20150629Comments (2 Total).pdf

June28,2015
To:Idaho Public Utitity Commission,Regarding Case IPC-E-15-01
From:Courtney White
As an Idaho Power customer and business person,urge the IPUC to decline application IPC-E-15-
01 requesting a tenfold reduction in the term of PURPA agreements.Declining the application
best serves the long-term interests of customers for several reasons:
1)Competition fosters competitive costs.The avoided cost policy atready ensures only cost-
effective capacity is added.Customers cannot benefit from the advantageous trends in
renewable energy or the cost-pressure inherent to competitive markets if utilities are allowed to
impede the development of resources not owned by the utility.
2)Approving the application wouLd create an additionaL incentive for utilities to over-
aggressively add infrastructure in order to preempt PURPA applications,thereby leading to
higher costs over time.Public utilities already have an incentive to over-build utility-owned
infrastructure to the exclusion of others.As CarL Pechman summarized in his book “Regulating
Power”:
Rate of return regulation creates unique incentives for pubtic utilities.These incentives
have traditionally resulted in utilities being biased toward investment in generation to
provide service to their customers to the exclusion of other resource options.
BaLancing market forces is always a challenge in a regulated industry,but this application doesn’t
balance those forces -it tilts them.It augments the incentive for utilities to over-build.
3)PURPA is the law.PC has long vocalized its lack of fondness for PURPA,but we all have to
foltow laws we don’t like.The application before the PUC does not present unique and
compelling reasons to circumvent the law.Is it really IPC’s betief two-year terms are ideal for
any capital investment in energy infrastructure,whether by the utility or by renewable energy
developers?Then there should be an earnest discussion of the utility’s spectrum of long-term
obligations rather than an application uniquely targeting investments not owned by the public
utility.
4)Developers of renewabLe energy should not be punished by IPC’s choice to not plan for
growth in PURPA projects.
If the Integrated Resource Plan represents the company’s best projection of demand and supply-
side resources,the IPC-E-15-01 is unfounded because IPC communicates in the 2015 Draft IRP
that it expects no new PURPA capacity from 2017 -2034.If IPC does actuaLly expect additional
PURPA projects,then the IRP is a misleading projection of our supply-side resources.
IPC states its policy on page 53 of the 2015 IRP Advisory Council Meeting presentation (January 8,
2015):
“Idaho Power has no control over new PURPA Project development,therefore Idaho Power
does not include any assumptions as to what new PURPA projects may or may not
materiatize.”
With regard to the Capacity Planning projections,Idaho Power DOES inherently make
assumptions,it assumes zero growth in PURPA.The 2013 IRP,for example,forecasts increasing
peak-hour load,but forecasts ZERO GROWTH in PURPA capacity from 2014 to 2032.These
capacity planning projections were used by IPC in its advocacy for investment in Bridger coat
capacity.
Secondly,tacking controt is not a reason to omit expected changes in the ptanning process.In
business,we project and plan for growth by competitors all the time.In a free market,the
company that fails to plan bears the consequences.I urge the PUC not to force renewable energy
developers to bear the burden of IPC’s choice not to plan for growth in PURPA applications.
5)The growth in renewable energy projects is not a surprise.Over the past planning period,
there have been endless publications projecting and documenting the growth of renewables.
From a globat perspective,McKinsey &Company summarizes in their June 201 5 article:
“In 2014,nonhydro renewabtes accounted for atmost half (48 percent)of net new power
capacity.This was the third year in a row the figure was above 40 percent.Solar,in
particular,is hitting its stride and has grown an average of almost 30 percent a year for
the past decade.
I ask the PUC not to create roadblocks which deny customers and businesses the opportunity to
benefit from renewable energy and the favorabLe trends associated with it.
6)A push for short-term agiLity shouLd be a push for distributed generation.IPC has expressed
concern that tong-term obligations create undue risk.If retaining the abitity to adapt-as-we go
has vatue,then let’s start a major effort toward renewable energy and distributed generation.
Small-scale projects enable more agile adaptation to changing needs and economics.
The time has come for IPC to embrace PURPA as an integral part of our supply-side resources in
Idaho.I deeply believe it is in my best interest as a customer for the PUC to dectine the
application before the PUC that would thwart competition,lead to higher costs over time,and
deny customers the opportunity to benefit from rapidly improving renewable energy
technoLogies.
Thank you sincerely for your thoughtful consideration.
JEROME
THE CITY OF)EROME
II4i
June23,2015 c
IDAHO,
Idaho Public Utility Commission
P.0.Box $3702
Boise,ID 83702
RE:IPUC Case No.IPC-E-15-01
Dear Commissioners,
The City of Jerome appreciates the opportunity to comment on Idaho Power’s filing with the
Public Utility Commission concerning shortening the length of PURPA contracts.We support
Idaho Power’s request to shorten the length of guaranteed contracts with solar developers
from a 20-year term to a two-year term.We strongly believe Idaho Power will continue to
provide reliable and affordable electricity to our residents.The requirement for twenty-year
contracts is unreasonable due to the ever-changing market prices,energy markets and
economic growth or recession.
We do not believe Idaho Power should have to buy electricity it may not need,and pass the
cost of unneeded power on to its customers.The City of Jerome supports clean energy,and
we are pleased to know that Idaho Power’s electricity comes from clean,renewable hydro
resources.However,moving toward a clean energy future should not come at the expense of
reliability and affordability.The City of Jerome recognizes the efforts made by Idaho Power
to keep power costs in line with current market rates.
The City of Jerome respectfully requests that you grant Idaho Power’s petition to modify the
terms and conditions and decrease the contract term to two years.This will enable Idaho
Power to continue to provide quality service at a low cost.
Sincerely,
David M.Davis,Mayor
City of Jerome
City HII 152 East Avenue )erome tdaho 83338 (208)324—6503 www.cijeome.id.us