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Home My WebLink About20130812Comments.pdfa|,'1 " I tt!1 r ^it:t . t "t ,i {,. I:a!i I : ! i:rl {,.}ul ,.-!r r I r.r; j i -r i I RENEI{T.&,BLS trHUfl SY COiIUTIOR August 8,?AL3 Idaho Public Service Commission P.O. Box 83724 Boise,lD 83720-A474 Re: Comments on PacifiCorp 201.3 Integrated Resource Plan Docket No. PAC-E-13-05 Dear Commission President Kjellander and Commissioners: Thank you for the opportunity to provide comments on PacifiCorp's 2013 Integrated Resource Plan [RP]. The Renewable Enerry Coalition (Coalition) is providing these comments for your review. The Coalition is a large group of primarily existing hydroelectric Public Utility Regulatory PoliciesAct (PURPA) qualiffing facilities (QF) located in PacifiCorp's multi-state service areas. We have one primary issue which is the year of resource deficiency in the IRP. PacifiCorp's20L3lRP acknowledges the utiliQ/s need for capacity resources immediately, in 2013. However, the utility plans to use short-term power purchases in the wholesale market to meet those needs rather tlan building a new generating facility. Frequently in the past, a deficit year was anticipated years in advance and a new generating facility planned to come on line on or near the year of deficit However, the availability of sufficient wholesale power allows PacifiCorp to delay the decision to build a new generating facility. PacifiCorp, in describing its resource situation with regulatory commissions, often refdrs to the next avoidable resource as a 2024 CCCT. This is questionablg because the nefi avoidable resource is power purchases in 201"3 and demand reductions through demand control programs [DSM). We believe that their decision of how or when to fill a deficit, whether from purchased power, DSM or a new generating facility, does not negate the reality of a specific capacity deficitin Z0L3,which grows significantly each year of the planning horizon (see PacifiCorp 2AL3IRP Volume 1, page 99, Table 5.1,2). The Coalition has several members with operating hydro elecric projects in ldaho that have existing and long-standing PURPA contracts with PacifiCorp, and have been receiving both capacity and energy payments. Contracts expiring and needing replacement could be impacted by avoided cost pricing trased upon theyear of deficit being established as 2A24. The Coalition appreciates the Commission's consideration of these comments. We Iook forward to working with the Commission and PacifiCorp in esablishing fair and reasonable contract terms for REC members in ldaho. Sincerelv. lohn R Lowe Renewable Enerry Coalition CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 8th day of August, 2013, I caused to be served a true and correct copy of the foregoing document to each of the following via the method so indicated: Jean D. Jewell, Secretary (original and 5) Idaho Public Utilities Commission P.O. Box 83720 Boise,lD 83720-0074 jj ewel@puc. state.id.us Ted Weston Daniel E. Solander Mark C. Moench Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, UT 841l1 ted.weston@pacifi corp.com daniel. so lan der @p acifrc o rp. com mark. moen ch@p aciftco rp. c om Yvonne Hogle Regulatory Counsel Rocky Mountain Power 201 S. Main, One Utah Center,23'd Floor Salt Lake City, UT 84111 yvonne. ho g le @p acilrcorp. com Benjamin J. Otto Idaho Conservation League 710 N. 6th Street Boise,ID 83702 botto@idahoconservation. org Ken Miller Clean Energy Program Director Snake River Alliance Box 173 Boise,ID 83701 kmiller@snakeriveralliance. org U.S. Mail and Electronic Mail Electronic Mail Electronic Mail Electronic Mail Electronic Mail Renewable Energy Coalition