20101222Comments.pdf

BLUE RIBBON ENERGY LLC
4515 South Amon Road
Amon, Idaho, 83406
208-524-2414
CEt\l
2ßnnlEC 22 AM 8: 32
lOi~\J"IO
UTIliTIESBEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
PETITION OF IDAHO POWER
COMPANY, AVISTA CORPORATION,
AND PACIFICORP DBA ROCKY
POWER TO ADDRESS AVOIDED COST
ISSUES AND TO ADJUST THE
PUBLISHED AVOIDED COST RATE
ELIGIBILITY CAP
Case No. GNR-E-1O-04
ORDER NO. 32131
COMMENTS BY BLUE RIBBON
ENERGYLLC
Comes Now Blue Ribbon Energy LLC and respectfully submits the below comments
regarding the above Joint Petition Order number 32131 and the above referenced Petition
pursuat to the Commission's Order.
Blue Ribbon is opposed to lowering the Published Avoided Cost Rate Eligibilty Cap as
requested in the above referenced Joint Petition for the following reasons:
1 It is unecessary.
2 It is a financial ploy by the Utilties to gain an unair advantage in Wind Development
over private developers. Please don't be fooled by this Joint Petition Ploy.. The Utilties'
attitude supporting the elimination of private developers, by any means possible,
especially if they can elicit the help of the Commission, which of course would
completely undermine federal law (PURP A ACT), is best exemplified by a recent
statement by Bruce Griswold of Pacificorp to Blue Ribbon Energy LLC, wherein he
stated, "I wish all you private developers would just go away."
3 An analysis of the proposed Strawman,initiative of the IPUC Staff and of the avoided
cost rate formula or new published avoided cost rates for wind can be accomplished by
the Commission without suspending or setting a new moratorium on Wind Far
Development in the State of Idaho. There is not rational justification supporting the
Petition.
4 There are wind far projects under development at this very time, into which private
developers have, and are in the process of, expending huge amounts of time and effort
and money, not to mention the collateral damage to other manufactuers and existing and
potential employees, jobs, and job losses, which would essentially be effectuated if the
aforesaid Petition for a moratorium (which is essentially what is being requested) is
granted by this Commission.
5 If the Commission were to consider ths requested/petitioned moratorium, cleverly
disguised as a petition to temporarily "cap" PURP A eligibilty for published avoided cost
rates (lowering the cap of eligibility to 100 kilowatts is essentially a moratorium) then it
should also Order the Petitioning Utilties to immediately suspend and stop all their own
utilty wind development projects within and without the State of Idaho, placing them in
the same financial jeopardy as they are requesting the IPUC to do to other non-utilty
wind developers. Placing every wind developer, including the utilties, on hold, would be
the only fai approach to leveling the playing field. Of course the Utilties wouldn't want
a moratorium on their out-of-state wind far developments - especially after requesting a
ratepayer rate increase to fud such wind developments - but that would be the only fair
approach - wouldn't it? - if a moratorium or cap were to be granted by this Commission.
6 The above referenced Joint Petition has been fied to eliminate any private wind
development competition from private developers, while the utilties move forward with
their own wind development - which will place the utilties in a position in the future to
claim and argue to the Commission, that all their wind power needs and goals are met, or
are substantially met, with respect to wind, through their own wind development, which
defeats the very purose of the National Energy Conservation Policy Act of 1978
(Public Law 95-617) which included the Public Utilty Regulatory Policies Act of
1978, as well as the Energy Policy Act of2005 (Pub Law 109-58) and so forth. The
Commission should NEVER allow itself to be seduced into this trap by the Utilties,
causing the Commission to essentially contravene the Federal law and it intent and
mandates.
7 PROPOSAL: What should happen, and Blue Ribbon Energy LLC respectfully submits
for the consideration of this Honorable Commission, that the State of Idao though its
Public Utilties Commission should immediately adopt as its own policy, and issue an
ORDER mandating, that all wind development in Idaho will follow the PURP A ACT
(1978) and the Energy Policy Act (2005) and immediately implement Title 16, Chapter
12, Sub-chapter I, §796(l7) of the United States Code - as set forth in the footnote below!
- and make, by Idaho IPUC definition, all PURP A QF facilties eligible for the Published
Avoided Cost Rate as set forth in the present published avoided costs, or better yet what
is published in the Strawman Poll, issued recently by the IPUC Staff, up to 80 MWs in
(l7)(A) , a facilty which is an
facilty,
(i)
geothermal resources, or any combination thereof;
solar, waste, or geothermal
of biomass, waste,
(ii)together with any other facilties located at the same site (as determined
anyone site. This would completely solve the curent debate initiated by the Utilties by
way of their aforesaid Joint Petition ruse. Furer, each wind far, up to 80 MW,
should/must be separated from any other wind far of 20 MW nameplate or more, up to
80 MWs, by not less than one mile (for example the nearest wind tubine of one 80 MW
far is separated by at least one mile from the nearest wind turbine of the next 80 MW
wind far).
8 The Joint Petition should be denied ab initio, with costs to all respondents and those
submitting comments. The Utilties should have to pay for this kind of non-sense at rate
payer expense, and the rate payers should be informed of this kind of nonsense by their
Utilty Companies, by the IPUC in a public declaration.
Respectfully submitted this 21 day of December, 2010.
Blue Ribbon Energy LLC
By MJ "umphries and Arron f. JelM
MemberslManagers
by the Commission), î$d.gã_Il~;ír.~_;
Jean Jewell
From:
Sent:
To:
Subject:
bonsai(Çcableone. net
Monday, December 13,20105:19 AM
Jean Jewell; Beverly Barker, Gene Fadness
PUC Comment Form
A Comment from Barry Schultz Sr follows:
-- - - -- - -- - ------- - - - - -- - - - - -- - - - - ---
Case Number: GN/t- ~-IO-O Lf
Name: Barry Schultz Sr
Address: 6319 Cougar ridge dr
City: Lewiston
State: Idaho
Zip: 83591
Daytime Telephone: [phone]
Contact E-Mail: bonsai~cableone.net
Name of Utility Company: avista
Acknowledge: acknowledge
Please describe your comment briefly:
Hello, I wanted to add my two cents to the mix. Oregon has a energy trust program, and its
working great. The state of oregon utility commision is the one who got this started. Hear in
the state of Idaho this type of program is a win/win for the consumer. Why not support a
programm like this? I know the powers to be in this state will not want or like such a
program, So its up to YOU. To get it going! Thank you and Happy Holidays!
The form submitted on http://www . puc. idaho. gov /forms/ipuc1/ipuc . html
IP address is 67.69.89.152
- - ----- ---- -- --- -- - - - - -- - -- - - - - - - - --
1