20110513Rep. Rusche Comment.pdf

John Rusche
DISTRICT 7
Nez Perc Coty
COMMITTEES
Reven and Tax
HOME ADDRESS
1405 2"f Avenue
Lewston, Idaho 831 Heah & Welf
BusineHOME (20) 7431339jrue(ho.ida.gov
House of Representatives
State of Idaho
Minority Leader
May 12, 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, ID 83720-0074
RE: Case No. GNR-E-11-01
IN THE MA ITER OF THE COMMISSION'S INVESTIGATION INTO
DISAGGREGATION AND AN APPROPRIATE PUBLISHED A VOIDED 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. Hundreds of wind turbines have been built
throughout our state and the once fledgling wind industr has taken hold in Idaho. As a member of
House Leadership, I am pleased to see that we have created a positive business climate for the
development of environmentally sustainable energy resources.
I have become concerned, however, that some policies may be counterproductive. Some energy
development projects have been able to artifcially disaggregate into 10aMW increments to take
advantage of higher, published avoided cost rates.
That is one of the reasons why I voted in support of HB 348. That important piece of legislation would
have set the eligibilit cap at 100 kw for wind and solar energy projects seeking published avoided cost
rates. This legislation would have required wind and solar projects larger than 100kw to negotiate with
the purchasing utilities on prices paid for the energy purchased. that are more in-line with the utilties'
actual avoided costs and need for energy. Since these costs are passed-through to Idaho's ratepayers,
it is critical that the customers pay not be saddled unnecessarily with excess costs.
May 12,2011
Page 2
I am aware that the Commission recently set the published rate eligibilty cap at1 00 kw on a temporary
basis and opened this docket to work through both the disaggregation and price issue for qualifing
facilties. As part of this proceeding, i suggest that the Commission to consider setting the published rate
eligibilty cap at 100 kw on a permanent basis. Making this policy permanent would align Idaho's
published rate eligibilty with federal regulations and require developers to negotiate a fair price for
ratepayers with the utility.
I appreciate the Commission's leadership in assuring that Idaho continues to offer businesses and
consumers reliable energy at reasonable rates while looking to the best mix of energy sources for the
future.
Sincerely,
John Rusche