20090109IRC Comments.pdf

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Wednesday, January 07, 2009 9:39 AM
Jean Jewell; Beverly Barker; Gene Fadness; Ed Howell
PUC Comment Form
A Comment from Idaho Rural Council follows:
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Case Number: IPC-E-e8-24
Name: Idaho Rural Council
Address: P.O. Box 21
City: FIler
State: Idaho
Zip: 83328
Daytime Telephone: 2e8-326-3686
Contact E-Mail: carlsonr~filertel.com
Name of Utility Company: Idaho Power
Add to Mailing List: yes
Please describe your comment briefly:
The Idaho Rural Council is very supportive of Idaho Power's efforts to expand its
renewable power portfolio and has encouraged all of its members to participate in the Green
Power Program. However, before submitting our comments, we had several questions about the
application. The questions below were submitted via e-mail to Lisa Nordstrom and Karl
Bokenkamp on January 7, 2ee9 but have not elicited any response:
1. Is the request to ((retire" Green Tags meant to cover just those IP sponsored project tags
it has already produced or is the company's request meant to cover tags associated with
future power production?
2. The application mentions 32e, eee MWh of Green Tags obtained through generation at the
Elkhorn Valley Wind Project in eastern Oregon in 2ee7 and 2ee8. What is the total number of
Green Tags associated with past production that IP is seeking to retire? What is the
estimated number of Green Tags IP has acquired ( at least potentially) through its U.S.
Geothermal affiliation?
3, IP apparently has questions about its ability to get the Elkhorn Green Tags certified by
Green-e Energy making their value questionable. Why does IP perceive a problem with
certi fication of those tags?
4. What was the total dollar value of Green Power Program contributions IP collected and
passed through to the Bonneville Environmental Foundation (BEF) in 2ee7? What is the estimate
of the pass through for 2ee8?
5. Voluntary contributions by Green Power Program participants that support IP's production
of renewable power - even outside IP's service area- doesn't seem to us to be the same
situation as the scenario from the 'Best Practices in Public Claims Related to Green Power
Purchase and Sales i cited in the application. Could contributions from IP's Green Power
Program participants be directed to the acquisition or lease of the Elkhorn Green Tags (
instead of funneled through 1 BEF) without conflicting with the Green-e Energy standards?
IRC requests that IPUC staff get answers to the above questions as part of its review and
analysis.
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IRC would also suggest that Idaho Power investigate the possibility of transferring Green
Tags to a escrow or trust to be held for the benefit of its Green Power Program participants
making voluntary contributions to the trust. This kind of arrangement might provide the
company with a source of funds with which to invest in more renewable power generation AND
achieve the same goals that retiring the Green Tags would.
Richard Carlson
Attorney for Idaho Rural Council
The form submitted on http://www . puc. idaho.gov/forms/ipuc1/ipuc. html
IP address is 2e8. 98 .172.26
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