20071024Comments.pdf

M~/Y\ ~'-i10/1):
Jean Jewell
.;/,
11/
To:
Subject:
armand~5afelink.net
RE: PUC Comment/Inquiry Form
-----Original Message-----
A Comment from ARMAND M. ECKERT follows:
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Case Number: IPC-E-07-15
Name: ARMAND M. ECKERTAddress: 716-B EAST 4900 NORTH
Cit y: BUHL
State: IDAHO
Zip: 83316
Home Telephone: [phone]
Contact E-Mail: armand~safelink.net
Name of Utility Company: IDAHO POWER
Add to Mailing List: .E2
COMPANY
Please describe your question or comment briefly:
The IPUC should use the NWPCC 2007 Forecast methodolgy. I understand the current
breakeven point to run a natural gas-fired combined cycle combustion turbine is $74 to$76/MW. To run a wind turbine and to get investors inclined to invest in wind turbines in
Idaho, the SAR price has to use the NWPCC 2007 forecast methodolgy to determine the new
avoided cost which should be around $72/MW. I believe there will continue to be fuel
shortages, including natural gas, which will drive the price for natural gas even higher
in the future (probably higher than the 2.3% increases used in the current methodology.
On the other side of the coin, prices for wind turbines, towers and blades have by far,
increased much more dramatically than the avoided costs and these price increases for
turbines, etc. will more than likely continue to outpace price increases in natural gas on
a percentage basis as long as tight supplies remain in effect. I believe the proposal by
Idaho Power to use the average price in natural gas price increases will only further
deter the development of small Purpa wind farms. Sincerely Armand Eckert
The form submited on http://www.puc.idaho.gov/forms/ipuci/ipuc.htmi
IP address is 216.57.167.199
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b- 'd-cj(v1
Jean Jewell
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From:
Sent:
To:
Subject:
ktinsV~cox. net
Tuesday, October 23, 2007 9:09 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: IPC-E-07-15
Name: Kiki Leslie A. Tidwell
Address: P.O. Box 2919
City: Ketchum
State: ID
Zip: 83340
Home Telephone: [phone]Contact E-Mail: ktinsv~cox. net
Name of Utility compa~~ Idaho
Add to Mailing L ~st Power
Please describe your question or comment briefly:
Public Comment on IPC-E-07-15 Petition to Modify Fuel Cost Component Methodology for
Published QF Rates
California is going to be relying on natural gas and natural gas-fired power plants for
the foreseeable future. They have adopted emissions standards which restrict the state
not only from building their own coal-fired plants, but also from buying power from coal-
fired plants from other states. This leaves them no choice other than natural gas if they
can not meet their energy generation targets through renewables power production. It
seems reasonable to expect that when there is strong demand for a commodity, the price for
that commodity rises. It does not seem reasonable to expect that natural gas prices will
decline in the foreseeable future. In a draft report the Athena Group reports, "Natural
gas prices today have doubled from their 1990 levels, driven in large part by the increase
in demand.
.. .
The U.S. Energy Information Administration (EIA) has increased its gas priceproj ection for each of the last seven years. ... Because these out-of-state natural gas
suppliers are privately held companies, they can and will sell their product over time toany higher-priced and higher-demand markets that may surface.
For the consumer, a 20 year fixed price wind or geothermal contract at today s prices is
pretty appealing. By making it hard for renewable PURPA projects to get built in Idaho,
the Idaho PUC is leaving the consumer to face unknown power price increases each year.
Could one have predicted two years ago when oil was at $40 a barrel that it would be at
$90 today?
Idaho Power s most recent petition to modify the avoided cost rate methodology for PURPA
projects is just one more way that the company is trying to kill the viability of PURPAproj ects by reducing the economic viability of the proj ects. Jim Miller of Idaho Power
says in his August 24th Twin Falls Times News opinion that Idaho Power has been trying to
integrate Idaho wind power into its system in the mutual best interest for all. Let's see
what they have actually done. In 2004, they insisted on 90/110 clauses in their PURPAcontracts with small wind farmers. With a 90/110 clause, Idaho Power required that these
small wind farmers predict many, many months in advance exactly how much power they were
going to produce during a certain month. If they did not meet 90% of their prediction, or
went over 110%, they were going to be paid 85% of the mid-c market price, which could
easily be less than half of the established PURPA rate. Idaho Power can not predict how
much snow will fall each year for their hydro dams, but they demanded crystal ballcertainty from small farmers. This 90/110 clause created unreasonable uncertainty inalready variable proj ect revenues for most investors and those proj ects did not get built,
while turbine costs have soared since then.
A couple of small wind farmers kept trying to forge ahead with their farms, even despite
the probability of half of the income they had expected - I guess farmers by nature might
be more optimistic than investors. So, in June, 2005 Idaho Power asked the Idaho Public
Utili ties Commission to suspend the requirement to purchase wind power from new PURPAproj ects altogether. The PUC squeezed the maximum allowable size of a proj ect down from
10 megawatts to 100 kilowatts. This essentially created a moratorium on PURPA projects asno proj ects today can financially work at 100 kw or less based on available technology.
As for the small farms that were already along in the process that were still allowed to
proceed at 10 megawatts, Idaho Power demanded they pay $60 million in transmissionupgrades to connect their proj ects.
Idaho Power had told the PUC it needed the PUC moratorium so it could study how it could
integrate these small wind projects into its system. After more than a year, they came upwi th an integration study that said it would cost them money to add these proj ects, and
that they wanted to discount the price of PURPA power purchases by 17.16%, even though the
rest of the U. S., integration costs have been established in the 3-6% range. The
integration study did not use any of the extensive years of data collected by the INL
through wind anemometers and used embarrassingly skewed modeling assumptions.
In August 2006, Idaho Power turned its attention to its smallest renewable energy
producers, those of us that have solar panels on our roofs and tiny hydro projects-27 net
meterers, who if we produce more power a month than we use, would get a credit on our
bills at the same rate we pay for power. Only 3 of these 27 net meterers produce morepower than they use each month. Idaho filed an application to the PUC to again pay only
the 85% of mid-c for any excess power, but withdrew its request after a flurry of public
comment to the PUC.
Finally, when Idaho Power did award a power purchase 100 mw contract to a wind farm, itwent to a proj ect in Oregon, not Idaho. Idaho has some of the best natural wind resource
in the nation, yet it has become the hole in the donut in terms of developed windprojects. While Oregon, Washington, Wyoming and Montana have each 300-600 mws of wind
power, Idaho has only 75 mw installed. Idaho had zero projects built in 2006 and 2007
while Texas is installing approximately 2,000 mw in 2007. Idaho Power could do a lot
more than just claim that it is misunderstood when it comes to integrating renewable
energy.
The Idaho PUC could support PURPA proj ects by keeping the avoided cost methodology inplace. PURPA proj ects in turn contribute to a stabilized rate base for consumers.
Sincerely,
Kiki Tidwell
The form submited on http://www.puc.idaho.gov/forms/ipuci/ipuc.htmi
IP address is 68.105.216.186
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~V1IV1
Jean Jewell
I~ t.-~.
From:
Sent:
To:
Subject:
km iller~snakeriveralliance. org
Tuesday, October 23, 2007 11 :00 AM
Tonya Clark; Jean Jewell; Gene Fadness; Ed Howell
PUC Comment/Inquiry Form
A Comment from Ken Miller follows:
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Case Number: IPC-E-07-15
Name: Ken MillerAddress: Box 1731
City: Boise
State: ID
Zip: 83701
Home Telephone:Contact E-Mail: kmiller~snakeri veralliance. org
Name of Utility Company:
Add to Mailing List: no
Please describe your question or comment briefly:
Comments of the Snake River Alliance
on PURPA Published Rate Modification Proposal
Submitted by
Ken Miler, Clean Energy Program Director, Snake River Alliance
October 23, 2007
The Snake River Alliance appreciates the opportunity to provide comments relating to IPC-
E-07-05, relative to the calculation of the Public Utility Regulatory Policies Act (PURPA)
published rate or small-power producers in Idaho. The Snake River Alliance submits these
comments on behalf of its members, many of whom are customers of Idaho Power Co. and most
of whom are customers of Idaho s investor-owned utili ties.
The Alliance believes Idaho Power s proposed change in the calculation of the PURPA
published rate does not accurately represent the true avoided costs of energy and
capacity. Given that the avoided cost rate is in large part the basis for setting pricesfor renewable energy proj ects in Idaho, Idaho Power s proposed change to the calculation
could have serious negative consequences for the future development of wind and other
renewable energy proj ects in Idaho. Idaho Power s proposed changes could result in a
reduction of the published rate from more than $72 under the current formula to just under
$68 if the company s proposal is adopted. If the company s proposal is not adopted, the
average rate would rise to the mid-$70 range and would create an environment that would
further encourage development of small-scale renewable energy proj ects in Idaho.
It's also our belief that use of a combined cycle natural gas plant continues to be anappropriate surrogate avoided resource (SAR) for purposes of setting the published rate.
Gas prices are reflective of energy market prices, and published rates for the benefit of
PURPA proj ects should reflect the expected power costs from a combined cycle gas plant. As
mentioned above, $67-68 does not reflect those expected costs. Furthermore, that serious
negative impact on Idaho s PURPA contracts may well be exacerbated by the possible outcome
in the pending wind integration docket, IPC-E-07-03.
We believe the Idaho Public Utilities Commission and the state of Idaho should consider
all options in encouraging development of renewable energy resources in Idaho, and in
particular those resources that are Qualifying Facilities under PURPA.
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
Box. 1731
Boise, ID 83701
[phone]
kmiller~snakeri veralliance. org
The form submited on http://www.puc.idaho.gov/forms/ipuci/ipuc.htmi
IP address is 67.42.190.
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I t1, A'-- A-J".~
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Jean Jewell
,/-;; ::-
From:
Sent:
To:
Subject:
blueribbonenergy~g mail. com
Tuesday, October 23, 2007 2:50 PM
Tonya Clark; Jean Jewell; Gene Fadness; Ed Howell
PUC Comment/Inquiry Form
A Comment from MJ HUMPHRIES follows:
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Case Number: IPC-E-07-15
Name: MJ HUMPHRIESAddress: 2630 CENTRAL AVE.
City: AMMON
State: ID
Zip: 83406
Home Telephone: [phone]
Contact E-Mail: blueribbonenergy~gmail. com
Name of Utility Company: idaho power company
Add to Mailing List: no
Please describe your question or comment briefly:
Here we are in the 11th hour. IPCO is trying to prevent wind farms from being built, they
talk one way but do another. keep in mind that ALL financial institutions that finance
wind follow the news in the IPUC websi te closely. Some will not do business in Idaho
because we cant seem to get our house in order. A good example of that is case# IPC-E-07-15. Meaning we established a cost based on methodology now IPCO is trying to change the
formula! This action is wrong. The expense of building a wind farm has risen approximately
60% over the last 3 years, and in that time IPCO has been preventing financialinsti tutions from funding proj ects because they keep changing the ground rules. The NWPCC
2007 forecast MUST stay the same in order to build. I would love to build my turbines in a
20 year forecasted average, but it is not practical. This issue needs to go in front of the
commissioners so that ALL the evidence can presented, if natural gas fired combustion
turbines could be built for less than the proposed new avoided cost, every utility company
in the country would build them and they are not doing so because the cost is to great.
The formula ipco has used does not calculate, the 3 year average used in case# IPC-E-07-
is the realistic cost. I dont believe ipco I s crystal ball for the 20 year future is even
close to being accurate. Every forecaster i speak to says the cost will only continue to
rise and not decline. BRE MJ Humphries
The form submited on http://www.puc.idaho.gov/forms/ipuci/ipuc.htmi
IP address is 69.92.60.243
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