20070926Tidwell Comment.pdf

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Jean Jewell
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ktinsv~cox.net
Tuesday. September 25, 2007 5:23 AM
Tonya Clark; Jean Jewell; Gene Fadness; Ed Howell
PUC Comment/Inquiry Form
A Comment from Kiki Leslie A. Tidwell follows:
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Case Number: :rpc..--b7 -0'/
Name: Kiki Leslie A. TidwellAddress: P.o. Box 2919
City: Ketchum
State: Idaho
Zip: 83340
Home Telephone: [phone]Contact E-Mail: ktinsv~cox. net
Name of Utility Compa Idaho
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Power
Please describe your question or comment briefly:
Recently, the Idaho PUC ruled in Case No. IPC-E-07-04 that utilities can also discount the
avoided cost rate paid to small power producers with a daily load shape adjustment so that
prices match time of delivery pricing. In reviewing FERC rule 292.304 Rates for
Purchases, it appears that the Qualifying facility has the option to accept the avoided
cost rate or a time of delivery rate. "(d) ...Each qualifying facility shall have the optioneither: .... (2) To provide energy or capacity pursuant to a legally enforceable obl igation
for the delivery of energy or capacity over a specified term, in which case the rates . for
such purchases shall, at the option of the qualifying facility exercised prior to the
beginning of the specified term, be based on either: (i) The avoided costs calculated atthe time of deli very; or (ii) The avoided costs calculated at the time the obligation isincurred"I believe that the Idaho PUC needs to clarify their ruling in this case so
that Idaho is compliant with FERC.
The form submited on http://www.puc.idaho.gov/forms/ipucl/ipuc.html
IP address is 68.105.221.
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