20101217Comments.pdf

Jean Jewell
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Sent:
To:
Subject:
rick~whispermountain. net
Friday, December 17,20103:40 AM
Jean Jewell; Beverly Barker; Gene Fadness
PUC Comment Form
A Comment from Rick Fawcett / William Frederiksen follows:
Case Number: GNR-E-10-04
Name: Rick Fawcett / William Frederiksen
Address: P.o. Box 131
City: Dubois
State: Idaho
Zip: 83423
Daytime Telephone:
Contact E ~Mail: ric~hispermountain. net Name of Utility Company: Rocky Mountain Power
Acknowledge: acknowledge
Please describe your comment briefly:
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION OF IDAHO POWER COMPANY, AVISTA CORPORATION, AND
PACIFICORP DBA ROCKY MOUNTAIN POWER TO ADDRESS AVOIDED COST ISSUES AND TO ADJUST THE
PUBLISHED AVOIDED COST RATE ELIGIBILITY CAP.
Case No. GNR-E-10-04
NOTICE OF JOINT PETITION
NOTICE OF MODIFIED PROCEDURE
NOTICE OF INTERVENTION DEADLINE
NOTICE OF ORAL ARGUMENT
ORDER NO. 32131
Written Comments of the Eastern Idaho Regional Solid Waste District
The Eastern Idaho Regional Solid Waste District ("District") is a political subdivision of
the State of Idaho formed by Clark, Bonneville, and Madison Counties who have the
responsibility for establishing, maintaining and operating a solid waste disposal system
pursuant to Idaho Code 31-4401, et seq.
The legislature of the State of Idaho has found and declared, pursuant to Idaho Code 31-4901,
et seq., that the disposal of solid waste wi thin the State of Idaho is an important public
purpose, and that the creation of independent regional districts to administer solid waste
disposal is an efficient and cost-effective method of meeting the state's solid waste
disposal needs.
The District has proposed to construct a waste-to-energy facility located in the service
territory of Rocky Mountain Power to meet these objectives.
The District has submitted an application for a Quali fied Facility (QF) contract to
PacifiCorp (dba Rocky Mountain Power) on August 25, 2010, and has reviewed terms and
conditions offered by PacifiCorp for a project whose generation is expected to exceed 10 aMW
per month.
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The District has submitted a revised application for a QF contract applicable to a non-fueled
project smaller than 10 megawatts as described in IPUC Order 29632 on November 26, 2010. The
District took these actions with the expectation of qua Ii fying for posted avoided cost rates
applicable to a project whose generation is expected to be less than 10 aMW per month as
published by the Commission on March 15, 2010.
Statement of Position
The Eastern Idaho Regional Solid Waste District ("District") opposes the Joint Utilities
Petition to "lower the published avoided cost rate eligibility cap from 10 aMW to 100 kW (to)
be effective immediately."
The District supports the position of the Milk Producers, Simplot, and the Coalition parties
to this proceeding that ~ny lowering of the eligibility cap should not apply to non-wind QFs.
In its deliberations, the District asks the Commission to take note of the following action
items contained in PacifiCorp's 2008 Update to its Integrated Resource Plan published on
March 31, 2010:
· Implement a bridging strategy to support acquisition deferral of long-term
intermediate/base load resources in the east control area (emphasis added) until the
beginning of summer 2015, .... (Item 2, Firm Market Purchases, 2010 - 2019, Table ES.2 - IRP
Action Plan Update)
This action item specifically calls for the acquisition of 200 MW of long-term power
purchases (presumably in the east control area comprising Idaho and Utah), and specifically
references PURPA QF contracts in this regard.
The March 31, 2010 IRP update also calls for Paci fiCorp (dba Rocky Mountain Power) to
proceed with the following action item:
· Procure through acquisition and/or company construction long-term firm capacity and
energy resources for commercial service in the 2012 - 2016 time frame (Item 3,
Peaking/Intermediate/ Base-load Supply-side Resources, Table ES.2 - IRP Action Plan Update)
The IRP states that the proxy resource in Paci fiCorp' s 2010 Business Plan consists of a Utah
wet-cooled gas combined cycle plant with a capacity rating of 607 MW, acquired by the summer
of 2015.
The District notes that Idaho Power Company has a gas resource under construction that is
substantially similar to the proxy resource contained in Paci fiCorp' s 2010 Business Plan.
The District request that the Commission ask these utilities to clarify the amount of costs
associated with these resources that each utility plans to recover through rates in the State
of Idaho for these resources. The Commission and parties to this proceeding could then
compare the projected costs on a Mwh basis with the posted avoided cost currently applicable
to a QF expected to generate less than 10 aMW per month.
The District believes that lowering the threshold for eligibility for posted avoided cost
pricing will result in few if any projects being developed over the next several years, with
the result that the utilities serving Idaho will not defer their plans to procure through
acquisition and/or construction long-term firm capacity and energy resources, which will
eventually cost Idaho consumers more than would the QF projects that could have been built
instead.
The Commission's attention to these comments is appreciated.
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Sincerely,
William Frederiksen
President, Eastern Idaho Solid Waste District
The form submitted on http://www. puc. idaho.gov/forms/ipucl/ipuc. html
IP address is 70.41.228.178
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