20101228Comments.pdf

.
Craig D. Hobdey
[phone]
HOBDEY LA WOFFICE, PLLC
125 Fifth Avenue West
Post Offce Box 176
Gooding, idaho 83330-0176
Facsimile
(29~) 93~4420_.; r.
December 22, 2010 ;~2, ~
en:'.',:::'!:". 1:JN..
Commission Secreta
Idaho Public Utilties Commission
PO Box 83720
Boise ID 83720-0074
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Re: Case No. GNR-E-IO-04
Inthe Matter ofthe Joint Petition ofIdaho Power Company, A vista Corporation, and
Pacificorp DBA Rocky Mountain Power to Address Avoided Cost Issues and to
Adjust the Published A voided Cost Rate Eligibilty Cap
Dear Commssioners:
ts;;t~:Aattm.ty.Jor s~yeralsmall.hYdr(),.C2~generati,:m facilties, we submit the followingcomments, in objection to the Petition fied above by Idaho Power et aL.
The . Petition does not indicate that any of the Petitioners are experiencing, nor do they
anticipate, any problems with maintaining the eligibilty cap regarding small hydro co-generation
facilties. To reduce the published avoided costs rate eligibilty cap at ths time would, in our
opinio~."unfairly hinder small power producers due to no fault of their own. A blanet reduction in
the published avoided cost rate eligibility cap is neither necessar nor appropriate.
Ifinf~ the wind prpdøs are tang unair advantage of the avoided cost rate eligibility
cap by dividtnglar vvptØêcts into smaller projects in order to utilize the published rates they,
the wind prucers, should be singled out and treated differently.
The Petition in effect, imposes a moratorium on PURP A projects in Idaho. As indicated, no
where in the Petition is there any reference to problems associated with small hydro projects.
Therefore, on behalf of our clients, we urge the commissioners to either deny the petition as
a whole, or to grant the petition only in as much as it refers to wind generation.
Tliankyouforyour apportunityto comment in this matter.
Sincerely,
~~
CDH:dm