20140521Renewable Northwest Comments.pdf

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,p Northwest
May2O,2014
Via U.S.Mail and Electronic Transmission
—4 —
The Honorable Paul Kjellander !E—
The Honorable Marsha Smith
The Honorable Mack Redford Cn (-:1
Idaho Public Utilities Commission ?:-::
472 West Washington Street
Boise,Idaho $3702
Re:Idaho Power Company Petition to Suspend Purchas&fSo
Powered Energy,Case No.IPC-E-14-09
Dear Commissioners:
I am writing on behalf of Renewable Northwest (f.k.a.“Renewable Northwest
Project”)in response to Commission Order 33039 regarding the Commission’s
public hearing on Idaho Power Company’s (Idaho Power”)petition to
temporarily suspend its PURPA obligation to purchase energy generated by
solar-powered quali1’ing facilities (“QFs”).Renewable Northwest is a non
profit regional advocacy group that works to facilitate the expansion of
responsibly developed renewable energy resources for the betterment of the
Northwest economy and environment.Renewable Northwest’s members
include renewable energy project developers and manufacturers,public and
consumer interest groups,academic institutions,and others.
Renewable Northwest opposes Idaho Power’s request for an immediate order
that would allow it to (I)suspend its obligation to enter into PURPA contracts
with solar QFs or (2)require the imposition of a solar integration charge on
any solar PURPA contracts.Renewable Northwest considers such a request to
be premature and not necessary to address Idaho Power’s concerns.Instead of
granting Idaho Power’s petition,the Commission should focus on ensuring a
robust solar integration study process that arrives at an accurate solar
integration charge.
As a threshold matter,Renewable Northwest is concerned about the timing and
process issues associated with Idaho Power’s request.Renewable Northwest
has been participating on the Technical Review Committee (“TRC”)that is
providing input on Idaho Power’s solar integration study—first,with Jimmy
Lindsay,our Regulatory Analysis Manager;following Mr.Lindsay’s departure
from Renewable Northwest in April,our Senior Policy Manager,Cameron
Yourkowski,has been serving on the TRC.Despite our participation on the
solar integration TRC,we had no knowledge of Idaho Power’s petition before
it was filed.This Lack of communication,combined with the request for
expedited treatment,provides little opportunity for meaningful stakeholder
participation on the issue.
421 SW 6th Avenue,Suite 1125 •Portland,OR 97204
phone:[phone] •fax:[phone] •www.RenewableNW.org
Second,Renewable Northwest considers Idaho Power’s request premature.As stated in Idaho
Power’s petition,the company’s 501 MW estimate includes solar QFs that “recently signed
contracts,received draft contracts,received incremental cost pricing calculations,or otheni’ise
made serious mqutrtcs or taken other steps designed to attempt to obligate Idaho Power and
its customers to purchase their generation pursuant to PURPA.”Of this 501 MW total,only
60 MW of solar projects have signed contracts with Idaho Power.2 As for the remainder,it is
not clear from the petition what constitutes “serious inquiries”or “other steps,”but it appears
to us that much of the 501 MW total is very far from signing a PURPA contract with Idaho
Power,even without the addition of a solar integration charge.(Certain of the terms and
conditions in Idaho Power’s contracts may make it difficult to finance solar PURPA projects.)
Thus,Idaho Power’s concern about the need to prevent a flood of solar projects is at least
premature.
Third,the requested remedy is not necessary to address tdaho Power’s concerns.Even for
those projects that have made inquiries to tdaho Power,the company is free to negotiate a
solar integration rate for those projects that are not subject to a standard contract.We
recognize that tdaho Power has not yet completed its solar integration study,but its analysis to
date could be used to inform the contract negotiations,and contract provisions can be drafted
a number of ways to account for the incomplete study results without burdening the
Commission with the petition.
fundamentally,what this petition underscores is the need to complete Idaho Power’s solar
integration study as expeditiously as possible—but without compromising the quality of the
analysis and the ability to thoroughly vet the study methodology.Our organization’s
participation on the TRC gives us a better window into the study process,and we find that
good progress is being made on the study.However,we also recognize that other
stakeholders do not have the same opportunity to participate.Instead of granting Idaho
Power’s petition,the Commission can address the company’s concerns as well as those of
other stakeholders by formalizing the study process to ensure that the study is completed in a
transparent and verifiable manner.Such oversight is not intended to supplant the important
role of the TRC in providing “input,review,and guidance for the Study,”3 but rather to
supplement the TRC’s efforts and provide for a more formal process.
We appreciate the opportunity for our organization to participate on the TRC and we look
forward to continuing to work productively with Idaho Power on that effort.However,we do
not consider this particular petition an example of a productive approach to solving integration
issues.We recommend that the Commission reject Idaho Power’s petition.
‘Idaho Power Petition at 16 (emphasis added).
2 Direct Testimony of Randy Alphin at 3.
See Direct Testimony of Philip DeVol at 3.
DinaM,
Staff Counsel
Renewable Northwest