20140602Petition to Clarify.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO
TEMPORARILY SUSPEND ITS PURPA
OBLIGATION TO PURCHASE ENERGY
GENERATED BY SOALR-POWERED
QUALIFYING FACILITIES ("QF').
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-14-09
IDAHO CONSERVATION LEAGUE
PETITION TO CLARIFY ORDER NO
33043
Pursuant to Rule 325 of the Idaho Public Utilities Commission's ("Commission") Rules
of Procedure, the Idaho Conservation League (lCL) respectfully submits this Petition to Clarifr
Order No. 33043. Overall ICL supports the Commission's decision. Our concern is with this
sentence: "We believe the benefits and value of solar generation are reflected in the solar avoided
cost rates and not part of consideration when developing the costs of integrating solar." Order
No ii043 at 8. We are concerned because this statement goes beyond the narrow issues before
the Commission and the statement does not comport with the Commission's description of the
IRP methodology in Order No 32976, GNR-E-I1-03. We request the Commission clariff Order
No 33043 by simply striking the above sentence.
The Commission addressed a narrow issue here: whether to stay Idaho Power's solar
PURPA obligation or order the inclusion of an integration charge in solar PURPA contracts.
Order No 3i043 at l.The Commission specifically excluded consideration of "whether and what
type of integration charge may be appropriate )' Id. By opining on the types of benefits and
values to include or exclude from an integration charge, the Commission went beyond the scope
of the narrow issues noticed for hearing in Order No. 33039.
IPC-E-14-09
ICL Petition to Clarifr Order 33043
lune2,2014
While the Commission's "belief'as to whether avoided cost rates incorporate the
"benefits and value of solar generation" is not a finding of fact, we are concerned that it could be
interpreted by some as precluding exploring that question in subsequent proceedings. Striking
the sentence will avoid confusion and possible further litigation before the Commission.
The Commission previously endorsed the IRP methodology because it "recognizes the
individual generation characteristics of each project by assessing when the QF is capable of
delivering its resources against when the utility is most in need of such resources. We find that
the resultant pricing is reflective of the value of the QF energy being delivered to the utility."
Order No 32697 at 20.Fwther, the Commission adopted Idaho Power's "single run" scheme to
find the highest incremental cost in each hour of QF delivery. Id. Avoided cost rates are clearly
from the utilitF or systemic perspective and are not developed based on the characteristics of the
QF. The rates do not reflect the value of the QF; they reflect the value of a generic avoided
resource.
We are concerned about confusion from Order No 33043 because integrating individual
resources is something different than payments for energy and capacity. As the Commission
recognized here the appropriate integration charge "may vary from very little to more based
project location, project size, and other factors." Order No 3i043 at 8. But the avoided cost rate
does not capture these location and project specific attributes. Because individual solar projects
have unique benefits and values in terms of integration, we recommend the Commission clarify
Order No 33043 by striking the sentence: "We believe the benefits and value of solar generation
are reflected in the solar avoided cost rates and not part of consideration when developing the
costs of integrating solar." Order No i304i at 8.
Respectfully submitted this 2'd day of fune 2014,
Benjamin Otto
Idaho Conservation League
IPC-E-14-09 2
ICL Petition to Clarifr Order 33043
lune2,2014
CERTIFICATE OF SERVICE
I hereby certifr that on this 2nd day of fune 2014,I delivered true and correct copies of
the foregoing PETITION TO CLARIFY to the following persons via the method of service noted:
Hand delivery:
Iean Iewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Donovan Walker
Idaho Power Company
121 West Idaho St
P.O. Box 70
Boise,Idaho 83707
dwalker@idahopower. com
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27s Street
Boise,ID 83702
[e-mail]
Dean J. Miller
McDevitt &Miller LLP
PO Box 2564-83701
Boise,ID 83702
joe@mcdevitt- miller.com
Ken Miller
Snake River Alliance
PO Box 1731
Boise, Id 83701
kmiller@snakeriveralliance. org
IPC-E-14-09
ICL Petition to Clarifr Order 33043
Benjamin J. Otto
Iune2,2014