20101220Comments.pdf

Twin Lakes Canal Company
PO Box 247
2 North State
Preston~ Idaho 83263
Tel [phone]
Fax [phone]
email: contact((twinlakescanalcompany.com
December 20, 20 lu
Jean Jewell
Commission Secretary
Idaho Public Utilties Commission
P.O. Box 83720
Boise~ ID 83720-0074
jea.jewell~puc.idaho.gov
RE: Case No. GNR-E-lO-04
Dear Commissioners:
E!
ZOIO OEC 20 AM II: 37
1be Bear River Narows Hydroelectric Project is proposed by the Twin Lakes Canal Company
as a centra component of its plan to upgrade its irrigation water delivery system. This plan has
two primary objectives: i. To improve water conservation by replacing open canals with closed
pipelines, and 2. Provide for storage and release of water in the event of emergency drought
conditions. The power generated by the dam would provide a clean, renewable resource without
being held hostage by oil-rich countries or polluting, coal fired plants. The sale of hydroelectric
power will provide revenue for these system upgrades.
We are a small Canal Company and we have spent milions of dollars on our hydro application.
We are relying on this development of hydro to help with the development of our irrigation system.
We have anticipated the continuation of these rates, so that it wil be a benefit to our farmers in our
irrigation company. We write to request hydro eligibility up to 10,000 Kilowatts at standard rates be
continued.
Thank you for your consideration,
~~K~~~tBosen
Twin Lakes Canal Company, President
1630 WEBSTER LANE
DILLON, MT 59725
PHONE: [phone]
FAX: [phone]
CCIMTêMSN.COM
December 17, 2010
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
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9?w\.
RE: Case No. GNR-E-l0-04 Joint Petition to Reduce the Available Avoided Cost from 10,000 Kilowatts
to 1,000 Kilowatts
Dear Commissioners:
This letter is written to request that the current methodology for avoided costs and the current
eligibility up to 10,000 Kilowatts be continued for QF hydro in the State of Idaho. The rates available for
small hyqropawer have been in place since 1981-1982 and have resulted in a moderate amount of small
hydro being developed in the State of Idaho. The hydros are distributed primarily throughout southern
Idaho associated with irrigation facilities. This distributed generation has resulted in clean renewable
resource being developed utilizing irrigation water and providing an economic return to the agricultural
base of southern Idaho. While many of the small hydro plants have been developed, there are more
that could be developed. I have already made a considerable investment in a project near Leadore, 10
on the assumption that there would be a market through the avoided costs rates set forth by the Idaho
Public Utilities Commission. I know of several others in the process of being developed based on the
same assumption. These plans generally range from 500 kilowatts up to 3 or 4 megawatts. In addition,
many of the small hydropower plants that were built in the early to mid 80's will have contracts expiring
in another 5 to 10 years. It is important to have a continued market for our power. While we recognize
the problems associated with wind, we do not believe that they should be placed at the feet of small
hydro. We believe that small hydro should be allowed to continue. Therefore, we respectfully request
of the commission the following:
1. That the maximum eligible rates for small hydro be continued at 10,000 kilowatts.
2. The avoided cost model of the natural gas-fired plant is a non-renewable energy resource. We
strongly believe that ownership of any environmental attributes or Renewable Energy Credits
"REC's" be associated with power salesby small hydro be owned by the developer ofthe
project. We request PUC concurrence.
Thank you for taking this information into account when considering this case.
Sincerely,
::Au. I¿ (l~ by )n£~
Fred R. Coleman
President, Coleman Construction, Inc.
CC: Nick Josten, Geosense
f '
f! GeoSense
2742 St. Charles Ave
Idaho Falls, '.,0 83404
gsense(gcableone. net
t
December 17, 2010,l
ZßlO DEC 20 AM 8= 1+ 7
Jean Jewell
Commission Secretary- Idaho Public Utilties Commission
P.O. Box 83720
Boise, ID 83720-0074
RE: Case No. GNR-E-l0~04 Joint Petition to Reduce the Available Avoided Cost from 10,000 Kilowatts
to 1,000 Kilowatts
Dear Commissioners:
This letter is written to request that the current methodology for avoided costs and the current
eligibilty up to 10,000 Kilowatts be continued for QF hydro in the State of Idaho. The rates available for
small hydropower have been in place since 1981-1982 and have resulted in a moderate amount of small
hydro being developed in the State of Idaho. The hydros are distributed primarily throughout southern
Idaho associated with irrigation facilities. This distributed generation has resulted in clean renewable
resource being developed utiizing irrigation water and providing an economic return to the agricultural
base of southern Idaho. While many of the small hydro plants have been developed, there are more
that could be developed. I know of several in the process of being developed that are anticipating
having a market through the avoided costs rates set forth by the Idaho Public Utilities Commission.
These plants generally range from 500 kilowatts up to 3 or 4 megawatts. In addition, many of the small
hydropower plants that were built in the early to mid 80's will have contracts expiring in another 5 to 10
years. It is important to have a continued market for this power. While we recognize the problems
associated with wind, we do not believe that they should be placed at the feet of small hydro. We
believe that small hydro should be allowed to continue. Therefore, we respectfully request of the
commission the following:
1. That the maximum eligible rates for small hydro be continued at 10,000 kilowatts.
2. The avoided cost model of the natural gas-fired plant is a non-renewable energy resource. We
strongly believe that ownership of any environmental attributes or Renewable Energy Credits
"REC's" be associated with power sales by small hydro be owned by the developer of the
project. We request PUC concurrence.
Thank you for taking this information into account when considering this case.
Sincerely, " ,.' ",
~o~~'
President, GeoSense~'¡daho Falls,ID
Big Wood Canal Company
~-:::~~ ~::~: ~~~; lftlftDEC 20 ~," 8:21
TeL. [phone] Fax [phone]
December 17, 2010
Commissioner
Idaho Public Utities Commission
Re: Case No. GNR-E-I0-04 Joint Petition to Address Avoided Cost Issues and
Joint Motion to Adjust and Publih Cost Rate Eligibilty Cap
Dear Commissioner:
I am writing this letter in opposition to the Petition as it relates to small
hydropower in the State of Idaho. We currently own and operate 3 hydro plants
within our irrgation project and have since 1983. We feel that the current
methodology for avoided cost and the eligibilty up to 10,000 Kilowatt needs to be
continued for QF hydro in the state of Idaho. We plan to develop at least one
additional hydro plant and are puruing a license for this project in anticipation of
having a market through the avoided cost rates set forth by the Idaho Public
Utities Commission. Small Hydro has none of the issues related to intermittency of
wind and therefore, should not be included with wid considerations. We believe
that small hydro should be allowed to continue under the existig avoided cost
methodology.
Please take this into account when considerig this case.
Sincerely,
Lynn Harmon,
General Manager