20140522RMP Comments.pdf

ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
May 21,2014
RECI l\r[: r)
201 South Main, Suite 2300
20lE itAY 22 Ail 9: hS sart Lake citv, Utah 84111
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VIA ELECTRONIC FTLTNG UTILITIES CCi,irciS$lC;.j
AND OWRNIGHT DELIVERY
Jean D. Jewell
Commission Secretary
Idatro Public Utilities Commission
472W. Washington
Boise,lD 83702
Re: CASE NO. IPC-E-14-09: IN THE MATTER OF IDAHO POWER
COMPAI\IY'S PETITION TO TEMPORARILY SUSPEND ITS PURPA
OBLIGATION TO PURCHASE ENERGY GENERATED BY SOLAR
POWERED QUALIX'YING FACILITIES
Dear Ms. Jewell:
Please find enclosed for filing an original and seven (7) copies of Rocky Mountain Power's
comments in support of solar integration charges.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at(801)220-
2963.
Very truly yours,
twT
Vice President, Regulation and Govemment Affairs
Enclosures
Cc: via electronic mail
Donovan Walker, Idaho Power Company
Daniel E. Solander (ISB #8931)
Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84l l l
Telephone: [phone]
Fax: [phone]
Attorney for Rocky Mountain Power
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO
TEMPORARILY SUSPEND ITS PURPA
OBLIGATION TO PURCHASE ENERGY
GENERATED BY SOLAR POWERED
QUALIFYING FACILITIES
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)) CASE NO. IPC-E-I4-09
)
)) Comments of Rocky Mountain
) Power in Support of Solar
) Integration Charges
COMMENTS OF ROCKY MOUNTAIN POWER
IN SUPPORT OF SOLAR INTEGRATION CHARGES
COMES NOW PacifiCorp dba Rocky Mountain Power (or the "Company") and
pursuant to Rules 56,203, and 256 of the Rules of Procedure of the Idaho Public Utility
Commission (the "Commission"), submits comments in support of including solar
integration costs in new power purchase agreements with solar powered qualiffing
facilities ("QFs").
I. Background
On May 14,2014,Idaho Power Corporation ("Idaho Power") filed a petition with
the Commission for an order temporarily suspending Idaho Power's obligation to enter
into contracts and/or obligations to purchase energy generated by qualiffing solar-
powered QFs under the Public Utility Regulatory Policies Act of 1978 ("PURPA"), or
altematively, an order determining that any future solar PURPA contracts shall contain
an appropriate solar integration charge.
Rocky Mountain Power supports Idaho Power's efforts to include appropriate
solar integration charges in PURPA contracts. Rocky Mountain Power believes that, as
Idaho Power argued, unless the cost of integrating solar generation is taken into account,
including accounting for the availability of transmission service, customers are harmed
by paying solar QFs a price that is above the avoided cost.
While Rocky Mountain Power is not requesting Commission action with respect
to its own obligations under PURPA at this time, it anticipates requesting approval of a
solar integration charge sometime in the future, after further evaluating its own
assessment of solar integration costs. The Company currently charges solar QFs in Utah
a solar integration charge per the Utah Public Service Commission Order issued on
August 16,2013, in Docket No. 12-035-100, which is based on a percentage of the wind
integration costs that are charged to wind QFs in that jurisdiction. In Oregon, the Public
Utility Commission agreed that integration costs are legitimate costs that should be
factored into avoided cost calculations and will revisit this issue in the future as more
solar development occurs. I
Based on the foregoing, Rocky Mountain Power recommends that the
Commission approve Idaho Power's petition to include an appropriate solar integration
charge for all future solar QFs.
I In the Matter of PUBLIC UTTLITY COMMISSION OF OREGON, Investigation Into Qualiffing Facility
Contracting and Pricing, Docket No. 1610, Order No. 14-058 at l5 (February 24,2014).
DATED this 2l't day of May z}ru.
Daniel E. Solander
Attonrey for
Rocky Motrrtain Power