20080221Reconsideration Petition.pdf

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ATTORNEYS AT LAW
Peter Richardson
Tel: [phone] Fax: [phone]
pete rfi rich ardson an dol cary. com
P.O. Box 7218 Boise,ID 83707 - 515 N. 27th Sr. Boise, ID 83702
February 21, 2008
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise ID 83720-0074
RE: Case NO.IPC-E-07-13
Dear Ms. Jewell:
Enclosed please find an original and seven (7) copies of the EXERGY
DEVELOPMENT GROUP OF IDAHO'S PETITION FOR RECONSIDERATION.
I have also enclosed an extra copy to be service-dated and returned to us for
our files. Thank you.
Sincerely,~ ÛA~\
Nina Curtis
Administrative Assistant
enc!.
.
Peter J. Richardson ISB 3195
RICHARSON & O'LEARY PLLC
515 N. 27th Street
PO Box 7218
Boise, Idaho 83700
Telephone: [phone]
Fax: [phone]
peter(frichrdsonandolear .com
Attorneys for Exergy Development Group of Idaho LLC
ECE
FEB 2 I Pi'll.: 08
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
EXERGY DEVELOPMENT GROUP OF
IDAHOLLC,
PETITIONER
VS.
IDAHO POWER COMPANY,
RESPONDENT.
)
) CASE NO. IPC-E-07-13
)
)
) EXERGY DEVELOPMENT GROUP
) OF IDAHO'S PETITION FOR
) RECONSIDERATION
)
)
COMES NOW, Exergy Development Group ofIdaho LLC ("Exergy") by and through
its attorney of record, Peter J. Richardson, and pursuat to Rule 331 of the Commission's Rules
of Procedure and respectfully lodges its Petition for Reconsideration of Order No. 30493.
I
SUMMARY
Rule 331.01 requires that a petition for reconsideration specify the grounds why the
petitioner contends that the order is "erroneous" or "unlawful" or "not in conformity with the
law". As set out in more detail below, Exergy respectfully submits that Order No. 30493 is
unawfl and not in conformity with the law in that it violates a fudamental tenant of regulatory
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E-07-13
1
law known as the "fied rate doctrine." Idaho Power's unlateral adoption of the FERC
interconnection process for application to Idaho PUC jurisdictional interconnections was done
without ths Commission's review or approval as required by Idaho Code Sections 61-305, 61-
313 and 61-315.
Furhermore, the Commission's order is erroneous in that it misquotes Schedule 72 in
such a way as to change the meanng of that tarff in a significant way. In the ordering paragraph
of Order No. 30493 the Commission finds that:
the estimates of transmission upgrade costs provided to Exergy . .. to be the "initial cost
estimates" (sic) required under Idaho Power tariff Schedule 72.
At page 7.
Schedule 72 is misquoted in the Order in such a way as to change the plain meaning of
that taiff. Schedule 72 does not allow for "initial cost estimates" in the plural as quoted in the
Commission's order. Schedule 72 contemplates "an initial cost estimate" - in the singular.
Changing the word "estimate" to "estimates" changes the meaning of the tarff schedule in a
subtle, albeit significant way.
II
ADDITIONAL PROCEEDINGS
Order 30493, by its own terms, demonstrates that Idaho Power has been operating outside
of its taiff. The.Commission ruled that:
To achieve greater transparency between the Company's taiffs and implementation
policy, however, we find it reasonable to require the Company to propose additional
language to its Schedule 72 tariff. The additional language 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
Exergy Development Group ofIdaho's Petition for Reconsideration IPC~E-07-13
2
interconnection process, and (3) opportties to qualify for and provide alternative
financial guarantees in lieu of full prepayment of the initial cost estimate.
Order No 30493 at page 6.
It is certinly reasonable to explore these issues in detail in order to craft a
comprehensive and understadable interconnection rule for Idaho Power. However, the fact that
the Commission believes it necessary for Idaho Power to embark on this additional path in order
to make the interconnection process "reasonable" suggests that thecUIent method for
interconnections is NOT reasonable. Exergy seeks reconsideration on the scope and extent of
additional filing Idaho Power has been asked to make. Among the questions that need to be
addressed are: (1) Wil the additional filing be in the natue of a rule makng that has generic
implications for all jurisdictional utilities in the state? (2) Wil the fiing be in the form of a new
tarff in which interconnection customers will have an opportunity to have input? (3) Wil the
additional filing be, as implied, simply an extension of Idaho Power's "internal administrative
template" id at p. 6 which is not approved by nor examined by the Commission and in which
interconnection customers have no opportity for input?
The Commission's goal of "achieving greater transparency between the Company's
taiffs and implementation policy" is vague and Exergy seeks clarification of the Commission's
intent with respect to its goal of "transparency." The Company's "implementation policy
template" is apparently to simply adopt FERC's rules, yet this Commission has not approved
. FERC's rules. Furhermore, interconnection customers have not had the opportity to
paricipate in, or even review in advance, the development ofthe Company's implementation
policy. Ifby "greater transparency" the Commission means nothing more than to continue to
allow Idao Power to unilaterally decide what process it chooses to adopt with respect to
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E~07-13
3
interconnection, then Exergy respectfully submits that the Commission's order is unlawf in
that it would abdicate its oversight obligations as a regulator. Ifby "greater transparency" the
Commission means that it intends to exercise its regulatory authority over Idaho Power's
interconnection process, then Exergy seeks reconsideration relative to the questions noted
immediately above.
III
FILED RATE DOCTRIE
The fied rate doctrine is routinely used by the Commission to protect the utilities it
regulates from claims by ratepayers for favorable treatment with respect to rates. For example,
as recently as last September, the Commission issued an order in an under-biling dispute
between Idaho Power and a ratepayer who was inadvertently under-biled for several years. In
that order the Commission made clear that the utility has no choice but to reach back and correct
the under-biling regardless of the hardship or mitigating claims by the ratepayer:
The filed rate doctrine is a basic principle of utilty regulation that was embodied in
Idaho Code §§ 61-313 and 61-315 shortly after the tur of the 20th Centu when our
Public Utility Laws were first adopted (1913). It has a long history and precedent with
the federal regulatory system and the United States Supreme Cour. Simply put, the fied
rate doctrine states that a utility may charge only the approved rates and charges it has on
file with its regulatory body, i.e., its approved taff on file with the Commission. It
means the utility canot charge more, and also that it canot charge less that its fied rate.
Idaho Code § 61-313 provides that no public utility shall collect or receive greater or less
or different compensation for any service rendered to the public than the rates and
Exergy Development Group ofIdaho's Petition for Reconsideration IPC~E-07-13
4
charges applicable to such service as specified in its tariffs on file with the Commission
and in effect at the time.
Phillps v. Idaho Power IPC-E-07,.1 at pp. 6-7 (2007).
The Idaho PUC Laws very unequivocally require that every charge, every rule, every
regulation and every rate that is charged or imposed by a regulated utility be on file with and
approved by the Commission in order for that charge, rule, regulation or rate to be legally
enforceable. Allowing regulated utilities to charge rates or impose rules that are not approved by
the Commission defeats the very purose of having a public utilities commission in the first
place. The legal requirements are clear, and encompass all aspects of utilty service:
Under such rules and regulations as the commission may prescribe, every public utilty
other than a common carrier shall file with the commission within such time and in such
form as the commission may designate, and shall print and keep open to public inspection
schedules showing all rates, tolls, rentals, charges and classifications collected or
enforced, or to be collected or enforced, together with all rules, regulations, contracts,
privileges and facilities which in any maner affect or relate to rates, tolls, rentals,
classifications or services
Idaho Code § 61-305
There can be no doubt that FERC's interconnection rules are encompassed in the above
statute which requires that all rules, regulations, contracts, and privileges be on file with the
Commission. Idaho Code Section 61-313 explicitly prohibits a regulated utility from deviating
from the rules it has on file with the Commission:
Except as in this act otherwise provided, no public utility shall charge, demand, collect or
receive a greater or less or different compensation from any product or commodity
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E-07-13
5
fushed or to be fuished for any service rendered or to be rendered, than the rates,
tolls, rentals and charges applicable to such product or commodity or service as specified
in its schedules on file and in effect at the time.
Idaho Power has been forthright in its admission that it is using rules, regulations and charges for
interconnecting customers on its system that are not on fie with the Commission and that have
not been approved by the Commission. The Commission's finding simply does not pass muster
when held up against the clear and unequivocal requirement that every rate-toll-rental-charge-
classification along with every rule-regulation-contract-privilege-facility that in any maner
affects or relates to rates-tolls-rentals-classifications or services be on file with and approved by
the Commission.
In spite of the clear requirement that Idaho Power's rules relating to customer
interconnections be filed and approved , the Commission found that:
We do not find the Company's use ofFERC's small-generator interconnection rules as an
internal administrative template for QF interconnection requests to be inconsistent with
Schedule 72.
Order No. 30493 p. 6, emphasis provided. It is irrelevant whether Idaho Power's "internal
administrative template" is or is not consistent with Schedule 72. The fudamental question that
must be answered before any utility may impose rules (interconnection or otherwse) is whether
they have been fied with, and approved by, the Commission. FERC's small-generator
interconnection rules have not been fied with nor have they been approved by the Commission.
The very notion of "internal administrative template ( s)" replacing the thoughtful deliberative
process of this Commission's rate and service regulation duties is anathema to the concept of
permitting state sanctioned regulated monopolies to exist in the first place.
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E-07-13
6
Order No. 30493 only addresses this issue head on in a single sentence:
Exergy contends that use of the FERC rules as a template by the Company to achieve
unformity in practice requires Commission approval. We disagree.
Order No. 30493 p. 6, emphasis provided. With that two word sentence, the Commission
appears to have endorsed Idaho Power's use of internal administrative templates as a
replacement for Commission regulation of this public utilty service (customer interconnections.)
Although not conceding that Idaho Power's "internal administrative template" is a rule that the
Commission must approve before it may be imposed on Idaho Power's customers, the
Commission stated that:
To achieve greater transparency between the Company's tariffs and implementation
policy, however, we find it reasonable to require the Company to propose additional
language to its Schedule 72 tariff. The additional language should describe in general the
three-step study process that the Company follows including (1) opportunities to pay for
additional required studies on incrementa amounts, (2) opportties to exit the
interconnection process, and (3) opportities to qualify for and provide alternative
financial guarantees in lieu of full prepayment of the initial cost estimate.
Order No 30493 at page 6.
In addition to the issues raised by this requirement noted in Section II above, it appears
that the Commission, by requiring Idaho Power to "propose additional language" to its Schedule
72 does understad that Idaho Power has, in fact, adopted a rule (a.k.a. "internal administrative
template") that requires Commission review and approvaL. However, the Commission's request
for "additional language" is no more than a small step to a full review of all of Idaho Power's
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E-07-13
7
"internal administrative templates" as they relate to the provision of interconnection services that
are within this Commission's regulatory perve.
iv
SCHEDULE 72
The Commission, in Order No. 30493, attempts to shoehorn all of FERC' s detailed and
complex integration rules into Schedule 72 by finding that:
The Commission finds the "estimated cost of all required upgrades" amounts included in
the generator interconnection feasibility studies provided Exergy to be the "initial cost
estimate" required by the Company's Schedule 72 tariff.
Order No. 30493 p. 6.
Assuming the Commission's finding is correct, that the initial cost estimate required by Schedule
72 is satisfied by Idaho Power's provision of a cost estimate pursuant to a Feasibility Study, then
the interconnection process would cease at that time and Idaho Power would be required to
commence construction upon the payment by the developer of that initial cost estimate.
However, the initial cost estimate is not used by Idaho Power as contemplated in Schedule 72.
After receipt of what Order No. 30493 has found to be the initial cost estimate pursuat to
Schedule 72, Idaho Power then goes beyond Schedule 72 and requires a developer to proceed to
execute a System Impact Study Agreement which is not approved by the Commission or even
mentioned in Schedule 72. The System Impact Study Agreement requires the developer to post a
deposit which is not approved by the Commission or even mentioned in Schedule 72. Upon the
conclusion ofthe System Impact Study, the developer is then required to enter into a Facility
Study Agreement which is not approved by the Commission and not even mentioned in Schedule
72. The Facility Study Agreement requires the developer to post a deposit which is not approved
by the Commission or even mentioned in Schedule 72. Indeed, none of the agreements Idaho
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E-07-13
8
Power requires developers to sign - the Feasibility Study Agreement, the System Impact Study
Agreement, nor the Facility Study Agreement have been fied with or approved by the
Commission. Adoption ofFERC's small-generator interconnection rules goes well beyond the
interconnection process approved by this Commission in Schedule 72.
V
CONFUSION AND INCONSISTENCIES
Allowing Idaho Power to unilaterally choose to use FERC's interconnection procedures
for small-generator interconnects creates uncertainty and confusion. For example, FERC's small
generator interconnection procedures contain different insurance requirements than are contained
in Schedule 72. FERC's small generator interconnection agreement only requires insurance to
be obtained by the interconnect customer at levels that are "suffcient to insure against all
reasonably foreseeable direct liabilities given the size and nature of the generating equipment
being interconnected." Article 8 FERC Small Generator Interconnection Agreement. ("SGIA")
The interconnection agreement contained in Idaho Power's Schedule 72 requires liability
insurance in the amount of $1,000,000 for each occurence. Paragraph 7.1 Idaho Power
Company Uniform Interconnection Agreement (PURPA). ("UIA") Idaho Power has adopted
FERC's interconnection application process, which is designed to result in a completed FERC's
interconnection agreement. However Idaho Power does not use FERC's interconnection
agreement, it uses the interconnection agreement in Schedule 72 - even though it uses the FERC
interconnection application process. If this Commission finds it reasonable for Idaho Power to
use FERC's interconnection process then the Company should be required to use the entire
package of FERC interconnection documents and not pick and choose, without Commission
oversight, which par of the FERC interconnection process it wants to use.
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E-07-13
9
Another example of an inconsistency between FERC's SGIA and Idaho Power's UIA is
that FERC's SGIA only requires the insurance company providing liabilty insurance to be
authorized to do business in the state where the interconnection is located. Idaho Power's UIA,
however requires a specific rating level for the insurance company providing liabilty insurance.
In both examples, Idaho Power uses the more restrictive and burdensome provision of its UIA
rather than the less restrictive and burdensome provisions found in FERC's SGIA. The
fudamental point, however, is that when this Commission defers to Idaho Power to select bits
and pieces ofFERC's interconnection process without oversight, then neither the interconnection
customer nor the Commission have any way of knowing in advance which bits and pieces Idaho
Power will choose to use and which it wil choose to leave out. Nor do the Commission or the
interconnecting customers know why and on what basis the Company has selected the provisions
it selects.
VI
UNCERTAINTY
An additional problem that arises when the Commission defers its ratemakng authority
to Idaho Power's "internal administrative template" is that it creates uncertinty as to exactly
what that "template" wil looklike at any given moment. For example Idaho Power's web site
for "Generator Interconnection Information" curently has the Schedule 72 Generator
Interconnection Agreement posted, however the word "DRAFT" is superimposed on each page
of that agreement. 1 The Generator Interconnection Agreement was approved by the Commission
in Order No. 30179 and it became effective on November 20,2006. It is not, according to the
Commission's order a "draft" agreement. Apparently, however, according to Idaho Power's
1 Attached as Attchment A is the opening page ofIdaho Power's Generation
Interconnection web site. The link at step 5(a) opens the Schedule 72 Generation Agreement
which is attached as Attachment B.
ExergyDevelopment Group ofIdaho's Petition for Reconsideration IPC-E-07-13
10
"internal administrative template" process, the Commission approved agreement is now
relegated to "draft" status. The uncertainty engendered by such conficting information is
causing developers to look to other states to do business in. That is why it is compellng for this
Commission to exercise its authority over the entire interconnection process and enforce and
enact detailed rules that Idaho Power and interconnection customers must follow in order to
complete a transparent and workable interconnection process.
In addition to being denominated "draft," the Generation Interconnection Agreement
posted on Idaho Power's Interconnection Web Site contains new language that is not in the
Generation Interconnection Agreement that was approved by the Commission in Order No.
30179. For example, there is an entirely new Attachment 4 and an entirely new Attchment 6 in
the "draft" Uniform Interconnection Agreement posted on Idaho Power's web site. These two
new sections contain significant substantive new interconnection requirements. Neither has been
reviewed or approved by this Commission. By allowing Idaho Power to utilize "internal
administrative templates" to set its interconnection policy apparently gives the power company
license to make modifications to the Commission approved tariff without prior Commission
authorization. It also creates uncertainty and ambiguity as to the interconnection terms and
conditions a customer will encounter at any given moment. The question raised in this Petition
for Reconsideration is not whether the additional language in Schedule 72 is reasonable or
desirable, the question raised by such unauthorized modifications is whether they should have
the benefit of Commission and customer input and review.
VII
CONCLUSION
F or the forgoing reasons and in the fuherance of good ratemaking policies, Exergy
respectfully requests this Commission to reconsider its decision in Order No. 30493 and grant
Exergy Development Group of Idaho's Petition for Reconsideration IPC-E-07-13
11
the prayer for relief contained in its Complaint that initiated this proceeding. Exergy believes
that reconsideration may be prosecuted through the use of legal briefs and does not believe an
evidentiar hearing is required.
RICHARDSON & O'LEARY PLLC
fdaBy
Peter J. Richardson
Attorneys for Exergy Development Group
of Idaho
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 21rd day of Februar, 2008, a true and correct copy of
the within and foregoing PETITION FOR RECONSIDERATION, was served by personal
service to:
Baron Kline
Monica Moen
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
Jean Jewell
Commission Secretar
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83702
uw..tv\ dt \
Administrative Assistat
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E-07-13
12
Peter J. Richardson ISB 3195
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
PO Box 7218
Boise, Idaho 83700
Telephone: [phone]
Fax: [phone]
peter(frichrdsonandolear .com
Attorneys for Exergy Development Group of Idaho LLC
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
EXERGY DEVELOPMENT GROUP OF
IDAHOLLC,
PETITIONER
VS.
IDAHO POWER COMPANY,
RESPONDENT.
)
) CASE NO. IPC-E-07-13
)
)
) EXERGY DEVELOPMENT GROUP
) OFIDAHO'S PETITION FOR
) RECONSIDERATION
)
)
ATTACHMENT A
Exergy Development Group ofIdao's Petition for Reconsideration IPC-E-07-13
JoUQJiV .iVWl;l - rtOUUi us -lJOing .tusiness With Us - Generator Interconnection Informati... Page 1 of2
Employment
Company InrormatÍ(m
Community
llmployee Portl
Doing BusinliSS WíUl Us
PlJrthuing Terme
Generation Interconnect
Tranemis..ion ServiCe.
RFP
Ancllary Seces
P_iiimeroi Fish Halchltry
Rlliiiatory Information
Generator Interconnection information
Generators and potential generators who wish to connect to Idaho Power Company's electrical system
wil find the following information and links helpfuL. Applications are placed in the queue and are
procesS~d on a first come, first serve basis. View the aPPliçatìQn fist. This link wil take you to the
OASIS site. From the left menu bar, click "Generation Interconnection" and then "Generation
Interconnecton Queue."
Net Metering (less than 100KW) Appliçatjon (POE, 30KB)
Sche(jt.leS4 for Idaho (POE, 102KB)
SChe(jIJle.72 for Idaho (POF, 279KB)
Generators less than 20 l\
Requirements for GeDergtorlnterconnectioii (PDf, 156KB)
Process for Generators less than 20 MW Small Generator int¡orconneetion
ProcedlJres (PoE 149KB)
Step 1: Tbe iatefg¡nnecl;oOAppl¡ç¡tiQf! (PDF, 45KB) must be completed and submitted
for all Generator Interconnections to the Idaho Power System.
Step 2: teasiQillYAoa!Y;¡fs (POE. 21KB) includes general review of system impact,
capacity constrints and possible problems with the customer's choice of point of
interconnection.
Step 3: $Ys!£rn ImpactStIJdy (PDf, 24KB) provides a detailed assessment of thetrnsmission system adequacy to accmmodate the application. This step may not be
necessary for some project depending on size and location of the project.
Step 4: Façjliy$tU9Y (f?OE, 36KB) includes design and engineering studies to
determine the design and specifications. Constrction options are provided to the
customer.
Step 5: Interconnection Agreement all project less than 20 MW are subject to
technical requirement under the Interconnection Agreement once the project becomes
operational.
a) PLJRPAJnJerCQnoe.etion Agreement (PIA) (POE, 1M) wil be filed with the Idaho Public
Utilities Commission under Idaho Power's Rate Schedule 72.
b) SIl¡lI! Gener.gtorlnlerCoririegiopAgreelleiit (SGIA) (POP, 111KB) an SGIA must be
filed with the FERC for all project less than 20 MWwho are sellng energy off-system.
Generators greater than 20MW
Large Generator Interconnection Procedure~s (eDF, 299KB)
Related Links
Transmission Services
Federal Energy Regulatory Commission (FERC) rules
Idaho Public Utilties Commission (I PUC)Idaho Power's Integrated ,Resource Plan (IRP)
idaho Power Company Rate Schedules
Primary Contacts
Generator Interconnection - Physical Connecton to the Wires
Rowena Bishop
htt://ww.idaopower.com/aboutu/business/ generationInterconnect/2/21/2008
Idaho Power - About Us - Doing Business With Us - Generator Interconnection Informati... Page 2 of2
208-388-2658 (voice)
208-388-5504 (fax)
rbistiQ~tiAQWj!LçJlm
Net Meter Applications
Candace Gentry
208-388-2276 (voice)
208-388-6647 (fax)
çg~i:lQ$LQ!er.CQm
çastcimerSeiylçe I fE_Qergçenter I NeWSfQciff I RiyeJi&ReçreiiiiQQ I ,lP9aLl1s
ÇQDJii~U'¡_s I Si!itM-lllI IDAc_QBE I l:!cime I Si1U~J2e.c
Copyright ii 1995-2008 Idaho Power Company
All rights reserved_ Revised on 1/24/2008_
SHE-
htt://ww.idahopower.comlaboutus/business/ generationInterconnect/2/21/2008
Peter 1. Richadson ISB 3195
RICHASON & O'LEARY PLLC
515 N. 27th Street
PO Box 7218
Boise, Idaho 83700
Telephone: [phone]
Fax: [phone]
peter(frichrdsonandolear .com'
Attorneys for Exergy Development Group of Idao LLC
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
EXERGY DEVELOPMENT GROUP OF
IDAHOLLC,
PETITIONER
VS.
IDAHO POWER COMPANY,
RESPONDENT.
)
) CASE NO. IPC-E-07-13
)
)
) EXERGY DEVELOPMENT GROUP
) OF IDAHO'S PETITION FOR
) RECONSIDERA TrON
)
)
ATTACHMENT B
Exergy Development Group ofIdaho's Petition for Reconsideration IPC-E-07-13
Idaho Power Company Generar Interconnecion Agreement # XX
l.P.U.C. Nt). 28. Tar No. 101
GENERATOR lNT
Seh
ENT
JEeT
Effctve Date:
Issued by ICWO PQWER COMPANY - Delivery Busines Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Power Company Generator Interconnection Agreement # XX
I.P.U.C. No. 28, Tari No. 101 Page 1 of9
TABLE OF CONTENTS
RECITALS ................................................................................................................................................1
AGREEMENTS.........................................................................................................................................1
1. Capitalized Terms................................................................................................................... 1
2. Terms and Conditions .............................................................................................................1
3. This Agreement Îs not an agreement to purchase Seller's power..... .... ............. ........... .......... 1
4. Attachments ............................................................................................................................1
5. Effive Date, Term, Termination and Disconnection. .............................................................2
5.1 Term of Agreement. ..........................................................................................................2
5.2 Termination. ......................................................................"...............................................2
5.3 Temporary Disconnecion ......................................;'o.;...:...;,i:.;..........................................2
6. Assignment, Liability, Indemnity, Force majeure, Co~entiâli~mages and Default........5
7. Insurance. ................................................................................................................................7
8. Miscellaneous. .. .... ....... ........ ....... .... ...... ...... ... .....~....... ..... ..... ........ ......;.......... ....... .......... .... .... 7
9. Notices. .....................................................................................................,.............................8
10. .' Signatures. ............................................. ......d...;........................................... ............................9
Attchment 1. ............................................................ .:,;....................................................... .........................1
Point of Interconnection .......................................;,........................;....................................................1
Ge~~ral ......~~~&?tion..;.......................r..........;. . i ........................................................1
Point of rie ~f OWersh~p ....................................:;. ..........................................................1
Attachment 1 _ Exhibit 1................. ........................................................1
Attchment 2............................................ ..2... ........................;...f.;........................................................1
Attachnlent .3...............................................::.. ...::.::.....;........................................................................1
Milesones. . . .. .. .. . .. . .. . . .. . . .... ... .. . . .. .... ...... ...... .. . ..... . .i'............. .. ... ... ................... . .... " . .. .. .. .................. ... 1
Attachment4.................;....................d.;...,.............~.t.d.....................................................1
SecuriArrang.~me . ..or:;.....................................................;........................1
Reliabilty Manage . .... .... ............ ..... ...... ......... ......... ............. ................1
Attchment 5............. ..... ..... .... ... .... .... .. :;;.;!~.. ..... ....... :..,.... .. .. ............ . " .. . . .... ........ .. .... ....... .. . ... .. .......... .......... 1
Reactive Power..~~quirements.;..........................:............................................................................1
Interconnection R~~~rement$if~a Wil'cj Gen ........ Plant......... ...... ....... ...... ......... .................. .....1
Attachment 6.................... .......;.; ....t;...... .... ... ';." ..,. .... .... . . ...... .......... . ...... .. .... . .... .. .. .... ........ . .. . ........ .... 1
Inter. Custo~rCOnstction R ibilty and Transfr of Ownership ............ ........ ....1
Attachibì1............. ..... ............................................................................................................ 2
ent 1.......................................................................................,..............................................3
~:~~Îbit 4..................... .............. .:. ................................................................................ .......................3
~j.r Facility List ..............................................................................................................................3
Effective Date:
Issued by 1DÄHO POWER COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Power Company Generator Interconnectn Agrnt # XX
I.P.U.C. Ng. 28, T_ No. 101 Page 1 of9
This Gereraor Interconnecon Agret ("Agreeme) under Idaho Power Company'sSeu:le 72 i§ etcte as of the _ day of , 2007 beeen
, ("sefl or "tnteroonection Custmerj ar:d Idao Power
~~ - ~~()~, or "Tran$mision Owet).
RECITIALS
a Geeraoo Facilit that
72 an any SUC(SS
ß. ~ ~~ Fap cpvere by ibis A~ is ~ partcularly descrbe inAttachment 1. ," . ."
for &eNice under Idaho
AG~NTS
3.
Pluichas ofag~.COl"y and S,
. .Ri;ve the sae in Soherul 72 or in the bod
ofthis
and coitons under which the
'11 wi, th Company'ssa de ning in
, . .reement and'idule 72,
.wer.
wi b,é cpve(ed (.Ðder separate
any othr agrement between the
A.by refence are "b folowig:
and Cos of the Gepralin Fa, Intercnnection
. e Ditgrm Deicting the Geeration Faclit, Interconnection
and Upgraes.
- Miiones For Interonnect the Gen,tion Faplit.~t4-A
Sy N~ tJ Suppo the
uiremei:~ for the Compny's Transmisson
Faoiit.
~t 5 - Reactive Power.
~t 6 - Descriptn ef Upgrades reuired to integrate the Generation Facilty and
Best Estimate of Upgrade Costs.
Effectve Date:
ISSue by IDA:HQ POWER COMPANY - Delivery Business Unit
Tes Park, Manager, Grid Operations
Issd on:
Idaho Power Company Generator Interconnection Agreement # XX
I.P.U.C. No. 28. Tarif No. 101 Pag 2 of9
5. Efftie Date. Term, Terminatin and Disconnecton.
5. 1 T en .of Agreement. Unless terminated earlier in accodanc with the provisions
of this Agreement, this Agreement shall become effectve on th dare spcíf:i above and
remain effective as long as Seller's Generation Facilit is eligible for seNice under Schedule 72.
5.2 Termination.
5.2.2 After a Default, eiter Part ma
Section 6.5.
ent upon expition or5.2.1 Seller may volunty termnat this
termination of an agreement to sel power to the Co
is Agreement pursuant to
5.2.3 Upon termination or expi
Facilit will be disconnected from the
termination or expiration of this A
and obligations, owed or contnuing
Section shall sUNive termination or expi
elJeseenèraon
system. The
its liabilites
ions of this
.'Jion shall continue only for so
Good UtiJity Practiæ mèans any of
of the eletrc
cts which, in the
e the decisio was made,
a reasonable cot cosistent with
edit. ood Utilit Practice is not intended
act to the exclusion.of all others, but rather to
Ily accepte in th reion. Goo Utilit
C requirement, Payment of los revenue
vemed by the power purchase agreement.
5.3.1 E. enc Conditons. "Emergency Conditn" means a condition or
situation:. ) th rUdgment of the Part making the claim is imminently likely to
endanger pn (2) that, in the case of the Company, is imminently likely (as
determined on inatory manner) to cause a materil aderse effect on the
security of, or damage to the Company's trnsmission/distrbution system, the
pany's InterOnnection Facilties or the equipment of the Company's customers; or
at, in thèæ:se of the Seller, is imminently likely (as determined in a non-
discminatory manner) to cause a material adverse eff on th reiabNit and securiy
of, , the Generation Facilit or the SeJler's Intercnnection Facilties. Under
Em ditions, eier the Company or the Seller may immediately suspend
interconnecton seNice and temporarily disconnect the Generation Facilit. The
Company shaJl noti the Seifer prompty when it beomes àW'are of an Emergency
Condition that may reasonably be expected to affct the Seller's operation of the
Generation Facilit. The Seller shall noti the Company promptly when it becomes
aware of an Emergency Conditon that may reasonably be expeed to affect the
Company's equipment or seNice to the Company's customers. To the extent
information is known, the notication shall describe the Emergency Condition, the extent
Effectve Date:
Issued by IDAHO POWER COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Power Company Generaor Interconnection Agreeen # XX
I.P.U.C. NÐ. 28, Tifft No. 101 Pag 3 of9
eff on the operation of both Parts'ti,. and the ~ oorre acton.
5~S.2 "~in~~~ dinae the..~ ~~~n
and ~iFs on th Company's
calendar year,
t Facilit1yagr asPar ~natio as to the
maintenance wil take into
reuirements and the SeHers
wihold accptance of the
y shaH, to the
system and
eeusly. Seller
prevent damage
In some cases,bae-UP Idaho Powers
such relays anRuaJy and Seller will pay the
Duling any føro øuge, th Company may suspend
eff imm:eæ re(l (¡f1 the Company's
. The Copany shall use reaSOaB/ efrts to provide
is l' given) th Coany shall, upon request,
afr the fad exp/aÌIIß the circumstances of
. Th Compay smlJ nd the SeHer as soon
. f. Præce, opratiR æ the Sellers Generation
OF deteoæt of seNi to ~r cuers served frm
the ~ ~ sYSf, OF if C:1! th GeoR Fao oolJcause damage to
the Company's transmission/disbutn system or other affte systems. Supportingd~ reoo th æqaiøn nec shaH be provided to the Seller
f1, th 8eer to reme the adv.roperating effct
bi tie, th ComparN may disoonti the Generatin Facilit. The
provi th Sel wi resoable no of such diconnectin, unless
the p~vísiøn of Artcle 5.3.1 appy.
Effectve Date:
1$S GY IQAHO POWE COMPANY - Delivery Business Unit
Tess Park, Manager, Gnd Operations
Issued on:
Idaho Powr Company Generator Interconnection Agrmen # XX
J.P.U.C. No. 28. Tar No. 101 Page 4 of9
5.3.7 MQdon of th Geti Facilit The Selr must receive written
autoriation from the Company before making any change to the Generation Facilit
that may have a material impact on the safety or reliability of the Company's
transmission/distbuon system. Such authoriatn shall not be unreasonably withheld.
Modrfcations shall be done in accordance with Good Utiity Practice. If the Seller makes
such modificatiøn without the Çompany's prior wrien autriatin, the latter shall have
the nght to temporariy discnnect the Generation Facilit.
5.3.8 Repon. The Parties shall cooerate
Generation Facilit, Interonnecion Fa
transmissiondistbution system to their noral
practicable following a temporary disconnectn.
5.3.9 Voltge Leve. Seller, in
minimize voltage fluctuations and main
Idaho Power may, in accordance with
(180) days' notice to the Seller, c
ten percent (10%) at the Point of
Power's expense, Seller's eqfJpme
nominal operating voltage level.
Utiit Practices, shall
to Idaho Power.
hundred eighty
i by more thanSeHer ïf, at Idaho
accommodate the modrfed
5.4 Land Riht.
grants to Idaho Power for the
sements to install, operate,
Equipment, Interconnection
nd other Speial Facilities
cluding adequate an continuing access rights
that it has procure sufient easements and
vie Idaho Power wi the access described
mems or nghtsof-way shall be subject to
rm.
Useo! Public Ri hts-of-Wa. The Partes agree that it is necessary to
and operating impacts that would occur as a result of
nstrcted in close proximity. Therefore, subject to Idaho
raph 5.4.4, Seller agres that should Seller seek and
ai, or federal govemmental boy the right to erect, construct
furnished Interconnecon Failiies upon, along and over any and all
and highways, then the use by Seller of such public right-of-way
to any future use by Idaho Power of such public nght-of-waý for
r màintenance . of elec distnbutn and trasmission facilties and
ay claim use of such public right-of-way for such purposes at any time.
Except required by Paragraph 5.4.4, Idaho Power shall not be required to
compensate Seller for exercising it rights under this Paragraph 5.4.2.
5.4.3 Joint Subject to Idaho Power's copliance withPararaph 15. us and attach it distbuton and/or transmission
facilites to Seller's Interconecon Facites, may renstct Seles Interconnection
Facilities to accommodate Idaho Power's usag or Idaho Power may construct its own
distnbution or transmissiøn facilities along, over and above any public nght-of-way
Effective Date:
Iss by IDAHO POWER COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Power Comii
I.P.U.C. NQ. 2ß Tar f'. 101
Generator Interconnen Agreent # XX
Palje 5.of 9
fi $elkN plJ1SlJ.ant to Pa h 5.4.2, aichin Seller's Intercnnecon
to. $:Gh ræ . Except as reuIre by Paragrah 5.4.4,oo lie ~~ to dosate Seller ft ex~ it rihts undr
andSeJJr wi an interonec to /ias e~ prr tf) lfi Roer e~ .
6."~ "
6.1 AS3a11nt. This Agrement(21) ~~. ~ wnø antht:
witouttfe consent of the other
qrit rating and wihof th assigning Part
'at viotes this artcle is void and ineffctve.
it oblations, oor sh a Pas obtions be
reson thf. An a is Feonsib/ to meetinginsura SeHer. Wh i:uired,unreaso~ ..:, ~d ordeye.
Liabö:~ . Each Part's liability to th other Part for any loss, cost,
ÎÆdig reasna atNTey'S fees, relatifI to or arising from
rfo.rance of this Agrement, shall be limed to th amount of direct
. In no event shall either Part be liable to the other Par for any
uential, or punitwe damages, except as autoried by this Agreemnt.
6.3 Inde,.
6.3.1 This provison pæJcts each Par frm liability incurr to third partes as
a of carrin out the prvi of this Agreement. Liabili under this proviion is
ex; ,from th gènerlimits on IibTlt found in Arte $.2.
Issued by lMHO PO"WR COMPANY - Deliver Busines Unit
Tes Park, Manager, Grid OperaonsEffecve Dat: Issued on:
Idaho Powr Company Generator Interconnection Agreement # XX
I.P.U.C. No.. 28. tar No. 101 Pae 6 of9
6.3.2 The Parties shall at all times indemnif, defend, and hold the other Part
harmles from, any and aJdamages, losss, claims, includin claims and actions
relating to injury to or death of any person or damag to prope, demand, suits,
recoveries, costs and expenses, court costs, attorney fees, and all other obligations by
or to third parts, arising out of or resulting from the other Part's action or failure to
meet its obligns under this Agreement on behalf of th indemnifing Part, except in
cases of gross negligence or intentional wrorioing by the indemnifed Part.
6.3.3 If an indemnifed perso is entid to in
a result of a claim by a thir part, and the in
reasonable oppounit to prod undr this
claim, su indsifed pers may at the ex
seffle or CO/fsent to the entr of any judgment
Failure to defend is a Material8reach.
"'n under this article as
fails, after notice and
the defense of such
nifing Part contest,
pay in full, such claim.
6.3.4 If an indemnifng pa
indemnifed person harmless under
persn shall be the amount of
insumnce or other recovery.
and hold any
he indemnifed
net of any
6.3.5 Promptly
the commencement of
as to which the
shalf noti the indenifyl
shafl be a Materil Breach asuch failure or materi
d persn of any claim or notice of
r legal proceedng or investigation
ayapply, the indemnified person
of or delay in such notifcation
nifcaon obligation unless
l1gpart.
Agrment, "Forc Majeure" or "an event of
tro of the Seller or of the Company which,
is unable to preven or overcome. Forc
fire, flood, storms, wars, hostilites, civil
fires, lightning, epidemics, sabotage, or
pemtfon Date, which, by the exercise of
could not reasonably have been expec to avoid and by the
be unable to overcome. If eiter Part is rendered wholly or in
s under this Agreent because of an event of Force
d from whatever performnce is affected by the event of
non-performing Par shall, as soon as is resonably possible after
Force Majeure, give the other PaFt wren notice descrbing the
occurrence.
(2) The suspension of performance shall be ot no greater scope and of no
longer duration than is required by the event of Force Majeure,
(3) No abJigatis of either Part which arse before the occurrnce causingthe SUspension of performnce and could and slwuld have been fully performed
before such occurrnc shaN be excu s a result of such occurrence.
Effectve Date:
Issued by IDAHO POWER COMPANY - Delivery Busines Unit
Tess Park, Manager, Gnd Operations
Issued on:
Idaho Pow Cø
LP.U.C. tj2S.. TPf No. 101
6.5 _Elan ~ß~
Generatr Interconnection Agen # XX
Pag 7 of9
6.5.2 ~ iJachs. Th notice afr ffrA ~i..d in *
midst be GV~ as ex
7. Insl§ce.
During. th te of th Agreement, Seifer
insurance coverage:
7.1 CompFen. .
dama Vi /k
for SlOO instl16e s#alJ be
propel.
for both bodily injury and propert
bined $ingJe limil. T1 deucle
Utli practis for similar
Idaho Power as an addfnal insure and loss
Ida Power of Loss of Cove - If the insurr: coverage
lap for any reaso, Seller wi immediatey notif Idaho Power
¡se Idaho Power of the specif reason for the lape and the steps
fa th covera. Fai7ure to provide this notie and to expeously
reinst or the covera wil constiute grounds for a tepory disr:on under
Secn 5.3 and wRI be a Material Breach.
8. Mi~eous.
8. 1 Goemin Law. The valid, interpretàtion and enforcment of this Agrement
and each of its provisions shaH be governed by the law of the state of Idaho witou regard to
its conficts of law principles.
Effecve Date:
Issued by lQAHO POW4R COMPANY - Delivery Busines Unit
Tes Park, Manager, Gnd Operations
Issued on:
Idaho Power Company Generaor Interconnection Agreeent # XX
I.P.U.C. No. 28. Tar No. 101 Pæe80f9
8.2 Salva. No later than sixty (M) days air the termatn or expiration of this
Agrement, Idaho Power will prepare and forward to Seller an estimate of the remaining value
of those læho Power fumished Intemonnecton Facilites as require under Schedule 72 and/or
described in this Agrent, Jess th co of removal and transfer to Idaho Powers nearest
warehouse, if the Interconnectn Pacilries wiJl be removed. If Seller ejects not to obtain
ownership of the Intercnnection Facilis but instead wishes that Idaho Power reimburse the
Seller for sad Facítities the Seler may invoice Idaho Power for the net salvage value as
estimated by Idaho Power and Idaho Power shll pay such amount to Seller wihin thirt (30)
days after receipt of the invoice. Seer shall have the right to invoice amount against
any present or future payments due Idaho Power.
9. Notices.
9.1 Geal. Unles othrwse provid
demand, or reque required or authorized in co
deemed properly given if delivered in person,
or sent by first class mail, postge prepaid,
any writen notice,
t ("Notice") shall be
currier service,
IUo the Setter:
Interconnection Customer:
Attention:
Address:
Phone:
Billings and payments shall be sent to the addresses set
Attentn:
Address:
City:State:Zip:
Phone:Fax:
Effecive Date:
Issued by IDAHO POWER COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Pow Company
I.P.U.C. Nn.28. TnNo. 101
Company: lå~ho Powr Company - DeliveryAttntion: Deliry Finance .Addr~: ~~ ': 8S1'G2Phone: 2ß&~~38 emil: twitdahopower.com
Generaor Interconnecion Agreement # XX
Pag9.of9
IntrcORfldioA Cusemr's Oile&ti .~èprmate:
AltR:
Addres:
Cit:Stee:
Phone:
Part may change this informaton by
date of the change.
mes have cause this Agreement to be execed by their
res
Name:
Date:
For the Inteonecon Customer
Name:
Tit: Managr, Grid Oprations -Idaho Power Company, Delivery
Date:
Effe Date:
Issued by IDAHO PO'iR COMPANY - Delivery Busines Unit
Tes Park, Manager, Grid Operaons
Issed on:
Idaho Powèr Company Generator Interconnecton Agreement # XX
l.P.U.C. No. 28. Tarff No. 101 Pag 1 of 1
Attchment 1
Descption and Costs of the Generation Facit, .1ntercnen Facis an Metering
Equipment
In this attachment the Generation Facilit and Intercnection Facilites, including SpecialFacilities and upgraes, are itemized as bei wned Seller or the Company. Asprovided in Schedule 72, . . any will provide a best
estimate. itemized cost of its Intennection Facifis, incliiã,ing Facilities, upgrades and
Metering Equipment.
Interconnecion Deils
t under Idaho Power
. stornr) and Idaho
'on Project.
This Attachment 1 is a part of the Standard Generator Intercon
Company's Schedule 72 between
Power Company - Delivery
speifcally Generaor Interconnection
The Connection Point for the where the
A drawing identifying the point of interconn this Attmet 1.
Effective Date:
Issued by IDAHO POWER COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Power CeßlJ*Fl
I.P.U.C.N.o:,,28. Tar No. 101
Generaor Interconnen Agre # )Q
Paq 1 ,of 1
Attlment 1 - bhibit 1
Effctve Date:
iss by 19Ae POR COPANY - Delivry Busines Unit
Tess Park, Manager, Grid Operations
Issed on:
Idaho Power Company Generator Interconnection Agrement # XX
I.P.U.C. No" 28, Tarif No.. 101 Page 1 of1
~ttšlchrn~Qt2One-line Diagram Depicting theSmalJ GenerátJø PácHit, Interconnection Facilities, Metering
Equipment and Upgrades
Effectve Date:
Issued by IDAHO POWER COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issed on:
Idaho Powr CQmp~ny
I.P.LlC. tA~:~. Tar tj. 101
Generator IntrconnectionAQreent # XX
Pgg 1 of1
Mileones
~t3
r its contrction activities will be based upn act
Agree to by:
Dat.$
For the TransmIssion Provider
Idaho Powe Company, Delivery Date
ANY - Delivery BusInes Unit
ark, Manager, Grid Operations
Effcte Date:lssed on:
Idaho Power Company Generator Interconnection Agreement # :x
J.P.U.C. ~. 28. Tari No. 101 Page 1 of3
Attchmet 4
The Company shall also provide requirements that must be met by the Seller prior. to initating
parallel operatin wih the Company's Transmission System.
1. Definitions:
nd contol hardware and
d oprational securit. All
nected to the
nts Critical
the electric
infrastructure
Securit Arrangements Details
Infrastructure securit of Transmission Systm equipment and ope
softare is esntial to ensure day-to-day Transmission System
Transmision Providers, market paipants, and Interconneci
Transmlson System will to comply with th recommendat
Infstructure Protection Board and, eventually, bet pr
reliabilty authorit. All public utilties wil be expected
and operational securit, including physical, opera
1.1
retabi1ty management
Seion 2 of Appendix H
IT FERC Electric Tanf
1.3 Wes
thereof, in Western Ca
WECC
prising those states and province, or portons
rn United States in which Members of the
ms.
estern Electricit Coordinating Council Agreement dated
'from time to time.
1.6
Reliability Crite
such may be am
ñteri Agreent: The Western Elecrici Coordinatng Council
ng the WECC and certain of its member Transmission Providers, as
to time.
1.7 WECC
on a cotract basis, d
Those employees of the WECC, including personnel hired by the WECC
ted as responsible for the administration of the RMS.
2. Terms and Conditions
1 Idaho Power Company applies the same technical standards to all generators connecting to the electrical
system.
Effective Date:
Issued by IDAHO POWER COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Pow Company Genertor Intconnection Agreme # XX
Page 2 of3i.P~U.C. NO. 28. Tar No. 101
2.1
Reliabilit erí
CUsWme aoo
~~~ç
In orer to maintain th rebl optin of th trnsmission grid, the VVCC
adop by th \ACC to intennecon
n OWner" shaTl be required to comply.
. . ..ents of the
sefGJ in
taæiy
as InterconnnCust is ~ ~R_1e fQr th reslting failure. Stich sanctons shal be ases pUf'uant to
in the WECC Relallit Crfen"a Agree d all of th provisions of
eent aPe hereby incorprated by int this Attachment 4
conside a
2. COFl'Cn toIntCOn
sanåi bere
ju~eton, whieh
Tl'smisn OW.
OWAer.
nt shaH be void ab inito if
any purported violaton or
ry nn or any court of competent
. n or sancton wold be available to
vilation had be taken by Transmission
2.5
mformwi
untl
o consents to the release by th WECC of
Customer's complianGe with tAis Agreemen only in accordanGe
nt; provided however that no informaon will be reeaed
or challenge to any all comf)anGe violation.
e rights and obDgtions betwn the WECC and
in this Attmet 4, this Agreent crea controtal rights and
. Nothing in this Agreement shal1 create, as betw the Parts
any obligaton or liability whatsoe (other than as expressly
) any dut or standard of care whatsoever. In addon, nothing in this
liabili, or standard of care whatsoever as to any other part. Except
fer the rights, as a nefciary under this Attchment 4, of the VVCC aginst Interconneion
Custmer. no third part shall have any rihts whatsoever wih respec to enfrcement of any provision
of this Agreent. Trarimission OWner and Intercnnecon Customer expresly intend that the
WECC is a third-part benefciary to this Attchment 4, and the WECC shall have the right to sek to
enferGe ~ainst Intennecn Custmer any provision of this Attachment 4 provided that specific
perormance shalt be the sale remedy available to the WECC pUf'uant to Attchment 4 of this
Agreme, and Intercnnection Customer shall not be liable to the WECC pursuant to this Agreement
Effecte Da;
Issue by IDAH PO\IR
T
Issued on;
PANY - Delivery Busine Unit
ark, Manager, Grid Operations
Idaho Power Company Generator Interconnection Alireent# XX
I.P.U.C. No. 28, Tafi No. 101 Page 3 of3
for damages of any kind whatsoever (other than the payment of sanctions to the WECC, if so
construed), whether direct, compensatory, special, indirec, consequential, or punite.
2.7 Resed Riht. Nøing in the RMS or the WECC Reliabrlty Crieria Agreemnt shall
affect the right of Transmision Ownr, subje to. any necry regulatory approvad, to take such other
measures to maintain reliabi.it, including disnnecon, that Transmission Owner may otherwise be
entitled to take.
2.8 (IntentionaUy taft blank)
2.9 Termin. Interconneon Customer may termin
Attachment 4 at any time for any reason upon writen notice.
2.10 Mutual Agreent. ThiS Attachment 4 may be
mutual agreement of Transmission Owner and Interconneot Customer.
by
Effectve Date:
Issued by IDAHO POWER COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Pow Ccpany
t.P.U.C.~f)~281 Tar No,. 101
Generator Interconnectin Agreemen # XX
PSQ 1 of3
Atent 5
R~Ve PR,!l Reuirmets
1.00 ~ will ' the ~ ¡XW$r reireto he ' by th Q;i3Y to theSeer, base upo ~t. Th sp th equipmentret,fRøn fl ~ys ~m to th Fæis po Feliire!l. These
. spoes will inelud but not be limited to equipment specifcatins, IoNe. Company-provide equipmnt, Selle providd equipment, and all costs associa e equipment, desig8M ~ øf '. ,ipmem.' sand r:irementswil ai The ~be ma(iteined bythe inst, mainaæi ineludingadmim rati to re.. th Company by the of thes cost wíll be inacrd wi Scede 72 and th total reactiv powe the calculatn of the
Moothly ~ awlttean Cls sp
A.Tedn'rds.
i.
. æs up'to thel.VRT.~ proides
T,
ha
Co
Jan
2007, or
Decmber
a~ to wmd gée~ Jilæts ~ to F6RC Of 661 that
and file wi thè Commiei:, fied wf ttee Commision as non-confin ag between
a scheduled in-service date no later than Decmber 31,~~ tea wfØ turBine pront CO exec prior to
ugh 2007.
1. Wr reuif to r~aiR in-servce during threetlsæ faults wi normal
clring period of approximately 4 - 9 cycles) an sin lineto groud faults
wih deyed and sUbsuent post-fault voltae recvery to prefault voltage unles
cl th . ~ th §ènrftom ~ sym. rh oi timereq~,_ a ~lJe~.. . CO , te the wid §ene pl ~n
I~, as déid by an, c¡ . by th trl'ss .pr~1Ge. rh maxl
clearing time the wind g.enerating plant shall be require to withstand for a threephase fault
sha,lbe 9 as 0.15 p.u.; as meured at th hi§h si of the windgeAer nsfrr that st th volte up tatte
trnsmisniftercAtlecon v0ltage Of UP), aftr which, if the fault remaJns f0long the
Efftive Date:
issue by IDAO POWE~ COMPANY - Deivery Busines Unit
Tes Park, Manager, Grid Operations
Issued on:
~,' (
Idaho Power Company Generator Interconnecion Agrement # XX
I.P.u.C. No.. 28. Tarif No. 101 pag 2 of3
location-specific normal clearing time fer three¡:hase faults, the wind generating plant may
disconnect from the transmission system.
2. This requirement does not apply to faults that would occur between the wind generator
terinals and the hih side of the GSU or to fault that would result in a voltage lower than 0.15
per unit on tle high side of the GSU servng the facilit.
3. Wmd geAeraing plants maybe trippe after tlefault period if this actin is intende as part of a
speal proteon system.
1.
\Moo geneting plants may me the LVRT requirements of
of the genetors or by inling aditinal equipmnt (e,g.,
witin the wine geneatngJit or by a combination of g
eqUipment.
rd by the perormance
r Compensator, et-c.)
. rmance and additonal
4.
5.Existng individual generator units that are, or hav
same location at the efftive date of th OA IT
from meeting the L VRT Standare for the
Existing individual generator units that are
the netwrk at the
rd are exempt
equipment.
Standard.
Post-transition Period L VRT Standard
All wind generating plants subjeet to FE
described above must meet the following
covered by the transition period
-phase faults with normal
s~ line to ground faults
to prefault voltage unless
rrrom sytem. Th olring time
n th wind generaplant substion
tr~nsmissi0n provid. The mæcimum
uired to withstand for a threephase fault
owing the locatin-spif normal dearing
wind plant may disconneet from the trnsmission
shall remain interconnected during such a fault on the
level as low as zero volts, as measued at the high volge
2.apply fu faults that would occur between the wind geneatr
of the GSU.
3.\Mndg
spel P
y be trpped after the faultperiod if this acton is intended as part of a
4. Wind' generti may me the LVRT requlremnts of this stndard by the perfrmance
of ttlgenerators or by instaiing adGit0flaJequipmet (e.g., Static VAr CGmpesator) within the
wind generating. plant or by a commination ofgeAerator performance and additonal equipment.
5. Existng indidual geor units tht are, or have ben, interconneced to the netork at the
same locaon at the efive da of th Appendix G L VRT Standard are exempt from meeting
th Appendix G L VRT Standard for the remaining li of the existing generation equipment.
Effective Date:
Issued by iDAHO POWËR COMPANY - Delivery Business Unit
Tess Park, Manager, Grid Operations
Issed on:
Idaho POWer Compny
l.P .U.C.Np~. as. Tar NO.1 01
Generator Interconnecton Agre # XX
..Paae3of3
Exng indMdual generor units that are re are required to meet the Appendix G L VRT
Stndard.
ii. Po,W Fa, Qe9Ð ~ ffe Pow)
iii.Su.Connl and Data
Effecive Date:
Issed by IDAH POWER COMPANY - Deliver Busines Unit
Tes Park, Manage, Grid Operaons
Iss on:
Idaho Powe Company Generator Interconnection Agreent # :x
I.P.U.C. No. 28, Tari No. 101 Page 1 of3
Attachment 6
Company's Descnption of Upgras Reuire to Integrate th Gene Facl1it and Best
Estmate of Upgrade Costs
As provide in Schedule 72 this Attachment descnbs Upgraes, including bet work upgrades,
and provides an itemized best estimate of the. cost of the Upgrades.
(e)
,of OwnehipIntrconi:cton Ctl Conól Respcibif and '
1. Interconnecon Facilies:
(a) lme.roDn.ecn Customets Interconnection
(b) Transision Owner's Interconnecion
2. Nek Upgraes
(a) Subtation
(b) Transmission Line
(c) System Protection:
(d) Telecormu
3. Local S~~Service:
4. R~ent of Tra n for Netol" Upgrades:
(a)*eimbursable CO'
(b) Reim~able ~~Repayment
5. Cooperation and Ræsonable Effort.
Effective Date:
Issued by IO.AHO POWER COMPANY - Delivery Busines Unit
Tess Park, Manager, Grid Operations
Issued on:
Idaho Pow Compay
LP.U.C. NO;. 28t T~ Ng. 101
Generaor Interconnection Agrent # XX
Page 1 of 1
Attchment 6 -Exhibit 1
Effece Dat:
Issued P¥ IPAHO POWER COMPANY - Delivery Busines Unit
Tes Park, Manager, Gnd Operations
Issue on:
Idaho Power Company Generator Interconnection Agreement # XX
I.P.U.C. No. 28. Tam No. 101 Page 1 of 1
Attchment 1
Exhibit 4
Major Facilty Lit
Par A:
Installed by Interconnection Customer
1. Iiitercoiinection Facilities
a) Interconnection Customer's
. describe
b) Transmission Owner's Interco
. describe
. Total
2. Network Upgrades:
a) describe $
Par B:
Intalled by Tranmission Owner
a)
b)
$
Effectve Date:
Issued by IDAHO POWER COMPANY - Delivery Busines Unit
Tes Park, Manager, Grid Operations
Issued on: