Testimony of Tom Wind, Wind Energy Consulting, PC, Jamaica, Iowa

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Q. Is MidAmerican’s QF tariff workable from the perspective of a wind generation
QF?
A. MidAmerican’s tariff does not work from the perspective of a prospective wind
generation QF because it is a two part tariff with both energy rates and capacity rates.
The wind generation QF cannot easily predict the revenue it would receive from the
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capacity rate since it would vary from year to year.
Furthermore, I believe that
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MidAmerican’s QF tariff discriminates against wind generation QFs compared to wind
generation investments it makes on behalf of its own customers. The discrimination is in
the form of the price paid to wind generation QFs compared to the cost that
MidAmerican charges its own customers for wind generation through its rates.
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Q. What do you recommend MidAmerican should do to make its avoided costs for QFs
workable and fair?
A. I would recommend that intermittent QF generation such as solar PV and wind
generation need a single part tariff paying a fixed or a predictable escalating amount per
kWh for a 10 to 20 year contract period. This single part rate would consider both the
capacity value and energy value of the intermittent QF generation. The IUB should
require MidAmerican to set an avoided cost rate specifically for wind and solar
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generation QFs, as allowed by FERC precedent. 2
The avoided cost rate for wind and
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solar generation QFs should comply with FERC regulations and Orders.
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2
In re California Public Utilities Comm’n, 133 FERC 61,059 (Oct. 21, 2010).
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