20250804Comment_1.pdf

PUBLIC WORKS DEPARTMENT
B O I S E MAYOR: Lauren McLean I DIRECTOR: Stephan Burgos
C I T Y O F T R E E S
July 1, 2025
Ms. Monica Barrios-Sanchez, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ID 83714
SUBJECT: Case No. IPC-E-25-23 — Idaho Power Company's 2025 Integrated Resource
Plan
Dear Ms. Barrios-Sanchez,
The City of Boise ("city") submits the following comments on Idaho Power's 2025
Integrated Resource Plan ("IRP"). We have participated in the development of the last
several IRPs and note how the process has continued to evolve in positive ways such as
staff responsiveness to advisory council questions and comments. We support the 2025
IRP's Preferred Portfolio's substantial additions of solar, wind, and storage resources, as
well as the planned exits from coal-fired generation, which align with both Idaho
Power's and the City's long-term decarbonization goals.
However, the city is concerned about the inclusion of 550 MW of new natural gas
capacity in the Preferred Portfolio. While recognizing the need for reliable capacity, the
city believes additional fossil fuel infrastructure impacts the trajectory toward Idaho
Power's 2045 clean energy commitment as well as the city's clean energy goals. The
city urges Idaho Power to prioritize clean energy alternatives and revisit assumptions
that led to this investment, notably inclusion of climate risk beyond extreme weather
(including future hydropower uncertainty), carbon price scenarios, and fuel price risk,
as detailed in the next paragraph.
The City encourages Idaho Power to further incorporate climate-driven risks—such as
changing hydropower availability and wildfire-related PSPS events—into its reliability
modeling. We recommend that the utility build upon the wildfire risk modeling in its 2025
Wildfire Mitigation Plan by explicitly evaluating how climate risk related to wildfire risk (as
well as increasing PSPS frequency) could affect system reliability, adequacy, and cost.
Since scenarios with higher risk (e.g., high carbon prices) drive up costs, this should be
reflected broadly, not confined to a few cases. We recommend that climate risk be
treated as a central input across all portfolios—not just as a sensitivity.
We also note the discrepancy between Idaho Power's and PacifiCorp's plans for
Bridger Units 3 and 4 and emphasize the need for transparency around joint decisions
and their potential impacts.
BOISE CITY HALL:150 N.Capitol Boulevard I MAIL:P.O.Box 500,Boise,Idaho 83701-0500 1 P:208-608-7150 1 TTY.800-377-3529
BOISE CITY COUNCIL:Colin Nash(President),Meredith Stead(President Pro Tem),Kathy Corless,Jimmy Hallyburton,Jordan Morales,Luci Willits
CITYOFBOISE.ORG/PUBLICWORKS

Additionally, the City would like Idaho Power to reevaluate the potential role of
geothermal generation given recent technology advances. The fact that geothermal is
selected in the "extreme weather" scenario (2025 IRP p. 131) reinforces its value in a
climate-impacted system. Additionally, costs related to climate risk could positively
impact the cost-benefit analysis of new geothermal power construction, especially with
new federal legislation for geothermal energy. As mentioned above, the city believes
climate risk will have a more significant impact than what is anticipated in the current
IRP analysis over the next 20 years. We encourage Idaho Power to evaluate geothermal
more thoroughly and include it in core portfolio modeling.
We appreciate the opportunity to provide input on the 2025 IRP and value our ongoing
collaboration with Idaho Power as we work toward a clean, reliable, and affordable
energy future.
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