20020830Idaho Rural Council(2).pdf

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BEFORE THE IDAHO PUBLIC UTILITIES coMM~~ioN 0
Case No. IPC-02--08 2002 AUG 30 AH I!:
Comments on Idaho Power lOry!) P:J::'LlC
2002 Integrated Resource Plan UTILITIES COf"I~ilSSlOH
From the Idaho Rural Council
Prepared by Bill Chisholm, Energy Coordinator' .
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It is our position that this is not an "integrated resource plan , what it is, is a
resource plan to justify a particular project, a particular course of action. Idaho Power
2002 Integrated Resource Plan is flawed for three primary reasons; first of all the process
was flawed and if the process is flawed the product can t help but be flawed. Secondly
the assumptions are flawed and thirdly with flawed process and flawed assumptions the
analysis aspect of the plan was flawed. We will address these flaws in that order to back
up our claim that Idaho Power s 2002 IRP should be rejected and the process started
anew.
First let us discuss the process. Idaho Power, because of its monopoly status has a
special relationship with its customers that other businesses don t have. It has because of
its monopoly status what is akin to the trust relationship that the United States
Government has with Native American tribal governments. Idaho Power s ratepayers
rely on Idaho Power to meet their electrical needs, as citizens of the area in which they
live the also rely on Idaho Power to meet those needs not only in terms of costs
reliability and safety, but to help steward the resources and quality of life that might be
impacted by Idaho Power s management decisions. The Idaho Public Utilities
Commission oversees this relationship, but also relies on an interactive relationship
between Idaho Power and its customers.
As part of the process of developing the Integrated Resource Plan, Idaho Power
was to hold a number of public meetings, ostensibly to get input from the public as to
what should be considered in the plan. The Idaho Rural Council was looking forward to
this process and to participate fully in the discussion. At the first public meeting,
discussion was limited to Idaho Power s agenda, which was to discuss the water/weather
data they should use for planning purposes. That discussion centered on whether to use
the mean averages or to skew the planning process toward a more severe prospect.
Having just gone through a severe drought throughout the region, we didn't see a
problem of looking at a more severe case scenario for planning purposes. What we asked
for at that meeting was to also look at what Idaho Power could do in terms of
conservation, efficiencies, shaping of demand curves and alternatives to meet projected
shortfalls. We were told that would happen at other meetings in the future.
There was only one more meeting and that was a public meeting to unveil the
draft plan. There were no discussions on alternatives, they were vaguely mentioned in
the plan but there was no public discussion of the options available to Idaho Power to
meet their obligations to their ratepayers, the citizens of Idaho that live within their
service area. The trust relationship was broken, the process flawed. The whole public
input aspect was merely a charade to say that public meetings were held. The public was
allowed to comment on the draft IRP, but it came out unchanged.
Nest let us discuss the assumptions made. Idaho Power, based on its 70%
water/weather worse case scenario assumed that there would be needle spike short falls
of production to meet peak demand in July-August and in December-January of most
years starting in 2005. Those demand curve assumptions seemed to be cast in stone, that
they are real and solid and that nothing can be done to shape those curves. Getting back
to process, without public input and discussion what can we know about the options
available to us? Idaho Power customers were hit with high electrical power costs during
the recent "energy crisis , a crisis that was eased through energy conservation and
efficiency measures, measures that had they been in place might have lessened or
prevented the crisis. The three tiered rate structure, which the Idaho Rural Council
supported was a key factor in the success of that conservation effort. Idaho Power
advanced nothing in the 2002 IRP to encourage conservation. If there had been true
public discussions about conservation, efficiency, load shaping and alternative
production, then the demand assumptions Idaho Power relied on in their IRP would have
been different and that would have led various other analysis of possibilities not only in
terms of load projections but assumptions about how to meet those loads.
Finally in the area of analysis we have the final flaw. First to have a valid
analysis or assessment of any scenario, one has to have some criteria on which to assess
the situation. Here again, the public meeting process would have played an important
role; there the public would have helped to define the scenario. There is where the
assumption about demand would have gotten defined as well as some sense of what the
goal of the IRP should be. Left to Idaho Power and Ida-corp, that goal was to build the
Garnet facility. With public input it would have been to implement energy efficiency and
conservation efforts, to shape the load curves and implement some renewables before
looking to other means of production. The analysis done on the 2002 IRP was limited by
both the process of defining demand and the assumptions made about that demand. A
false assumption was made that only one option existed to deal with demand and that was
to build a power plant to meet wasteful, thoughtless consumption. Yet there was a host
of evidence in the region that the demand curved could be shaved and shaped with other
alternatives. Those alternatives weren t part of the goal and were not thoroughly
analyzed. It is exactly that kind of scenario that got us int? the crisis in the first place.
We lack in Idaho a coherent and comprehensive policy; instead we rely on such
mechanisms as the integrated resource planning process. While Idaho Power talks about
some public interest aspect of this process, it demonstrates no tangible ways to bring the
public s concerns into the planning process. Public hearings without listenings are a
serious dis-service. We need a full, honest and open discussion of this issue. A new
docket should be opened on this matter so that this type of discussion can take place.
Bill Chisholm
Energy Coordinator
Idaho Rural Council