20091209ICL Comments.pdf

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2009 DEC -9 AM 8= 37
Conservation League
PO Box 84, BoÎ$e, ID 83701
208.345.6933
Idaho Public Utilties Commission
PO Box 83720
Boise, ID 83720-0074
November 6,2009
RE: Idao Conservation League Comments on Avista's 2009 Electric Integrated Resource Plan,
Case No. AVU-E-09-09
Honorable Commissioners:
Thank you for the opportunity to com men t on the A vista's 2009 Electric Integrated Resource
Plan (IRP). For thirty-four years, the Idaho Conservation League (ICL) hcls been Idaho's voice for
clean water, clean air, and wilderness-values that are the foundation to Idaho's extraordinar
quaity of life. As Idaho's largest state-based conservation organization we represent over 9,500
members, many of whom have a deep personal interest in protecting our clean air, clean water,
and quaity of life.
ICL's comments address three issues in A vista's 2009 IRP: Energy efficiency, renewable energy
acquisition, and carbön emissions.
A. Energy Efficiency
ICL applauds Avista for planning to meet 26 percent of its new load growth through 2020 with
energy efficiency, which is a 3.3 percent increase in conservation from the 2007 IRP. These goals
are consistent with the Northwest Power and Conservation's Draft Sixth Power Plan, which calls
for 5800 averages megawatts of conservtion over the next 20 years. The Draft 6th Plan finds that
all new demand can be met with efficiency and renewable energy.
ICL encourages Avista to continue looking for more opportunities in energy efficiency and
demand side management, including both customer programs and transmission and distriution
systems. Energy efficiency is cheapest and cleanest way to meet Idaho's energy needs, and there
are stil many opportunities to capture energy savings.
B. Renewable Energy
ICL is pleased to see the Preferred Resource Strategy (PRS) includes 350 megawatts of windgeneration and encourages the Company to explore other non-wind renewable energy options.
The Idaho Energy Plan calls for efficiency and renewable energy to be the first resources acquired
to meet growing energy needs. The acquisition of renewable energy will allow A vista to meet its
requirements under Washington's Renewable Portfolio Standard (RPS) and will help the
Company be better prepared for a federal RPS. In addition, a more diverse energy portfolio
reduces risk for the Company and its ratepayers by mitigating fuel price volatility.
C. Carbon Emissions
ICL is also pleased to see no signifcant increase in carbon emissions over the 20-year timeframe in
the PRS but strongly encourages A vista to develop a strategy to actually reduce carbon emissions.
Focusing on developing a more diverse renewable energy portfolio and increasing energy savings
with efficiency may allow the Company to avoid or postpone building new natural gas fired
generation, which would lower Avista's carbon emissions. This also benefits ratepayers by avoiding
natural gas price volatility.
Thank you for the opportunity to comment on A vista's 2009 IRP. If you have questions about
our interest in this matter, please contact me at [phone] ext. 12 or at
bbridgeCiidahoconservation.org.
Sincerely,
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Betsy Bridge
Energy Efficiency Associate
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