20150622Comments (4 Total).pdf

Bernard J.Zahren,CEO
ZAHREN FINANCIAL CO.,LLC ----
MANAGER of CLEAN FEET INVESTORS I,LLC
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Ui LrES COMiSU
June 17,2015
Idaho Public Utilities Commission
P.0.Box 83720
Boise,Idaho 83720-3762
RE:IPC-E-15-01
Dear Commissioners:
Thank you for the opportunity to comment on Idaho Power’s filing with the PUC in the above
referenced docket.As managers of a financial services company that invests in clean
energy projects throughout the United States,we are concerned about the decision before
you.While we currently have no investments in Idaho,a decision to shorten the length of
PURPA contracts from the current 20-year period to 2 years would dramatically impact our
ability,or that of any other investor,to invest in Idaho.With investors putting over $40
Billion to work in clean energy every year can Idaho afford to jeopardize any investment
opportunity?
Development of any new energy project has high upfront capital costs.Long-term contracts,
therefore,are essential to financing.This is especially true for clean energy projects,which
have low to negligible fuel costs,and are therefore almost fully financed upiront.When
evaluating the length of contract necessary to finance a project we consider the price,the
risk of performance,and the useful life of the project.With Idaho’s low avoided costs,
contract terms of at least 20 years are essential to even consider making an investment.
Contract lengths of two years,or even a compromise length of five or ten years,would make
it impossible for any project in Idaho to meet our thresholds as a viable investment.
On the other hand,long-term fixed price electricity contracts provide stable,predictable
energy costs for utilities and customers.With Idaho’s low avoided costs the utility should be
locking in these favorable opportunities to mitigate the risk of volatility in natural gas costs
and wholesale electricity.This provides benefits to the citizens of Idaho,not only from an
environmental,but also from an economic standpoint.You cannot decrease your
dependence on dirty,volatile energy sources without the proper mechanisms to build and
finance new,clean,local sources of energy.
For these reasons,we believe it is in Idaho’s best interest for you to reject Idaho Power’s
proposal.
Sincerely,
Bernard J.Zahren
CEO,Zahren Financial Co.
Manager,Clean Feet Investors I,LLC Co-Founder/President,Generate Capital
Bernard Zahren is Manager of Clean Feet Investors I,LLC and Chair of the Avon,CT Clean Energy
Commission.Jigar Shah,his partner at Clean Feet,was Founder and CEO of SunEdison (the largest solar
services company in the world)and Founding CEO of The Carbon War Room.
40 Tower Lane Avon,CT 06001
Find us on the web @ www.cleanfeetinvestors.com
Founder,CEO SunEdison
C5.COLLEGE OFISOUTHERN
IIDAHO
—
June 22,2015
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Idaho Public Utilities Commission —
P.O.Box 83720
472 West Washington
Boise,1D83720
Dear Commissioners,
As one of the Magic Valley’s largest employers and occupying one of the largest facilities,
the College of Southern Idaho supports Idaho Power’s request to review the guaranteed
contract length for PURPA requirements that regulated utilities purchase energy from
qualified renewable generation projects at a fixed rate for 20 years.
CSI serves roughly 8,000 students in the eight-county service region of the Magic Valley.
College facilities include the 330 acre main campus in Twin Falls,off campus sites in the
city,physical sites in outreach centers in Jerome,Hailey,Gooding,Burley,and Idaho Falls.
Utility costs tend to loom large for us,and as rates rise,we strive to keep education
affordable and accessible.If we can assist in keeping electrical rates down,it assists in
keeping costs down for students.
CSI favors clean and renewable energy,and the college also supports a balanced regulatory
approach,one that reflects a contemporary 2015 base.The current Public Utility
regulatory Act of 1978 is over 30 years old,and it is time to review the model.
Thank you,
Dr.Jeff Fox
President
315 FaIls Avenue •P0 Box 1238 •Twin Falls Idaho 83303-1238 •208.733.9554 •www.csi.edu
RITE STUFF FOODS
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June 22,2015
Idaho Public Utilities Commission
P.O.Box 83720
Boise,ID 83720-0074
Re:Idaho Power’s request to limit solar and wind contract lengths
Dear Commissioners,
Rite Stuff Foods supports Idaho Power’s request to shorten the length of guaranteed contracts for large
solar and wind generation projects.
The cost of electric power is an important component in the cost of products we produce in Idaho.
Keeping power costs low is of great importance in keeping our Idaho business competitive in the world
market.
We don’t believe Idaho Power should be requited to buy electricity it does not need.We support
limiting the length of large solar and wind contracts to two years.
Thank you for your consideration.
Sincerely,
Jim Madden
General Manager
Rite Stuff Foods
27555.LINCOLN,JEROME,ID 83338 •PHONE [phone] •FAX [phone]
www.ritestuff corn
Dr.Craig W.Nickisch
4161 Bannock Highway
Pocatello,ID 83204-4525 ?JJ 22 9t 3L
I lB June 2015
Idaho Public Utilities Commission
P.0.Box 83720
Boise,Idaho 83720-0074
Dear Commissioners:
I am moved to write in support of Idaho Power Company’s requests to the Commission
in the current matter of PURPA contract conditions.In a word,it is my contention that
your substantive approval of Idaho Power’s request will be in the best interest of Idaho’s
consumers,both residential and commercial.
In the matter of PURPA itself,I was once told by a very wise mentor that “like doctrine,
regulations are promulgated with commitment,even fervor —but they must be
administered with judgement.”furthermore,he reminded us that,over time,commercial
and cultural changes cause each regulatory requirement to become less directly applicable
to the questions it was intended to address.That may well apply in this matter,and I am
most appreciative of the Commission’s judgement in finding an optimal contextual
resolution of the matter at table.
I will refrain from addressing the specific aspects of Idaho Power Company’s request,for
you will certainly hear much about each of them in the upcoming hearings.
In sum,however,the proposals made by Idaho Power,and taken in context,stand the
test of reason.They will allow a very reputable and conscientious organization to continue
providing Idaho citizens and businesses with an essential resource at prices which support
economic growth and our fine quality of life.
I sincerely appreciate your consideration.
With best regards,
Craig W.Nickisch,PhD
Colonel,USA,Retired
Professor Emeritus,Idaho State University