Power pay the
same price to a QF that delivers entirely during light load hours as a QF that delivers entirely
during heavy load hours. This payment is not appropriate as it does not provide proper
incentives to QFs, and is neither fair to customers nor to the QF because it could result in either
under or overpayments for the value of the power. Recognition of this difference was the 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-
Rocky Mountain Power agrees with Idaho Power that the calculation of avoided cost will
be unaffected by allowing the payment differential. The differential will only affect the way that
avoided costs are paid. Likewise, a QF that delivers energy at a constant delivery rate would not
be affected by the payment differential.
Rocky Mountain Power also believes the method of calculating the on-peakloff-peak
differential proposed by Idaho power provides a reasonable measurement and should be adopted
by the Commission. However, the Commission should also recognize that due to geographic
differences among utilities it may be appropriate to use different market hubs or combination of
market hubs.
COMMENTS OF ROCKY MOUNTAIN POWER
CONCLUSION
Based on the foregoing, Rocky Mountain Power supports the changes requested by Idaho
Power and recommends Commission adoption of those changes. The Company respectfully
requests that the Commission acknowledge in its order that the type of changes proposed by
Idaho Power are applicable to all electric utilities within its jurisdiction. To the extent any
company-specific information is necessary, Rocky Mountain Power will provide that
information separately.
All communications regarding these comments should be directed to Brian Dickman at
[phone].
Respectfully submitted this 23rd day of March 2007.
Dean Brockbank
Attorney for Rocky Mountain Power
COMMENTS OF ROCKY MOUNTAIN POWER
CERTIFICA TE OF MAILING
I HEREBY CERTIFY that on the 22rd day of March, 2007, I served a true and correct
copy of the foregoing COMMENTS upon the following named parties by the method indicated
below, and addressed to the following:
Monica Moen, Attorney II
Barton L. Kline, Senior Attorney
Idaho Power Company
PO Box 70
Boise, ill 83707-0070
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise; ill 83702
Peter J. Richardson
Richardson & O'Leary PLLC
515 N. 27th Street
PO Box 7218
Boise, ill 83702
Dr. Don Reading
6070 Hill Road
Boise, ill 83703
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COMMENTS OF ROCKY MOUNTAIN POWER