Comments..pdf

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lj1' pV'Jean Jewell
From:
Sent:
To:
Subject:
Ed Howell
Friday, March 15, 2002 9:43 AM
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WWW Form Submission:
Friday, March 15, 2002
9:43:20 AM
Case: GNR-02-01
Name: Bill Chisholm, IRC EnergyStreetAddress: 19073E Hwy 30
City: Buhl
State: Idaho
ZIP: 83316
Home Telephone: [phone]
E-MaIl: chisholm30mindspring. com
Company: General
mailing list yes no: yesComment=descriptIon:
Coordinator
March 11, 2002
Idaho Rural Council
Bill Chisholm, Energy Coordinator
19073E Hwy 30
Buhl, Idaho 83316
Idaho Public Utili ties Commission
O. Box 83720
Boise, Idaho 83720-0074
Comments:Case GNR-E-02-01, PURPA projects
Dear Commissioners,
The Idaho Rural Council is a grassroots organization dedicated to the preservation
and enhancement of the guali ty of life in Idaho. We are concerned with economic viabilityand sustainabili ty and with the prudent and responsible use of our state s abundantnatural resources. We care about the environment, about the air, land and water whichsustains us and which must also sustain future generations. It is in that context that wesubmi t these comments regarding GNR-E-02-01.
The Idaho Rural Council supports the concept of a safe, sustainable, affordable andjust energy policy for all Idahoans. We believe strongly in energy conservation and theefficient and responsible use of our energy resources. We are in favor of renewable anddistributed energy production and thus believe that longer PURPA contracts in the 15 to 20
year range are essential to encourage investment in renewables such as wind and solar. Wehave concerns about the kind of hydro development and proposals that took place when
longer PURPA contracts were available before. While small hydro proj ects in canal systemsmake sense, damming up the few remaining free flowing waters of Idaho don t make senseei ther in water guali ty terms or for protection and enhancement of fisheries. We believethat hydro projects should be limited to canal systems or other waters that have neitherfish nor recreation issues. To that end, we would recommend that an environmental
assessment be done for all proj ects to determine their impacts and allow for public
comment and participation. That there be in essence a more wholistic approach to economicassessment of these proj ects.
The rate structure of applying avoided costs to PURPA projects up to 5 MW seems
reasonable. However, in order to better reflect the true nature of the avoided costs and
thus protect rate payers from paying higher prices than necessary, these costs should
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reflect the seasonal fluctuatlons of these costs. It is important that wind and solarproduction proj ects become a part of the energy mix here in Idaho if we are to have a
sustainable energy future. Idaho has abundant wind and solar resources and along with
conservation and efficiency we should look to better utilize those resources. We urge youto be creative and visionary in your approach to this issue so that we truly move forward
to establishing a safe, stable and sustainable energy future that is environmentallyresporysible, economically sound and socially just.
Bill Chisholm
IRC Energy Co-ordinator
Transaction ID: 315943.
Referred by: http: I Iwww.puc. state. id. usl scripts/polyform. dIll ipucUser Address: 67.234.149.User Hostname: 67.234.149.
Jean Jewell
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From:
Sent:
To:
Subject:
Ed Howell
Thursday, March 14, 2002 12:34 PM
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WNW Form Submission:
Thursday, March 14, 2002
12:34:21 PM
Case: GNR-E-02-01
Name: David F. Luck
Street Address: 26 Del Prado
City: Lake Oswego
State: OR
ZIP: 97035
Home Telephone: [phone]
E-Mail: dfluck0aol. com
Company: statewide ap~ication
mailing list yes no:
. '
yes/
Comment -descriptIon: '~oduction:My name is David F. Luck, and thesse comments are based on both my current position with
enXco, and my 28 years in the power generation industry. Those 28 years include directexperience with all technologies utilized as "Qualifying Facilities
" ("
QFs ) under PURPA(hydro, wind, solar, waste fuel plants, and cogeneration)
EnXco is the world's leading operator of wind turbines, and has U. S. headquarters in Palm Springs, CA. enXco has committed significant resources to Idaho, since the summer of2001, with the objective of developing viable wind energy projects in the state. EnXcohas installed "met towers , to accurately measure wind energy (the first step in windproject development), at Notch Butte Farms (between Jerome and Shoshone, ID), and will beinstalling additional met towers at a number of locations in southern Idaho when the snow
melts sufficiently to allow access to the higher sites. I have worked closely with theIdaho Department of Water Resources (Energy Division) to increase awareness of thebenefits of wind energy by speaking at conferences on the subject, speaking to groups likeIdaho Farm Bureau, speaking with state and county officials, and by meeting with ranchersand farmers interested in "harvesting the wind" on their property.
Comments:
To allow renewable energy and energy-efficient cogeneration to contribute to meeting thegrowing electrical energy needs of Idaho, it will be necessary to adjust the current
(1994) structure of rates paid for the energy produced by such QFs. Because mostQualifying Facilities are constructed using private funding, it is essential that they beprovided with a reasonable price for the product (electrical energy), and that thecontract for the energy be of sufficient time to support the investment. The currentspecified contract duration of 5 years is insufficient, and the Commission should considera more reasonable period of 20 years.
Like many other construction related activities, QFs benefit from "economy of scale Thecurrent limit in Idaho of 1 megawatt is well below the size necessary for cost effective
projects - either based on renewable energy technologies or cogeneration. If Idahoadopted the original Federal specification of 80 megawatts, construction of QFs of alltechnologies would become feasible in Idaho.
On the subject of QF size, let me note that enXco sees the future of wind energy in Idaho
as based on a number of modest proj ects (between 20 and 80 megawatts) at locations spreadacross the state. Our position is based on the fact that "commercial quality" windresources are based on localized terrain features, and on the fact that smaller, diversesi tes are more beneficial to the electrical transmission system - a form of "distributedgeneration" which has the potential to improve electrical service in remote rural areas.
If the Commission acts to liml t a revised program to proj ects located in Idaho, thesehomegrown" wind and biomass generation proj ects offer the opportunity for Idaho farmersranchers to secure much needed alternate revenue streams, and for industrial operations toreduce their overall energy costs through cogeneration. Taking advantage of theseopportuni ties is essential if Idaho s industry and agriculture is to continue to be
competi ti ve in the national (in many cases international) marketplace. The continuedviabili ty of farms, ranches and industry in Idaho should be of direct and critical
interest to the Commission: Failure of farms and ranches will result in significant
reductions reduction in utility revenues as the irrigation pumps are shut down, andshuttered industrial facilities will remove steady loads that are the lifeblood of Idaho
utilities. The remaining ratepayers (residential and light commercial) will be required
to pick up the "slack"
In closing, I urge the Commission to conduct public hearings on this critical matter. Myextensi ve experience working with utili ties in many places, and, more recently, withfarmers and ranchers in Idaho, gives me an appreciation for the complexity of this issue.I suggest that it can only be properly acted on after the parties that will be affected
have had the opportunity to present the facts.
Respectfully,
David F. Luck
Transaction ID: 3141234.Referred by: http: I Iwww. puc. state. id. us I scripts/polyform. dIll ipucUser Address: 152.163.207.177User Hostname: 152.163.207.177
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Jean Jewell
From:
Sent:
To:
Subject:
Ed Howell
Thursday, February 07, 2002 12:45 PM
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WNW Form Submission:
Thursday, February 07 , 2002
12:45:21 PM
Case: GNR-E-02-01
Name: Christopher Scott HarrimanStreetAddress: 528 Ballingrude Dr.
Ci ty: Twin Falls
State: Idaho
ZIP: 83301
Home Telephone: [phone]
E-Mail: harriman0pmt. org
Company: Idaho Power
Comment description: Dear Commissioners,
As a Plant Manager for two 10MW gas turbine cogeneration
have a vested personal and professional interest in this
contracted under the old rules and would not exist under
contracting of power from new Qualifying Facilities.
facilities in southern Idaho, Iissue. The plants I manage were
the present rules governing the
The current rule makes it virtually impossible for a developer to retrieve the project'
capital expenditure in the 5 year time frame, since the energy rate required to recover
captial expenditure is much greater than that required with a contract of a longer term.
Naturally, it is virtually impossible to receive proj ect financing as well.
The 1 MW limitation eliminates nearly all viable stear~ Host facilities since almost
without exception the steam requirements for most production facilities is at least ten
fold the amount of steam a 1 MW gas turbine can provide. In fact, most industrialfacili ties with a steam requirement will require more than thirty times the amount a 1 MW
facil ty is capable of providing. Such a limitation is a complete disincentive to both the
potential developer and the any potential Host facility. Clearly, with only two QF
contracts being issued by Idaho Power since the new rules were inacted, the proof is in
the pudding. If the rule as stated was intended to promote system diversification, that
certainly hasn t happened. If the rule was intended to promote opportunity for
development outside the framework of the utility, that hasn t happened either.
I believe that if the Commission believes that it is desireable to see new Qualifying
Facili ties developed in the State of Idaho, then a return to the old rules are the minimumthat should be done. An even better approach would be to survey potential Host facilities
throughout the state, and from that derive a more suitable sizing limitation, which,
without a doubt, would be larger than 10 MW. As I said before, the five year contract
limitation dramatically raises the rate that the developer must be paid to recover the
proj ect 's capital expenditures. Raising the contract term limit back to twenty years will
allow the developer to operate profitably at a much lower rate to utility, and finally to
the consumer.
I find it interesting that Idaho Power is very concerned with the amount they have to pay
for electricity from outside sources, but is less concerned when paying for new capacitywithin it's own facilities as evidenced by the fact that all recent new capacity within
Idaho Power is being paid for without exception, at a higher rate than they pay for the
power our facilities deliver to them. I think that they now realize the true cost of
developing and operating new facilities.
Transaction ID: 271245.Referred by: http: I Iwww. puc. state. id. usl scripts/polyform. dIll ipuc
User Address: 216.83.68.129User Hostname: 216.83.68.129
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Jean Jewell
From:
Sent:
To:
Subject:
Ed Howell
Tuesday, March 12 , 2002 11 :08 AM
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WNW Form Submission:
Tuesday, March 12, 2002
11:07:56 AM
Case: GNR-E-02-01
Name: Valerie K ChisholmStreetAddress: 19073E Hwy 30
City: Buhl
State: ID
ZIP: 83316
Home Telephone: [phone]
E-Mail: highride0mindspring. com
Company: Idaho Power
mailing list yes no: no
Comment description: I support the resestablishment of longer contracts for PURPAproj ects of renewable energy sources. The solutions to our energy problems must be based
on long-term planning that provides an avenue for sustainable energy sources, particularlywind and solar, to take hold. What we need are small, local (demand site) systems that canaugment our energy independence and that can be more responsive to our responsibility to
ensure a cleaner environment. At the same time, we must all refocus our definition of needand examine our incessant, wasteful consumption.
Thank you for your attention to this matter, and please keep focused on getting everyone,the public and the industries, to examine their energy consumption. We need education and
financial support to get us out of the wasteful past and into a sustainable, green future.
Valerie K Chisholm
Transaction ID: 3121107.
Referred by: http: I Iwww.puc. state. id. usl scripts/polyform. dIll ipucUser Address: 67.234.149.196User Hostname: 67.234.149.196