20111216Comment and Request for Hearing.pdf

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John L. Runft I Jon M. Steele
201l DEC 15 PM 4: 42
December 15, 2011
Mr. Gene Fadness
Executive Assistat
Idaho Public Utilties Commssion
472 W. Washigton
Boise, ID 83702
Mr. Rick Sterling
Sta Engineer
Idaho Public Utilities Commssion
472 W. Washington
Boise, ID 83702
VI HAD DELIVERY
Re: Case No. IPC-E-11-25
IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY
FOR A DETERMINATION REGARIDNG THE FIRM ENERGY SALES
AGREEMENT FOR THE SALE AND PURCHASE OF ELECTRIC ENERGY
BETWEEN IDAHO POWER COMPANY AND DYNAMIS ENERGY, LLC
Dear Mr. Fadness and Mr. Sterling:
I represent Mr. Hubert Osborne, an Idao Power customer and resident of Canyon
County. Mr. Osborne and a number of other Idaho Power customers have concerns about the
above-referenced application.
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Although PURP A was intended to encourge the development of renewable energy
technologies as alternatives to the use of fossil fuels, ths application is premised upon unproven
technology, governent payments, and ta credits. The unque charcteristics of ths application
differentiate it from PURP A qualifying facilties.
The modified procedure requested by Idao Power does not serve the public interest. Not
only is the proposed technology unproven but the framework of the entire business model is
premised upon contrcts with other public entities which do not have the abilty to question the
representations of Dynamis Energy, LLC.
runftsteele.com
Phone: [phone] Fax: [phone] I Boise, Idaho 83702
In the Alaska Center I 1020 W. Main Street, Suite 400 I Fourth Floor
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The application states the contract price will be a negotiated price between the utilty and
developer. Without knowing the rate the Commssion ha no basis for determinng it to be
reasonable. Additionally, ths application is intended to formulate a model to be repeated in
other Idaho counties.
The public deserves to be heard on the energy policy issues presented by ths application
as the issues involved in ths application will afect the fu of alternative energy resources in
our state. The Commssion should requir complete trsparncy and disclosur of all confcts
of interest.
Please place the following individuals on the Interestd Pares list:
1. Jon M. Stele
2. Hubert Osborne
j steele(iruftsteele.com
Wclosborne(iaol.com
Idaho Power's request tht ths application be handled by modified procedure mus be
denied and a hearng date scheduled.
Jon M. Steele
Run & Steele Law Offces, PLLC
JMS:kra
Cc: Hubert Osborne