20150603Comment.pdf

4Ian RIcharéson
r—•
121 Patéu6on Place -
‘‘‘
‘1-IaIley,JV 83333 C.:O
Li II
May 22,2015
Idaho Public Utilities Commission
P.O.Box $3720
Boise,Idaho 83 720-3 762
Re:IPC-E-15-01
Dear Commissioners:
I appreciate the opportunity to comment on Idaho Power’s filing with the PUC in the
above referenced docket.Idaho Power has proposed to shorten the length of PURPA
contracts from the current 20-year period to 2 years.This proposal is inconsistent with
the intent of Congress in enacting PURPA in 197$.If adopted,it will seriously and
adversely undermines the ability of independent renewable energy companies to develop
new renewable energy facilities here in Idaho.And it will slow the introduction of
homegrown,environmentally friendly sources of electricity in Idaho.
President Jimmy Carter’s National Energy Plan was submitted to Congress in April 1977.
A White House fact sheet issued on April 27,1977 discussed the purpose,goals and
objectives of the plan (http://www.presidency.ucsb.edulws/?pid=73 73).Among other
things the Plan was designed to:“develop the new,unconventional sources of energy we
will rely on in the next century;”develop “renewable and essentially inexhaustible
sources of energy for sustained economic growth;”“be fair;”“protect the environment;”
and provide prices to consumers that “reflect the true replacement cost of energy.”
These principles are all reflected in what became the Public Utility Regulatory Policies
Act of 1978,one of five parts ofPresident Carter’s National Energy Plan.It is that Act
that requires electric utilities to purchase power from specific energy generating facilities,
which are for the most part co-generation and renewable energy facilities,including solar
photovoltaic facilities.
In at least one respect PURPA was revolutionary.It breached the monopoly position
held by electric utilities that allowed them to control not only transmission and
distribution but also generation.Electric utilities opposed the requirements imposed on
them by PURPA,and many continue to oppose PURPA’s goals and objectives today.
Their efforts include proposals to eliminate renewable portfolio standards in the states
where they exist,construct obstacles to make sales from qualifying facilities more
difficult,and undermine the efficacy of PURPA’s requirements through seemingly subtle
changes such as reduction in the required length of PURPA contracts.
Idaho Power undoubtedly recognizes the fact that two year PURPA contracts are a nearly
insurmountable obstacle to the non-utility development ofrenewable energy facilities.It
is simply impossible to finance these capital-intensive projects in the absence of long-
term commitments.Approving Idaho Power’s request seriously undermines if not
completely frustrates the ability of independent clean energy companies to provide
reliable,fair-priced,environmentally friendly energy.
The benefits to Idaho of promoting the development and utilization of renewable energy
facilities are many.These businesses are investing millions of dollars in Idaho.The
energy they produce (or,more accurately,the solar energy they capture)is locally grown.
They are creating jobs and growing our tax base.They are,to paraphrase the words of
the 1977 White House fact sheet,developing the sources of energy we must rely on in the
21 Century.And they are doing so under a program that is fair,is based on prices that
reflect replacement costs (avoided costs),and,perhaps more important than anything
else,protecting the environment.
I urge you to oppose Idaho Power’s proposal.
7
Man Richardson