20250502Comment_1.pdf

From:Justin Hayes <[e-mail]>
Sent: Friday, May 2, 2025 3:16 PM
To: secretary<[e-mail]>
Cc: [e-mail]
Subject: ICL comments re: Case No. IPC-E-24-45
To whom it may concern,
Please find attached the Idaho Conservation Leagues Comments in Support of Idaho
Power's Application for a Certificate of Public Convenience and Necessity-Case No. IPC-
E-24-45
Please contact us if you have any questions or if this attached file is not available to you.
Have a nice weekend,
-jh
Justin Hayes
Executive Director
He/Him/His (what's this?)
Idaho Conservation League
PO Box 844, Boise, ID 83701
Shoshone and Bannock Tribal lands
Office: [phone] x224
http://www.idahoconservation.org• http://www.idahoconservation.org/blog
Twitter: idconservation
Facebook: /idahoconservationleague
Instagram: @idahoconservationleague
Become a member and help us grow our conservation community!
I DAHO
CONSERVATION
LEAGUE
I DAHOCONSERVATION.ORGOONATE
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DA H O
CONSERVATION
LEAGUE
5/2/25
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720 Boise, ID 83720-0074
Submitted via email to: secretary(a-bpuc.idaho.gov
Re: Comments in Support of Idaho Power's Application for a Certificate of Public
Convenience and Necessity — Case No. IPC-E-24-45
To the Idaho Public Utilities Commission:
The Idaho Conservation League (ICL) respectfully submits these comments in support
of Idaho Power's application for a Certificate of Public Convenience and Necessity
(CPCN) in Case No. IPC-E-24-45.
ICL is a nonprofit 501(c)(3) organization headquartered in Boise, Idaho. As Idaho's
leading voice for conservation, ICL represents several thousand members who reside
within Idaho Power's service territory and who are directly affected by the Commission's
decisions regarding electric resource planning and investment. Our members are
deeply concerned about the environmental and human health impacts associated with
energy production and have a strong interest in the advancement of clean, reliable, and
affordable energy systems.
ICL has been an active participant in Idaho Power's integrated resource planning
process and served as a public interest representative on the 2023 Integrated Resource
Plan (IRP) Advisory Council. We continue to engage in Idaho Power's planning and
procurement activities. Through numerous venues, we advocate for resource decisions
that minimize environmental impacts, reduce costs, and maintain grid reliability for
Idaho Power's customers.
At present there are several factors which put at risk Idaho Power's ability to safely
deliver reliable, affordable, and environmentally sound electricity to its customers.
These include the projected capacity deficits identified in ongoing Integrated Resource
Planning as well as the growing impact of extreme weather events and wildfires that are
attributable to climate change. Idaho Power has experienced two weather-related
energy emergencies since 2022 after a period of experiencing no energy emergencies
in over a decade. Moreover, we should anticipate the impacts of increasingly severe
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wildfires on Idaho Power's transmission system and the additional flexibility in grid
operation such impacts will require.
For these reasons and others outlined below, we support Idaho Power's request for a
CPCN to develop two battery energy storage facilities totaling 100 megawatts (MW) of
dispatchable capacity. The 2023 IRP identified a minimum need for 350 MW of new
peak capacity resources by 2026-2027. While Idaho Power's 2026 RFP process
identified resources to fill a portion of that need, the inability to contract for the full 236
MW of 2026 capacity led the Company to pursue these battery storage facilities as
alternative, least-cost, least-risk solutions. These facilities are essential to meeting
Idaho Power's obligation to provide adequate and reliable service to customers in 2026
and beyond.
Battery storage is a proven, cost-effective technology for meeting peak demand. Unlike
traditional peaking plants that rely on fossil fuels, battery energy storage systems
(BESS) offer fast-ramping, flexible capacity that can be deployed instantaneously to
provide frequency response and regulation to maintain power quality during high
demand or unexpected generation loss. Compared to natural gas "peaker" plants,
recent studies have shown that BESS offers faster response times, better frequency
response, greater flexibility and better environmental performance at lower cost.
Battery systems are also safe and reliable. Utility-scale battery projects deployed across
the U.S. have demonstrated an excellent safety record when designed, operated, and
maintained with the latest in battery management and thermal management systems,
fire detection and suppression systems in conjunction with a robust safety culture.
In addition to reliability and cost benefits, battery storage enables Idaho Power to
capture and store electricity generated from variable and intermittent renewable sources
such as solar and wind. This capacity allows clean energy to be stored when it is
abundant and dispatched when needed—especially during peak hours or periods of grid
strain. As Idaho Power continues to integrate higher levels of renewable energy, energy
storage will be critical to ensuring grid stability, maximizing the value of zero-carbon
generation, reducing reliance on fossil fuels, and ensuring that its customers have
continued access to affordable, reliable electricity.
The battery storage proposed in this CPCN, while important, is not a substitute for the
additional renewable generation and demand management initiatives that are needed in
the near future. Apart from continuing economic growth in Idaho Power's service area,
we may see more residential and commercial customers switching out older
fossil-fueled space and water heating systems with improved electric heat pump
systems. The value of BESS in facilitating transmission and distribution upgrades,
firming capacity, offering frequency response and regulation, and providing value in
"black start" scenarios are all advantages that new BESS installations can leverage as
these changes occur.
For these reasons, ICL strongly supports Idaho Power's request for a CPCN for the
proposed energy storage project. The project aligns with the utility's most recent IRP,
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supports the Company's statutory obligation to provide safe and reliable service, and is
in the best interests of Idaho Power's customers. Granting the CPCN will allow Idaho
Power to move forward with a cost-effective, environmentally sound solution to its
near-term capacity needs while helping to lay the foundation for a more responsive,
resilient and intelligent grid in the future.
Thank you for considering these comments. Please do not hesitate to contact us if you
require additional information.
Sincerely,
Brad Smith
Conservation Director
Idaho Conservation League
[phone] ext. 403
[e-mail]
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