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Home My WebLink About20150626Comments (5 Total).pdfJame5 Mulhern,President &Chief Executive Officer I Randy Mooney,Chairman PAGE @2 Agri-Merk,Inc. Associated Milk Producers Inc. Bonqards’Creameries Cooperative Milk Producers Association Cortland Bulk Fvlilk Praducers Cooperative Dairy Pa mets of Ameflca,Inc. Dairymen’s Markeling CooperaWe,Inc. EI’swodh Cooperative Creamery Farmers Cooperah Creamery Famrn9rstDairy Cooperative First District Association Foremost Farms USA Land O’Lakes.Inc. Lone Star Milk Producers Maryland &Virginia Milk Producers Cooperative Association Michigan MilkProducersAssociallon Mid-West Derymen’s Company MountJoy Farmers Cooperative Association Northwest Dairy Association QneldaMadison MPk Produce’s CooperaNe Association Prairie Farms Dairy,Inc. Premier Milk Inc. Scicto County Cooperative Milk Producers Association SelectMilk Producers,Inc. Southeast Mik,Inc. Sc Albans Cooperative Creamery,mc, Swiss Vaney Farms Company Tillamooli CountyCreameryAssocIation United Dairymen of Arizona Upstate Niagara Cooperative.Inc. Zia Milk Producers.Inc. June 26,2015 Commissioners Kjellander,Raper.and Redford Idaho Public Utilities Commission 472 V.Washington St. Boise,Idaho 83702 Re;Dockets AVU-E-1 5-01,IPC-E-15-01,PAC-E-15-01 Dear Commissioners: WA FAX The National Milk Producers Federation (NMPF),based in Arlington,VA,develops andcarriesoutpoliciesthatadvancethewell-being of dairy producers and the cooperativestheyown.The members ofNMPF4s cooperatives produce the majority ofthe US.milksupply,making NMPF the voice of more than 32,000 dairy producers on Capitol Hill andwithgovernmentagencies.Visit www.nmpf.org for more information. NMPF submits these comments in response to the Commission’s proposed rulemakingrelatedtoshorteningthedurationofPURPAcontractsfrom20yearsto5yearsorless.NMPF has grave concerns that the proposed rule will negatively impact the adoption ofanaerobicdigestersandnutrientremovaltechnologiesondairyfarmsinthestateofIdaho --a major dairy state..Digesters and related technology are critically important to the dairyindustryandhelpreducegreenhousegasemissionsandnutrientlosses.We must encouragetheiruse,not discourage them.Digesters are very expensive to install and operate anddespitetheenvironmentalbenefitstheyproduce,they are difficult make workeconomically.Selling electricity to the grid at a fair rate is the primary’means by which adigestercanbefeasible,limiting that ability will be counterproductive.NMPF and theInnovationCenterforU.S.Dairy,as well as our member cooperatives,have been sl:rivingtoencouragetheadoptionofdigestertechnolo’For a variety of reasons which include,among other things.helping to meet our industry’s goal of a 25%reduction of greenhousegas(GUG)emissions by 2020)This rule,as proposed.is a disincentive.Ifthe Public UtilityCommissionchoosestolimitpowerpurchaseagreements(PPA’s)to five years or less,thatdisincentivewillalmostcertainlyendtheadoptionofdigestertechnologyinIdaho.We donotbelievethatisinthebestinterestsofthestateofIdaho,its citizens and the dairy industryinIdaho. While we note that the Commission has imposed an interim live-year limit as noted in theMay8,2015 notice of public meetings For solar and wind projects largerthan 100-kilowattsandforallotherrenewableprojectslargerthan10megawattswhileitconsiderstwoutilitycompanyrequeststocapPPA‘5 at 2 or 3 years.We also note that in your February 6,2015 09:53:23 am.0o—25—20r5 2 7033419323 INN 86/26/2815 11:48 7838419328 NMPF 215JU213 P1 (:1,6 3L1T!c l htlt;//www, 09:53:238.m.00—20—2015 3 J 7038419328 @6/26/2015 11:40 7038419328 NMPF PAGE 03 order that all contracts are limited to 5 years.The apparent inconsistency is concerning.Inmostcasesdairydigestersaredesignedtogenerate1MW,with a few that could potentiallygoto2or3MW-Ifthe May 8th notice is correct it would appear that dairy digesters wouldbeunarfected.If however,the February 6h Order is correct and daiiy digesters PPA’s arccappedat5years.or less when a final determination is made,you are in essence banningdairydigestersinyourstate. A decision to build and utilize digester technolo’is risky in many cases and addinguncertaintyintheformofshortdurationPPAwherethereisalreadyriskwillspelldisaster.Tnstead of the approach taken in the proposal,NMPF urges the Commission to retain a 20-year PPA term for anaerobic digesters due to the well-established recognition of the factthattheydeliverenormousenvironmentalbenefitsandthefactthata5-year or less PPAwillterminateanyandallconsiderationoftheiradoption. NMPF appreciates the opportunity that the Commission has provided for consideration ofourcomments.We are pleased to answer any questions you may have or to provide anyadditionalinformationwhichyoumayrequire. Sincerely, Clay Detlefsen Senior ‘iee President.Regulatory and Environmental Affairs &Staff CounselNationalMilkProducersFederation 2 June 24,2015 Ji 2b f 1:29 Idaho Public Utilities Commission — 472 W.Washington Street Li I IL1fi;uMfSiQN Boise,Idaho 83720-0074 Re:AVU-E-15-01 I PC-E-15-01 PAC-E-15-03 Dear Commissioners: The League of Women Voters of Idaho (LWVID)requests that you deny the petitions to reduce the power purchase contract length with qualifying facilities under the Public Utility Regulatory Policies Act (PURPA).We believe reducing the maximum contract length to two years would effectively eliminate future large scale solar projects from being built in Idaho. The LWVID is a statewide,non-partisan organization that studies issues and comes to consensus before adopting any position.The state League and the national Leagues have adopted positions that support policy,legislation,regulation and funding to attain clean air standards,reduce greenhouse gas emissions and to increase energy efficiency and reliance on renewable energy resources. Regulated utilities should act,and be regulated,in the public interest.In the League’s studied opinion, it is in the public interest to transition away from polluting,carbon-emitting sources of energy to renewable energy resources.Utilities must change their fuel mix and business models to less harmful and ultimately more cost-efficient generation sources.Please require the largest utilities in our state to give qualifying facilities the chance to produce clean energy and related jobs. Judy Edwards,President League of Women Voters of Ida ho P.O.Box 153 Coeur d’Alene,Idaho 83816 Jean Jewell From:jennifer@dgardiner.com Sent:Friday,June 26,2015 12:41 PM To:Beverly Barker;Jean Jewell;Gene Fadness Cc:jennifer@dgardiner.com Subject:Case Comment Form:Jennifer Kefer Name:Jennifer Kefer Case Number:AVU-E-15-0l,IPC-E-15-01,PAC-E-15-01 Email:jennifer@dgardiner.corn Telephone:202 365 2194 Address:2609 11th Street North Arlington VA,22201 Name of Utility Company:Alliance for Industrial Efficiency Acknowledge public record:True Comment:June 26,2015 Commissioners Paul Kjellander,Mack A.Redford,and Kristine Raper Idaho Public Utilities Commission 472 W.Washington Boise,ID 83702 Re:Dockets AVU-E-15-01,IPC-E-15-01,PAC-E-15-01 In the Matter of Idaho Power Company’s Petition to Modify Terms and Conditions of PURPA Purchase Agreements Dear Commissioners Kjellander,Redford and Raper: I am writing on behalf of the Alliance for Industrial Efficiency to express out concerns about Idaho Power Company’s recent petition to shorten the required power purchase agreement contract term from 20 to two years.The Alliance is a diverse coalition of labor,contractor, business and environmental groups committed to increasing deployment of combined heat and power (CHP)and waste heat to power (WHP)technologies.Our membership includes businesses throughout the country,including 39 member companies in Idaho.We urge you to maintain standard policies for 20-year contract lengths of power purchase agreements under PURPA. If the Commission reduces the length of purchase contracts,this decision would significantly set back the deployment of clean and efficient CHP and WHP facilities.Enacted in 1978,PURPA has helped installed CHP capacity grow by 550 percent (from about 12,000 MW in 1980 to more than 66,000 MW in 2000)enabling businesses to reduce energy consumption,save money,create jobs,and increase grid reliability.(1)This policy has been successful because long-term revenue streams have enabled financing for these large projects,which has no doubt helped at least 12 cogeneration facilities in the state of Idaho.(2)Now is not the time to reverse a successful energy policy. Decreasing the term of PURPA contracts would significantly chill construction of future CHP and WHP projects.A typical CHP system requires a substantial up-front investment and remains in place for decades;EPA estimates a typical 10.6 MW gas turbine represents a $20-million investment and the median age of these systems (which represent 64 percent of CHP capacity) is 20 years.(3),(4)Financing should similarly reflect the useful life of a CHP facility, rather than be limited to the proposed two-year power purchase agreement term.Long-term financing is a crucial component of developing projects with significant up front costs such as CHP and WHP facilities.(5)Limiting required power purchase agreements for CHP and WHP 1 facilities would therefore diminish CHP developments this would weaken manufacturing competitiveness,increase Idaho’s risk to variable fuel costs,and increase emissions of harmful air pollutants.Accordingly,we urge the Commission to restore the requirement for 20-year power purchase agreements for qualifying facilities. By producing both heat and electricity from a single fuel source,CHP systems can be twice as efficient as the separate generation of heat and electricity,while WHP captures waste heat to generate electricity with no incremental emissions.CHP systems enhance the reliability of critical facilities such as hospitals and universities,make manufacturing facilities more efficient,reduce volatile fuel costs and bolster industry.PURPA allows these facilities to sell surplus power back to the grid at prices that protect electricity consumers,providing a revenue stream that has been a key factor firms have considered when adopting these technologies.(6)The combined savings and revenue stream to businesses allows industry to reinvest these funds to increase both jobs and productivity,creating cascading positive effects for Idaho’s economy.Reducing the required term of power purchase agreements to two years would eliminate a guaranteed market for clean and efficient electricity generated by CHP,making firms less likely to invest the large up-front costs that these systems require. We appreciate the Idaho Public Utility Commission’s efforts to make Idaho’s energy sector reliable and efficient.We hope that your decision on this matter will preserve the current standard of requiring 20-year power purchase agreements for qualifying facilities under PURPA so that Idahoans can continue to benefit from these technologies. Sincerely, Jennifer Kefer Executive Director Alliance for Industrial Efficiency Citations: l.DOE-ORNL,2008,ccCombined Heat and Power:Effective Energy Solutions for a Sustainable Future,”Retrieved from:http://info.ornl.gov/sites/publicationslfiles/Pub13655.pdf 2.U.S.Department of Energy.,2015,“Combined Heat and Power Installation Database:Combined Heat and Power Installations in Idaho”Retrieved from: https :1/doe.icfwebservices .com/chpdb/state/ID 3.U.S.Environmental Protection Agency and U.S.Department of Energy,Combined Heat and Power Partnership.2015,“Catalog of CHP Technologies.”Retrieved from: http://www.epa.gov/chp/documents/catalog_chptech_full.pdf 4.U.S.Department of Energy.,2015,“Combined Heat and Power Installation Database.” Retrieved from:https :1/doe.icfwebservices .com/chpdb/ 5.Weiss,J &Sarro,M.,2013,“The importance of long-term contracting for facilitating renewable energy project development.”[White paper].Retrieved June 15,2815,from: http ://www.brattle.com/system/publications/pdfs/000/004/927/original/The_Importance_of_Long- Term_Contracting_for_Facilitating_Renewable_Energy_Project_Development_Weiss_Sarro_May_7_20l3 pdf?1380317003 6.Fox-Penner,P.S.,1990,“Cogeneration after PURPA:Energy conservation and industry structure,”JL &Econ.33,517. Unique Identifier:98.169.247.130 2 Jean Jewell From:docfox@cableone.net Sent:Thursday,June 25,2015 5:41 PM To:Beverly Barker;Jean Jewell;Gene Fadness Cc:docfox@cableone.net Subject:Case Comment Form:Edward Burton Name:Edward Burton Case Number:IPC-E-15-01 Email:docfox(cableone.net Telephone:208-798-0956 Address:3213 8th St E Lewiston ID,83501 Name of Utility Company:Avista Acknowledge public record:True Comment:Power suppliers must be permitted to enter into long-term contracts in order to be able to finance major projects leading to a diversity of suppliers and a diversity of power generation devices.For example,I could not begin to create a large land-base solar generation facility,without being to show a bank that I have a source of income to repay the necessary loan.The logic in that seems impeccable. This is a public comment,as I do not in fact propose any such project.I did some years ago work as an attorney for owners of/participants in the TAPS (Alyeska Pipeline)from Prudhoe Bay to Valdez,which project would have been impossible without long-term prospects for shippers of the product.Getting into solar power generation would have similar economic needs. Unique Identifier:184.155.237.180 1 Jean Jewell From:nunyabiznus @ nunya.com Sent:Friday,June 26,2015 7:25 AM To:Beverly Barker;Jean Jewell;Gene Fadness Cc:nunyabiznus@nunya.com Subject:Case Comment Form:Daniel Pfankuch Name:Daniel Pfankuch Case Number: Email:nunyabiznus(nunya.com Telephone: Address:5170 Mountain View Dr. Boise ID,83704 Name of Utility Company:Idaho Power Acknowledge public record:True Comment:Who are you trying to kid?It is all about the profit for Idaho Power.Get into the 21st century.Alternative power needs to be embraced and utilized.It will eventually put your company out of business,thank goodness,so start getting with the times and make the changes to help people and this planet. Unique Identifier:71.220.131.176 1