20120314Opposition to Idaho Power Motion.pdf

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Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservtion.org
Attorney for Idao Conservtion Leage
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RECENEO
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UT\LrfIES COMM\S
BEFORE TH IDAHO PUBLIC UTITIS COMMISSION
IN TH MAlTR OF TH )
COMMISSION'S REVIEW OF PURPA )
QF CONTRCT PROVISIONS )INCLUDING TH SURROGATE )
AVOIDED RESOURCE (SAR) AND )
INTEGRATED RESOURCE PLANING )
(IRP) METHODOWGIES FOR )
CALUIATING PUBLISHED AVOIDED )COST RATES. )
CASE NO. GNR-E-ll-03
OPPOITION TO IDAHO POWER'S
MOTION FOR TEMPORARY STAY
OF ITS OBLGATION TO ENTR
INTO NEW POWER PURCHASE
AGREEMENTS WITH QUALGFACIlS
The Idaho Conservation League opposes Idaho Power's motion. While the Company claims their
prefied testimony and documents filed to support this motion "inargubly makes a prima facie
showing," in reality this testimony is just a one-sided view of the facts applicable to this case.
Motion at 3. The Commission should allow other paries to contest these asserions before
deciding if any of them are indeed incontrovertible facts.
Furer, the Company's claim they expect a ruh of developers seeking new contrcts is
just that, a claim not a fact. The Company's position on this issue in this case should be
compared to how the Company treats potential PUR A projects durg the Integrted Resource
Planing process. In the IRP the Company states they "canot accurately predict the level of
futue PUR A development" so they only consider those projects with signed contracts. 2011
IRP at 33. In support of the curent motion, Idao Power establishes a new stadad for the
likelihood ofPURPA development, those projects that move "beyond just a phone call and onto
more serious inquiries within the last six months." Allphin Declaration at 2. .The Commission
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ICL's Opposition to Idaho Power's Motion i March 14,2012
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should reject this self-serving change in stadads, paricularly since the Company does not
define the "more serious inquires" that leads them to believe every potential QF wil come to
frition.
In order to make an informed decision about the facts supporting this motion ICL urges
the Commission to provide other paries a real opportity to respond. Two days time to deal
with the varety of factul claims made by the Company is simply insuffcient. While ICL does
not have a specific proposal on fuer proceedings on this motion, we do hereby reserve our
right to be heard.
WHEREFORE, ICL respectfully requests the Commission deny Idao Power's motion.
DATED thi 14th day March of 2012.
~Siimitted,~
Benjamin J. Otto
Idao Conservtion League
ICL's Opposition to Idaho Power's Motion 2 March 14,2012