20040331Comment.pdf

Jean Jewell
From:
Sent:
To:
Subject:
Ed Howell
Tuesday, March 30, 2004 1 :38 AM
Jean Jewell; Ed Howell; Gene Fadness; Tanya Clark
Comment acknowledgement
WWW Form Submission:
Tuesday, March 30, 2004
1:38:16 AM
Case: IPC-E-04-
Name: Brian D. Jackson
Street Address: 7800 Alfalfa Lane
City: Melba
State: 10
ZIP: 83641
Home Telephone: [phone]
E-Mail: brian~clever-ideas. com
Company: Idaho Power Companymailinglist _yes _no: yes
Comment description: Renewable Attributes Case
Dear Commissioners and Staff:
I realize the official comment period is over for this case, however, I was discussing
this with Gene Fadness and he encouraged me to simply drop a note about it anyway.
The green tags are a commodity which have a huge
working with several farmers and ranchers across
opportunity to develop wind farms on their land.
farm going up near Idaho Falls this year.
variability in market usefulness. I
this state who are exploring the
I am the proj ect manager for a 3MW wind
I believe the green tags are completely not associated with Purpa and should very much
belong to the developers themselves. In fact, they are truly just a fabrication of value.
The key is all in how they are marketed and the value other people are willing to attach
to clean renewable energy sources. We are just beginning to see indicators of some
marketability in such sources of energy. I believe when the pain and risk of sourcing
energy from fossil fuels outweighs the cost and security of renewable sources, the value
will be more evident and such things will become more valuable.
My first thought is I would much rather sell my "green tags " to the utility with my Purpa
energy itself in the same contract or a similar one executed at the same time for
efficiency and simplicity. I would probably even take a lower rate than true market
simply for this value and perhaps a longer term. My belief is that if the utili ties would
market these concepts better, they could make a serious return on such renewableattributes. Then they would encourage more development and less dependence on fuel basedresources. Unfortunately, most utili ties have a form of a green tag program which is
disjointed and not even remotely connected to real projects. An example would be Idaho
Power not buying green tags from Bob Lewandows ki 's small wind proj ect in Mountain Home -
he didn t even hold out for a Purpa rate.
My concern is that if Idaho Power, or any other local utility had first right of refusal,
it would limit the marketability of something that is still barely marketable. Who would
have a serious negotiation with me when they know once we get to a price Idaho Power getsfirst right to buy them. That alone would de-value the green tags. If I negotiate with
Idaho Power first, how can we figure out a market price. It definitely can t be based on
their existing system of selling the tags - that doesn t even connect to anything inIdaho. I think the first right of refusal would play well into a renewable portfolio
standard...which is one of Idaho Power s fears on this issue. They probably should be
stepping up and developing a program to truly promote the green tags effectively so they
could offer a good price for the tags. Otherwise, a proj ect developer should be able to
market them to whoever does have a good marketing program and is willing to pay a premium
rate.
It sounds like the commission has decided to stay out of this issue and I thank you forthat decision. I just wanted to say that I think it was wise - I just wish there was a
system in Idaho that I could sell the tags into from the projects working on.
Sincerely,Brian D. Jackson, PE MBA CEM
Renaissance Engineering & Design PLLC
Transaction 10: 330138.
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