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Boise, Idaho 83701-0167 - [phone] .
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March 11 , 2002
Idaho Public Utilities Commission
PO BOX 83720
Boise , 1083720-0074
CASE NO. GNR-02-
Dear Commissioners:
On behalf of the more than 52 000 member families of the Idaho Farm Bureau, I
am pleased to comment in the matter of the investigation of the continued
reasonableness of current size limitations for PURPA QF published rate eligibility
and restrictions on contract length.
Our members are very interested in developing various forms of distributed
generation including anaerobic digestion , small hydro units, wind , and possibly
biomass and geothermal. All of these forms of generation are completely
renewable and will help to strengthen the existing power grid by firming the grid
with a greater diversity of generation as well as distributing generation around the
state and closer to load centers.
Other benefits of these small, renewable projects include diversifying farm
income, thus assisting farmers to maintain a viable farm operation which
strengthens the local economy, and they will also assist in solving several
perceived and real environmental concerns such as dairy odor, waste
management, crop residue disposal , etc.
Dairies now contribute more to the state economy than any other segment of
agriculture. Unfortunately, they are also becoming the most heavily regulated
segment of agriculture because of perceived environmental concerns stemming
from the number of animals concentrated into relatively small areas. An
innovative and effective way to alleviate these concerns is to divert manure from
dairies into anaerobic digesters that convert the manure into methane and other
flammable gasses that are burned to generate electricity. This not only solves
the odor and nutrient management concerns effectively, but it also provides a
renewable, reliable source of electricity which was the purpose of PURPA when it
was enacted in 1978.
Another emerging technology takes crop residue, such as wheat straw, and finely
chops it and then injects it using compressed air into a combustion chamber.
Home Office: P.O. Box 4848 - 1001 N. 7th Avenue. Pocatello, Idaho 83205-4848 . [phone]
Idaho Farm Bureau Federation Comments
RE: CASE NO. GNR-02-
March 11 , 2002
Page 2
The material burns hot enough to efficiently power steam turbines. This
technology has the promise of helping to alleviate some of the concerns across
the state due to the burning of crop residue. However, they, like the anaerobicdigesters, cannot economically come to the market without a more friendly
regulatory environment.
Current PURPA limitations here in Idaho are too restrictive and do not allow
enough flexibility to effectively implement many of these innovative new
solutions. For example, an anaerobic digester for a 5 000 cow dairy can easily
cost $2 500 000 to construct. There is absolutely no way that a dairyman canfinance that large of a project with a five year contract. We request that the PUC
restore the PURPA contract length to 20 years as it was prior to 1994. This
would make it possible to use more traditional financing when a project can be
amortized over a twenty year contract period.
In addition , the one megawatt size limitation is too small. The operations that are
most in need of innovative solutions to their environmental concerns are the large
dairy operations. 5 000 cows can adequately supply a one megawatt anaerobic
digester. With the current PURPA size limitation, you are effectively taking away
a golden opportunity to both generate clean , renewable, reliable energy and also
help solve the nutrient management and odor concerns associated with the
larger dairies in the state.
It also limits the ability of several smaller dairies located close together from
cooperatively building a larger digester that they all can use, thus receiving thebenefits of economy of scale. Most biomass generators would also need to be of
a sufficient scale to be economically feasible. We believe that the pre-1994 sizelimitation of 10 megawatts is a much more reasonable standard.
Idaho has a great opportunity to utilize our vast agricultural resources to produce
clean , renewable energy at a reasonable price for the consumers while also
being innovative and proactive in our approach to environmental concerns.
We have an additional concern which is beyond the scope of this investigation
that we want to bring to your attention. The current interconnect process needs
some immediate attention. We have been told that a number of dairymen have
applied to Idaho Power under their current interconnect guidelines for a feasibility
study on the possibility of connecting anaerobic digesters to the grid. They were
Idaho Farm Bureau Federation Comments
RE: CASE NO. GNR-02-
March 11 , 2002
Page 3
required to pay thousands of dollars up-front only to be told six months later that
it would cost them more than $80 000 to connect to the grid for work which
should cost considerably less.
We readily admit that we are not electrical engineers and do not understand all
that is required to connect a generating facility to the grid. However, we have
been told by more than one source that the current process is quite outdated and
that current technology allows for a much safer and far less expensive
connection to the grid than Idaho Power seems to be willing to admit.
We respectfully request that the PUC investigate current interconnect procedures
as required by the utilities. We believe it is only fair that you require the utilities
to charge no more than the actual cost of interconnecting to the grid.
We appreciate the opportunity to comment on this most important matter.
CC:Robert J. Lafferty, Avista Corp.
Gregory N. Duvall, Pacificorp
Jim Fell , Pacificorp
John M. Eriksson , Utah Power and Light
Mark Widmer, Pacificorp
Barton L. Kline , Idaho Power Co.