20150226Comments (2 Total).pdf

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February 26,2015
Idaho Public Utilities Commission
472 West Washington Street
Boise,Idaho 83702
Attn:Honorable Paul Kjellander
Honorable Marsha Smith
Honorable Mack Redford
Re:IDAHO POWER PETITION TO MODIFY TERMS AND CONDITIONS Of PROSPECTIVE
PURPA ESA,WC-E-15-O1
Dear Commissioners:
I would like to provide comments on behalf of Energy of Utah LLC.We are a renewable energy
developer,which primarily focuses on renewable energy consulting and development in the
Intermountain West region.
Our energy team has proudly contributed to successful construction of muJtiple renewable energy
facilities in several geographic areas of United States.Our experience spans back as early as 2006.The
total generatioti exceeded 757.2 MW with capital expenditure at 2.2 billion in completed projects alone.
Lastly,we are also actively developing Utility Solar PV project in Idaho and the outcome of this
proceeding will have a direct effect on success of our project.
In our position,we do not support Idaho Power’s request to shorten PURPA contracts from 20 years to 2
years based on submitted evidence and reasoning for such request.We also appreciate Idaho Public
Utilities Commission’s temporary solution to limit PURPA contracts to 5 years,pending docket
proceeding but unfortunately this short duration does not offer viable solution to support continuing
project development in State of Idaho either.
We would like to present the following comments:
•PURPA summary of its purpose
•Essentials of tong term planning
•Benefits of renewable generation
PURPA summary of its purpose:
Public Utility Regulatory Policy Act was adopted in 197$,in midst of the energy crises that directly
impacted US economy.The Congress acted to reduce our dependency on foreign oil and to promote
alternative energy sources and energy efficiency and to diversi1v the electric power industr .One of the
most powerful effects of this law was the creation of a market for renewable power from non-utilities.
PURPA remains to be the only federal instrument supporting competition in energy and development of
renewable resources.These two pillars must be protected in its intended format resting on generation
price fairness and assurance of a fair market place existence under-written by long term contractual
structure of Power Purchase Agreement (PPA).
Essentials of long term planning:
Through long term planning and long term contractual obligations a Utility protects their energy rate
payers from volatile energy spikes and minimize mostly expensive “front office transaction”.for this
very reason Utilities are likely to enter into long term PPA with a private developer ensuring long term
price protection passed down to Idaho rate payers.
The Public Service Commission has an approval authority over Utilities developed Integrated Resource
Plan (TRP).The IRP is a long term plan of future generation and its pertinent infrastructure to assure safe
and reliable generation delivery to Idaho rate payers.Price protection via long term planning is a vital
component of an IRP and the main driver in sound energy purchases.Without the IRP,Utility could enter
into any contractual offer or to self-construct a new facility at any costs and Idaho rate payer would bear
the costs of this resource plus a profit margin.
Long term PURPA contracts similar to IRP also offers this very benefit of protection to Idaho rate payers
in addition to protecting private investment in fair and just manner.Utility and private enterprise shall not
be treated differently and the benefit of long term planning shall be offered to all entities.Energy business
fairness,renewable energy development support and decreased dependency on foreign fossil fuel supply
were the very essence for PURPA creation.Short-term contracts (under 20 years)are instifficient to
attract much needed capital investments for development,permitting,equipment purchases or a
construction financing.Renewable energy projects are capital intensive and any uncertainties in regards to
generation pricing will results in lack of finding resulting in development stall in State of Idaho.Only by
long term “energy price certainty”private developers are ensured even level playing field with a Utility in
development of renewable energy projects.It is very likely that Idaho power would not enter into
construction of new generation plant given 2 year price certainty with no “guarantee”to secure fair return
on their investment as requested in this electric docket from others.
Benefits of Renewable generation:
Renewable energy is important because of the benefits it provides:
V Environmental benefits-more often than not this benefit is not fully realized while utilities only
count energy component and portion of renewable generation capacity in their price modeling.
There is typically no value given to lowering environmental impact of fossil fuel based resources.
The Environmental Protection Agency (EPA)and its carbon pollution standard are rapidly
changing the way the renewable generation benefits will be viewed in the near future.
V Energy longevity-renewable energy is an infinite resource and the only limitation on renewable
generation is its equipment life span.All other energy sources are finite.
V Economic benefits-renewable energy investments are spent on material and labor to construct
these facilities over costly energy imports.Renewable project often requires local content in form
of labor,supply chain,temporary and permanent job positions.This means that dollars are spent
in USA or State of Idaho providing much needed long term tax base income to local schools and
rural communities.
V Energy security-renewable energy generation allows for energy independents form foreign oil
and gas contributing to local economy.
V Price hedging-Renewable energy is the only generation resource that allows for long term price
“guarantee”,thus offering costs hedge against future price spikes that fossil fuel generation
cannot mitigate.Expected future carbon tax will also add additional costs to fossil fuel supply and
thus incremental cost to Idaho rate payers.
Conclusion;
We would like to thank to Idaho Commission for this opportunity to present our comments for review and
consideration during PURPA docket brought fonvard by Idaho Power.In our view,renewable energy
PPA’s under 20 years in duration will not only deprive Idaho residents from future investment capital
providing various economic benefits to Idaho.but it also creates and unjust and discriminatory
environment that will hinder renewable development and expose Idaho residents to future fossil fuel
costs volatility.
Respectfully /
/7
Ros Rocco Vrba,MBA-President
Energy of Utah LLC
Phone:$01 70$2086
P.O.Box 900083.Sandy,UT 84090-0083
www.energyofutah.com
“Power for People”
07.45.49 am 02—26—2015 2 POCArELLOSCHOOLS
To:‘2083343762 From:Renae Johnson 2-26-15 8:28am p.2 of 3
Pocateio
________
School District 25 Whatever li Takes!
February 18,2015
Idaho Public Utilities Commission
P.O.Box 83720
472 W.Washington
Boise,ID 83720
Dear Commissioners:
As a public entity,employer and Idaho Power customer,the Pocatello/Chubbuck School District
No.25 supports Idaho Power’s request to shorten the length of guaranteed contract for large
solar and wind generation projects.The District believes Idaho Power’s request is in the best
interest of the District and all other Idaho Power customers.
The District operates more than 26 facilities in the Pocatello and Chubbuck communities and
plays a major role in the local economy.Having access to reliable electricity at a fair price is
essential to the District’s operations.It is also essential to the financial health of our employees
and families attending the School District,many of whom are on limited or fixed incomes.
The District and families in this community love and respect the clean environment that is
essential to our way of life in Southeast Idaho.Our community members want clean energy and
are glad to know that a majority of our electricity comes from the region’s clean,renewable
hydro resources.However,moving toward a clean energy future cannot come at the expense of
reliability and affordability.The District believes that Idaho Power recognizes and understands
this and works hard to strike a good balance.
The District does not believe that Idaho Power should be required to purchase electricity that it
does not need,especially from sources that decrease reliability while increasing costs which are
passed onto customers.If Idaho Power is required to make such purchases,than the District
agrees that such contracts should be limited to two years or less,rather than locking in prices for
20 years.
The Pocatello/Chubbuck School District No.25 supports Idaho Power’s environmentally
responsible and balanced service and its tradition of providing quality,reliable service at a low
cost.This is critical to the operations of the School District and is in the best interest of Idahoans.
C/i ubbuck
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07.45,49 am.02—26—2015 3 POCArELLOSCHOOLS
To:‘2083343762 From:Renae Johnson 2-26-15 8:28am p.3 of 3
The District requests that the Idaho Public Utilities Con’nriission grant Idaho Power’s petition to
modify the terms and conditions of future PURPA energy sales agreements (IPC-E-15-O1).
Respectfully.
Mary tv’Vagner
Superintendent
c.Board of Trustees
Ban Reed
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