Advice Filing - Pacific Power

1 As a result, the court nullified the CPUC's 0.95 floor.
2 Third-party transmission costs associated with QFs delivering to load pockets are
3 closely analogous to the QF line loss deductions in Edison I because they always increase
4 the utility's cost above the published avoided cost rate. When a QF delivery of net output
5 to a load pocket causes local generation to exceed local load, PacifiCorp incurs a net
6 additional cost when it must purchase third-party transmission to move excess output
7 from a load pocket to adequate load on PacifiCorp's larger system. In short, QFs that
8 elect to deliver output to a load pocket systematically increase transmission costs for
9 PacifiCorp. Adding those costs on top of the published avoided cost rates required under
10 Schedule 37 would result in PacifiCorp paying more than its full-avoided cost for net
11 output from small QFs delivering energy to load pockets. For the same reasons the
12 CPUC could not impose a floor on line loss deductions for QFs receiving standard
13 published rates, PacifiCorp cannot be required to pay Schedule 37 prices and pay for
14 third-party transmission necessary to move a QF's output to load.
15 E.
16
A prompt change to Schedule 37 is needed to avert the long-term costs that
could result under the current Schedule 37.
17 PacifiCorp respectfully requests that the Commission allow the proposed
18 revisions to Schedule 37 to become effective on July 27,2011, even if the Commission
19 decides to initiate an investigation. If the revisions are postponed or suspended, QFs that
20 would be affected by the revisions may rush to execute PP As under the current Schedule
21 37 while the proposed revisions are being investigated. Once a PPA is executed, the
22 ambiguity in the current PPA regarding who must pay for necessary third-party
23 transmission to move excess QF generation to load will be locked in contract-for a term
PacifiCorp's Memorandum of Law in Support of Advice No. 11-011 13