20110422Representatives Comment.pdf

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LAWERENCE E. DENNEY
SPEAKER OF THE HOUSE
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House of Representatives
State of Idaho
April 21, 2011
The Honorable Marsha H. Smith
The Honorable Paul Kjellander
The Honorable Mack A. Redford
Idaho Public Utilties Commission
472 West Washington Street
PO Box 83720
Boise, 1083720-0074
RE: Case No. GNR-E-11-01
IN THE MA TTER OF THE COMMISSION'S INVESTIGA TION INTO
DISAGGREGA TlON AND AN APPROPRIATE PUBLISHED AVOIDED COST
RA TE ELIGIBILITY CAP STRUCTURE FOR PURPA QUALIFYING FACILITIES
Dear Commissioners Smith, Kjellander, and Redford:
As you may be aware, the Idaho legislature dealt with numerous issues related to the
state's policy on wind and alternative energy this last legislative session. As anyone
can see by the hundreds of wind turbines located throughout our state, the once
nascent and fledgling wind industry has now fully developed and taken hold in Idaho.
As members of House Leadership, we are pleased to see that we have created a
positive business climate for the development of environmentally sustainable energy
resources.
We are concerned, however, that we may be going too far by setting policy that requires
Idaho's investor owned utilities to purchase energy at prices that subsidize project
developers to the detriment of Idaho's ratepayers. The Commission's previous policy
has allowed projects to artificially disaggregate into 10aMW increments to take
advantage of higher, published avoided cost rates, has created an operational burden
for Idaho's electric utilities, and, more importantly, wil lead to higher energy rates for
Idaho consumers. We are also concerned about the increasing amount of variable and
intermittent energy being introduced onto the utilities' system and the potential effects
that may have upon system reliability and customers' rates.
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That is why we, as members of House Leadership, voted in support of HB 348. This
important piece of legislation would have set the eligibility cap at 100 kw for wind and
solar energy projects seeking published avoided cost rates. We supported this
legislation because it would have required wind and solar projects larger than 100kw to
negotiate with the purchasing utilities on prices that are more in-line with the utilities'
actual avoided costs and need for energy. Since these costs are passed-through to
Idaho's ratepayers, it is critical that the utilities pay no more than what they would have
otherwise paid for the same type of energy.
We are aware that the Commission recently set the published rate eligibility cap at 100
kw on a temporary basis and opened this docket to work through both the
disaggregation and price issue for qualifying facilities. As part of this proceeding, we
urge the Commission to consider setting the published rate eligibility cap at 100 kw on a
permanent basis. Making this policy permanent would align Idaho's published rate
eligibility with federal regulations and require developers to negotiate a fair price for
ratepayers with the utility.
Through the Commission's leadership, Idaho has had a long history of offering
businesses and consumers reliable energy at reasonable rates. We must set
appropriate energy policies that ensure this wil continue into the future.
Very truly yours,t7a-7
Lawerence Denny
Speaker of the House'~~
Mike Moyle
Majority Leader~~
Scott Bedke
Assistant Majority Leader949t
Ken Roberts
Majority Caucus Chair
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