20070111Comment.pdf

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Comments of the NW Energy Coalition and Renewable Northwest Project
On Idaho Power s Application for Power Purchase Agreement with Telocaset Wind Power
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:D'The NW Energy Coalition (NWEC) and the Renewable Northwest Project (~5 ::3:
appreciate the opportunity to provide these comments relating to Idaho Power Comp~y~c:?
Application for Approval of a Power Purchase Agreement with Telocaset Wind Pow ParttJs
LLC., in Case No. IPC-06-31. This is not an intervention request, but rather a COmnIent on the
pending request in this docket.
Submitted by
Ken Miler, NWEC
And Troy Gagliano, RNP
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Jan. 10,2007
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With this submittal, NWEC and RNP support the PP A as beneficial to both utility
ratepayers and the furtherance of renewable energy in the Company s portfolio. This PPA and
the fulfillment of the Company s wind RFP is long overdue, and the Coalition welcomes it. In
addition, the Coalition supports an expedited proceeding in this case.
The Elkhorn Wind Power Project Is a Reasonable Renewable Enere;v Addition for Idaho
Power and Its Customers
NWEC and RNP agree with Idaho Power that inclusion of the TelocasetIHorizon Wind
Energy Elkhorn Wind Power Project in the company s portfolio will benefit ratepayers and will
help the Company work to achieve the renewable energy goals as specified in its 2004 and 2006
Integrated Resource Plan.
The Power Purchase Agreement (PP A) and its initial base rate of $48/MWh establishes
this long-overdue wind resource as competitive with other resources and as a good bet for
ratepayers. In fact, that price and its 3 percent annual escalation rate will make this resource one
of the most cost-effective of all generation resources identified in its 2006 Integrated Resource
Plan (IRP).
The Eastern Oregon location of the Elkhorn Project and its proximity to the LaGrande-
Brownlee 230 kV transmission line also fits well with plans in the Company s 2006 IRP to
upgrade its McNary-Boise transmission infrastructure.
Wind Forecastin2 Data Commitments in PP A Should Be Precedent-Settin2
NWEC and RNP are enthusiastic about provisions in the PP A that commit Telocaset to
provide the Company with detailed, real-time wind forecasting data. While the inherent value of
adding a wind resource in the location of the Elkhorn Project is manifest in its spreading the
geographic diversity of the Company s developing wind portfolio, the ability to provide the
Company with day-ahead and even hour-ahead forecasting data should significantly enhance the
Company s ability to cope with the variability of its wind assets.
We expect that the combination of enhanced forecasting along with the geographic
diversity this project provides the Company can only serve to make the number of pending
Idaho-based wind projects more attractive to Idaho Power.
NWEC and RNP believe strongly in the growing sophistication of wind forecasting tools
as well as the value they bring in reducing delivery uncertainties and as a result making it
possible to integrate even greater quantities of this important resource in to the portfolios of
Idaho s regulated utilities. It's our hope that the forecasting provisions in this PPA set a
precedent that other utilities and wind energy suppliers will follow - particularly given the
Company s observation that the Elkhom Project is a resource that will parallel Idaho Power
seasonal load shape.
Summary.
NWEC and RNP believe this PPA is in the best interest of Idaho Power CO.s ratepayers
as well as for the continued development of renewable energy resources in Idaho. The
geographic diversity of the Company s wind portfolio will be of value in allowing more wind to
be integrated from Qualifying Facilities and other wind energy developers in Idaho.
NWEC and RNP recommend the PUC approve this PPA, and also that this docket be
processed in an expedited fashion through a modified procedure. We appreciate the opportunity
to comment on this docket.
Respectfully submitted
Ken Miller
Idaho Energy Advocate
NW Energy Coalition
5400 W. Franklin, Suite G
Boise, ID 83705
[phone]
kenmillerifYnwenergv.org
www.nwenergV.org
Troy Gagliano
Senior Policy Associate
Renewable Northwest Project
917 SW Oak, Suite 303
Portland, OR 97205
[phone]
troyifYmp.org
www.rnp.org