20071123PAC additional comments.pdf

ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
lûß~l llO'l 23 AM 9~ 52
201 South Main, Suite 2300
Salt Lake City, Utah 84111
November 23, 2007
VI OVERNIGHT DELIVERY
Ms. Jean D. Jewell
Commission Secretar
Idaho Public Utilties Commission
PO Box 83720
Boise, ID 83720-0074
Re: Additional Comments of Rocky Mountain Power in Case No. IPC-E-07-15
Dear Ms. Jewell:
Rocky Mountain Power, ("RMP" or the "Company"), hereby submits for fiing an original and
seven copies of Additional Comments of Rocky Mountain Power in Case No. IPC-E-07-15.
Communications relating to this proceeding should be served on the following:
Jordan A. White
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Uta 841 i i
jordan. whiteCfpacificorp.com
Brian Dickman
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 84111
Brian.DickmanCfPacifiCorp.com
In addition, it is respectfully requested that all formal correspondence and Staff requests
regarding this material be addressed to:
By E-mail (preferred):datarequest($acificorp.com
By Fax:[phone]
By Regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
Sincerely,
~~~/Wt.
Vice President, Regulation
Enclosure
Cc: Bar Kline
Lisa Nordstrom
Jordan A. White
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Tel: [phone]
Fax: [phone]
jordan. whiteaæpacificorp.com
2mn Mû'l 23 At' 9= 52
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER'S )
PETITION TO MODIFY THE METHODOLOGY )
FOR DETERMINING FUEL COSTS USED )
TO ESTABLISH PUBLISHED RATES FOR )
PURPA QUALIFYING FACILITIES )
)
)
CASE NO. IPC-E-07-15
ADDITIONAL COMMENTS OF
ROCKY MOUNTAIN POWER
In response to the Commission's Notice of Additional Comment Period issued
November 9,2007, Rocky Mountain Power ("Rocky Mountain Power" or the
"Company") respectfully submits the following additional comments in the above
referenced matter.
Additional Comments
The initial comments filed by the Company, Avista Corporation (Avista) and the
Commission Staff (Staff propose modifying the current fuel cost calculation to
incorporate the natural gas price forecast on a year-by-year basis as provided by the
Northwest Power and Conservation Council (NWPCC). The efficacy of this
methodology is evidenced by the fact that four of the states in which Rocky Mountain
Power files avoided cost tariffs (Oregon, Washington, Utah, and Wyoming) utilize a
year-by-year gas forecast. This methodology has never been contested in those
jurisdictions.
ADDITIONAL COMMENTS OF ROCKY MOUNTAIN POWER -1
The petition at hand is necessitated by a view of forecasted natural gas prices
that is fundamentally different than those existing at the time the current methodology
was implemented. For example, the recently-released NWPCC gas price forecast
exhibits a near-term downward trend in fuel prices - causing the current methodology
calculation forecast to significantly overstate the cost of fuel as a component of the
overall avoided cost calculation.
Rocky Mountain Power agrees with Staff that any change in methodology
approved by the Commission in this case should apply to all three Idaho investor-owned
utilities. The Company also agrees with comments previously filed by Idaho Power,
Avista and Staff, stressing the importance of an accurately modeled fuel cost
calculation. This component comprises the single largest component of the overall cost
of the SAR.
Finally, the Company concurs with the Reply Comments of Idaho Power
regarding the Commission's ability to consider this issue and believes resolution can be
reached in this matter without reopening all aspects of the avoided cost calculation.
Based on the above, Rocky Mountain Power supports the continued use of Modified
Procedure in this case and does not believe further technical proceedings are
necessary.
Respectfully submitted this 23rd day of November 2007.
ROCKY MOUNTAIN POWER
Ik&w~jJ/wr
Attorney for Rocky Mountain Power
ADDITIONAL COMMENTS OF ROCKY MOUNTAIN POWER-2