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May 18, 2005
Public Utilities Commission
1580 Logan Street, OL 2
Denver, Colorado 80203
RE: Docket No. O5R-112E—Decision No. CO5-0314 issued March 29, 2005, Notice of Proposed Rulemaking
Dear Commissioners:
Much of the resource development required under Amendment #37 will occur in rural Colorado. While rural communities are largely served by non-jurisdictional customer-owned utilities, these same communities have a direct interest in the decisions you make under the subject docket.
The Rocky Mountain Farmers Union supported adoption of Amendment 37 and has been in close communication with rural constituencies concerning its implementation.
On May 12, 2005 we held an all-day meeting with leaders of five locally-owned wind projects that are seeking market access through a daunting array of issues. Our comments on draft rules clearly reflect concerns expressed during this meeting.
On April 22-23 we organized an Amendment 37 tour of renewable projects within Northeastern Colorado counties headlined by Congressman Mark Udall and former House Speaker, Lola Spradley (Co-chairs of the Amendment 37 Campaign). This remarkable opportunity to communicate with local developers, opinion leaders, elected officials and customer-owned utility executives demonstrated the excitement and level of commitment found in rural communities. Over the next few months, we will extend the tour to include all of rural Colorado.
We have established, through Colorado Working Landscapes, a website and electronic newsletter directed to 900 rural Coloradoans with an interest in renewable energy development.
The Farmers Union and Farm Bureau co-chair the Colorado Renewable Energy Forum that enables us to communicate on a regular basis with advocacy organizations, utility
executives, consultants, financial interests and public officials. Draft Amendment 37 rulemaking was the subject of a recent meeting.
Optional approaches within the draft rule raise the question as to whether the Commission will delegate rulemaking responsibility to individual utilities or assume a leadership role. Our judgment is that delegating responsibility to multiple entities that opposed Amendment 37 would risk confusion and delay and be inappropriate. Developers we have talked to are frustrated trying to deliver power through multiple jurisdictions operating under different sets of rules. Delegated rulemaking would simply increase this frustration level and dampen access to markets.
To the degree possible, we want draft rules applicable to solar made applicable to all eligible renewable energy technologies. Having simple and efficient requirements for interconnection, insurance, net metering, and the like is vital to all small project technologies including wind and biomass generation.
Adoption of Amendment 37 was through a statewide vote and, to the degree possible, economic benefits from resulting development should be available statewide. Specifically, the draft rule should make is clear that a qualifying retail utility can acquire REC’s outside its service territory. Furthermore, REC’s attributable to off-grid applications, such as a solar livestock watering pump, should be accommodated by the rules.
Transmission is clearly the primary issue of concern for rural communities. They know, that the economic benefits they seek from renewable energy development are contingent on transmission. Many rural areas are not even candidates for a project because of inadequate transmission. We encourage the Commission to look at the end goals of Amendment 37 and how to structure an efficient transmission capability.
We appreciate the consideration we know you will give our comments. We look forward to the development of an effective set of rules that facilitate rural development.
Sincerely,
John Stencel
President
Rocky Mountain Farmers Union
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