19970221IPC to Aurora Answer to Petition for Reconsideration.PDF

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IDI1O IDAHO POWER COMPANY
POUIJER
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Mrs.Myrna J.Walters
Secretary
Idaho Public Utilities Commission
P.0.Box 83720
Boise,Idaho 83720-0074
37 FEB i 1i 8 E
IU:;I:February 20,1997iTIES
Re:Case No.IPC-E-95-15
Answer of Idaho Power Company To
Petition For Reconsideration of Aurora
Power &Design
Dear Mrs.Walters:
Enclosed for filing with the Commission are the original and seven (7)copiesoftheIdahoPowerCompany’s Answer to the Petition for Reconsideration of Aurora Power&Design regarding the above-entitled case.
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Enclosures
C)1)
FQ’r
BARTON L.KLINE
Counsel for Idaho Power
L.Kline
Telephone [phone],Fax [phone]
BARTON L.KLINE
Idaho Power Company
P.O.Box 70
Boise,Idaho 83707
[phone]
Attorney for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise,Idaho 83702
FAX Telephone No.:[phone]
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR AN
ORDER REVISING THE RATES,TERMS
AND CONDITIONS UNDER WHICH
IDAHO POWER PURCHASES NON-FIRM
ENERGY FROM QUALIFYING FACILITIES.
)
)CASE NO.IPC-E-95-15
)
)ANSWER OF IDAHO POWER
)COMPANY TO PETITION FOR
)RECONSIDERATION OF
)AURORA POWER &DESIGN
In accordance with RP 331.05.,Idaho Power Company (“Idaho Powers’or the
“Company”)hereby answers the Petition for Reconsideration filed by Aurora Power &
Design (“Aurora”or “Aurora Power”).
Aurora’s Petition for Reconsideration consists primarily of statements of
opinion.The Petition does not identify errors in the facts the Commission relied upon in
rendering its decision.It does not identify any legal conclusions made by the Commission
that it claims are incorrect.Idaho Power does not intend to respond to Aurora’s
characterizations of the Company’s motives in this case.However,there are several points
ANSWER OF IDAHO POWER COMPANY TO PETITION
FOR RECONSIDERATION OF AURORA POWER &DESIGN,Page 1
0 C)
that do merit some additional discussion in order to correct apparent misunderstandings
on the part of Aurora.
1.Qualifying Facilities are not entitled to be paid more than avoided
costs.
Much of Aurora’s displeasure with Order No.26750 appears to arise
from Aurora’s assumption that “alternative energy technologies”are entitled to be paid at
retail rates which are currently in excess of the Company’s avoided costs.Aurora objects
to the fact that “alternative energy technologies”will only be paid the Company’s avoided
costs.As this Commission is well aware,PURPA specifically prohibits the Commission
from requiring electric utilities to purchase energy from qualifying facilities (“QF’s”)at rates
that exceed avoided costs.Therefore,the Commission’s decision to allow smaller
alternative energy producers to be paid full avoided costs without paying the costs
associated with dual metering and interconnection protection equipment that other QF
developers are required to provide,constitutes a reasonable level of incentive to alternative
energy technologies.
2.Idaho Power’s solar photovoltaic service under Schedule 60 did not
compete with the applications of solar photovoltaic generation at issue in this proceeding.
New service under Idaho Power’s solar photovoltaic service
Schedule 60 was suspended in November of 1996.Prior to suspension,Idaho Power’s
Schedule 60 solar photovoltaic service was only available to off-grid locations.Because
Schedule 86 is applicable only to on-grid applications,Order No.26750 will have no impact
ANSWER OF IDAHO POWER COMPANY TO PETITION
FOR RECONSIDERATION OF AURORA POWER &DESIGN,Page 2
on Aurora’s ability to compete with any entity to develop off-grid solar photovoltaic
applications.
3.The monthly charge in Schedule 86 allows for recovery of non-
generation related customer costs and is readily integrated into the Company’s retail billing
system.
Aurora argues that the computation of the monthly charge is “absurd,
subjective,and in conflict with maintaining simplicity.”Aurora goes on to characterize the
monthly charge as a”...calculation that appears to be impossible to incorporate into any
billing system.”(Page 2,Aurora’s Petition)Aurora offers no objective support for its
assertions,nor does it provide any evidence that the underlying assumptions used in the
methodology to compute the monthly charge are unreasonable or that the methodology
produces inaccurate results.In direct contrast to Aurora’s rhetoric,the Commission Staff
has reviewed and accepted the monthly charge methodology.
While the monthly charge computation is presented in Schedule 86 as an
algorithm,and as such is somewhat intimidating on the surface,in fact,once the data
regarding the customer’s generating equipment is obtained from the customer or the
customer’s photovoltaic equipment vendor,computation of the monthly charge is not
difficult.Once the monthly charge is computed,the Company can use its existing retail
billing computer program to add the monthly charge to the customer’s retail electric bill as
a separate charge.Aurora is simply wrong in its assertion that the monthly charge is overly
complex and is not capable of being readily integrated into the Company’s existing billing
system.
ANSWER OF IDAHO POWER COMPANY TO PETITION
FOR RECONSIDERATION OF AURORA POWER &DESIGN,Page 3
0 0
4.Alternative generating technologies must be interconnected safely.
Idaho Power is concerned about the statements Aurora makes in the
last paragraph of its Petition on Page 3.When a customer installs electric generating
equipment that has the capability to energize Idaho Power’s distribution lines,it is
imperative that Idaho Power know about the installation and have the ability to protect its
employees and system from injury or damage.Idaho Power will continue to insist that
disconnection and protection equipment be well designed and constructed with quality
materials.Idaho Power does not believe that having qualified personnel be responsible
for reviewing and approving such protection is “laughable.”If,as Aurora indicates,Idaho
Power’s customers are installing electric generation without providing Idaho Power with
notice of the installation,Idaho Power is hopeful that companies such as Aurora will be
responsible and work cooperatively with Idaho Power to avoid the possibility of injury,
death or damage that can come from inadequate interconnection and protection
equipment.
Respecifully submitted this 20th day of February,1997.
BA TON L.KLINE
ANSWER OF IDAHO POWER COMPANY TO PETITION
FOR RECONSIDERATION OF AURORA POWER &DESIGN,Page 4
fl)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20th day of February,1997,I served a true
and correct copy of the within and foregoing ANSWER OF IDAHO POWER COMPANY TO
PETITION FOR RECONSIDERATION OF AURORA POWER &DESIGN upon the
following parties of record by the method indicated below,and addressed to the following:
Brad Purdy Hand Deliver
Deputy Attorney General U.S.Mail
Idaho Public Utilities Commission Overnight Mail
472 West Washington Street Facsimile
P.0.Box 83720
Boise,Idaho 83720-0074
Mike Leonard
____
Hand Deliver
Aurora Power &Design x U.S.Mail
3412 N.36th Street
____
Overnight Mail
Boise,Idaho 83703 Facsimile
CERTIFICATE OF SERVICE