20101118Answer in Opposition.pdf

om~~
r:'" (' ç:t,t:v~
\' i' '36
1\\\~ "0'4 \ ß l .
MILK PRODUCERS OF IDAHO
IDAHO WHEAT & AGRICULTURE CENTER
PO Box 2751
Boise, ID 83701
208/345-1190
brenttW m pida ho.com
Ms. Jean Jewell
Commission Secretary
;Mo Public Utilties Commission
:472 W. Washington
Boise, ID 83702
RE: GNR-E-IO-04
Dear Ms. Jewell:
\ì¡\hÜ
Ui\\Jt\ì:.S
We are enclosing an original and seven copies of this ANSWER IN OPPOSITION TO
JOINT MOTION TO ADJUST PUBLISHED AVOIDED COST RATE ELIGIBILITY CAP BY THE MILK
PRODUCERS OF IDAHO in the above case.
Would you please file the same?
Thank you for your attention to this matter. Please feel free to give me a call if you have any
questions.
J. Brent Olmstead, Director
Milk Producers of Idaho
,
,~
RECEl!
November 18, 2010 291û NOY l 8 PM 2: 36
o
üUTI ~.~ ¡
MILK PRODUCERS OF IDAHO
IDAHO WHEAT & AGRICULTURE CENTER
PO Box 2751
Boise, ID 83701
208/345-1190
brenttWmpidaho.com
The Milk Producers of Idaho (MPI) is a dairy industry trade association comprised of dairies and
associated industries in Idaho. It is with this background that we respectully submit this letter
in opposition to CASE NO. GNR-E-IO-o4 - THE JOINT PETITION OF IDAHO POWER COMPANY,
AVISTA CORPORATION AND ROCKY MOUNTAIN POWER TO ADDRESS AVOIDED COST ISSUES
AND JOINT MOTION TO ADJUST THE PUBLISHED AVOIDED COST RATE ELIGIBILITY CAP.
Members of MPI have spent millons of dollars over the course of the past decade in research,
construction and operation of anaerobic digesters. The purpose behind this expense is twofold:
1. To answer a growing concern with waste products produced at the dairy and
2. To provide a consistent reliable form of power in the community in which the industry is
located.
While a system that completely answers the above concerns has yet to be constructed, the
industry continues to work toward that goal with ongoing research and the construction of
prototype digesters. A key to the success of this research is to have a customer to market the
resultant energy production.
It is a fear that should this petition from the Utilty industry be accepted by the Commission,
especially under a modified procedure, that the incentive for the Utilties to deal in good faith
with the dairy industry will no longer be preseflt.
The Joint Motion requests Commission determination on the eligibilty cap issue in less than 14
days from the )oint Motion's purported date of service, November 5, 20:iO.Forthe reasons
stated in this letter,the ""ilk Prody~ers of Idaho oppose the Joint iyot,OI1, and respectfully
requests that the Idaho Publiç Utilitie~CQlmission (the "Çomrnission'!) t;eny ,the Joirit Motion
for expedited disposition.
The Commission should allow a reasonable time for all adverse parties to present evidence or
argument in opposition to a reduction in the eligibilty cap for the published avoided cost rates.
It is the opinion of MPI that an order of this magnitude should be completely vetted with both
the public and with impacted parties (such as the Idaho Dairy Industry).
;
Should the Commission determine that the normal procedure for determination of cases of this
magnitude be used, MPI and the Idaho Dairy Industry wil participate in the public hearings and
provide educational materials to demonstrate a definite harm to the industry by this order.
Additionally MPI would like to endorse comments submitted by the lR. Simplot Company
regarding the exclusion of Non-Wind PURPA resources:
"It is clear that the driving force and sole concern 0/ the Power Companies, in their
request to reduce the eligibilty cap for published PURPA rates, is the amount 0/ wind
resources being offered by the development community. Not once does the Joint Petition
refer to problems associated with biomass, cogeneration, solar, small hydro, waste-to-
energy projects or any other type 0/ PURPA eligible QF resource. These other types 0/
resources have very diferent generating characteristics from wind and should there/ore
not be caught in the overly broad sweep 0/ the Join Motion. II
Thank you for the opportunity to submit this letter of opposition. Should you have any
questions feel free to contact me at any time.
Respectfully submitted
J. Brent Olmstead, Director
Milk Producers of Idaho