20020830Purdy motion.pdf

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Brad M. Purdy (ISB # 3472)
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
bmpurdy~hotmail.com
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' ICUTiLlTIES- COIT1fTf(SSION
William M. Eddie (ISB # 5800)
LAND AND WATER FUND OF THE ROCKIES
O. Box 1612
Boise, ID 83701
[phone]
FAX: [phone]
lawfund2~rmci.net
Attorneys for Idaho Rivers United, NW Energy Coalition, Land and Water Fund of the
Rockies, and Idaho Rural Council
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING
BY IDAHO POWER COMPANY OF
ITS 2002 INTEGRATED RESOURCE
PLAN (IRP)
Case No. IPC-02-
MOTION TO INITIATE
FORMAL PROCEEDING
COME NOW, Idaho Rivers United, NW Energy Coalition, Land and Water Fund
ofthe Rockies, and Idaho Rural Council ("Clean Energy Advocates" or "Advocates
pursuant to Rules 51-58 of the Rules of Practice and Procedure ofthe Idaho Public
Utilities Commission, IDAPA 31.01.01.51-, and moves this Commission for an Order
opening a formal docket for the purposes specified below.
This Motion is supported by the comments of the Clean Energy Advocates filed
herewith, and by the following points and authorities,
ORIGINAL
MOTION TO INITIATE FORMAL PROCEEDING --
ARGUMENT IN SUPPORT OF MOTION
The Clean Energy Advocates have filed comments in response to Idaho Power
Company s 2002 Integrated Resource Plan, pursuant to the public comment provided in
the July 18 2002 Notice in this matter. As stated in those comments, the Advocates
believe the 2002 IRP does not present a reasonable and prudent plan to meet Idaho
Power s customer load in a cost effective manner. Moreover, the Advocates believe the
IRP's deficiencies, as well as the important changes in planning direction reflected in the
IRP , are of a sufficient magnitude to warrant greater scrutiny by the Commission and the
public. Therefore, the Groups ask the Commission to open a formal docket and hold
hearings for the purpose of investigating cost effective resources which should be
pursued in the short and long term to the benefit of ratepayers, but which Idaho Power
has chosen to disregard in its IRP.
First, although the IRP repeatedly recognizes that peak power demands will likely
drive the need for more resource acquisition, the IRP does not include any meaningful
analysis of load management and other demand-side resources. With Idaho Power now
engaging in only the most minimal demand-side management, a careful exploration of
which types of such resources could be acquired, and at what cost, is clearly warranted.
The Groups are aware that Idaho Power is now initiating studies of the potential for
demand-side management in its service territory, and will be increasing its DSM
programs pursuant to Order No. 29026. Since better information is becoming available
it is now all the important that Idaho Power undertake a meaningful exploration of
demand-side resources in the IRP. This proceeding also should include investigation of
MOTION TO INITIATE FORMAL PROCEEDING -- 2
financial incentives for Idaho Power and other utilities to engage in meaningful and
effective demand-side management programs without incurring financial hardship.
We also believe it is appropriate for the Commission to investigate the prudence
of Idaho Power s planning assumptions in the IRP, including the Company s move
toward more extreme water and weather conditions. It also appears that the "Garnet"
gas-fired power plant now will not be constructed, although the 2002 IRP appears to have
been drafted assuming additional peaking generation would be available from that
facility.
Moreover, the Groups note that in Case No. IPC-01-, the Idaho Rural
Council/Citizens for Responsible Land Use (IRC/CFRLU) filed extensive testimony and
exhibits regarding many of the issues that are relevant to the Idaho Power 2002 IRP and
to more far-reaching issues that transcend that utility and that particular IRP. Because of
the manner in which that case was ultimately resolved, these issues never were
substantively addressed by the Commission. It seems regrettable for the analysis
engaged in not only by IRC/CFRLU, but the other parties to the case as well, to go to
waste. Instead, a formal proceeding could be initiated to address those issues.
The Groups propose that the Idaho Power 2002 IRP be sent back to the Company
pending the outcome of formal proceedings to be held in Fall 2002. We believe such
proceedings could encompass numerous issues, but request that the Commission
investigate the following: (1) changes to the IRP development process, including more
rigorous public and Commission review, as well as meaningful development of
alternative methods of meeting loads; (2) specific DSM (both load management and
general efficiency) resources alternatives; (3) specific alternative resource options
MOTION TO INITIATE FORMAL PROCEEDING -- 3
including increased acquisition non-hydropower renewable energy resources and other
distributed generation; (4) Idaho Power s plans for meeting peak loads in the absence of
the Garnet facility; and (5) investigation of the prudence of Idaho Power s new planning
criteria for more extreme water and weather conditions.
This docket could be specific to Idaho Power, though the Groups believe that it
would be in the best interests customers of regulated electric utilities in Idaho if the
docket were generic and involved all the major electric utilities. The IRP process for
Idaho Power, Avista and PacifiCorp has become increasingly lacking in public and
Commission input. It is not the Group s intent for this formal proceeding to be
adversarial, but rather more investigatory in nature, leading to a revised IRP process and
the implementation of load management and alternative resource development.
The Groups request that the foregoing motion be granted, and that the
Commission reject Idaho Power s 2002 IRP pending completion of formal proceedings
addressing the issues outlined above.
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RESPECTFULLY SUBMITTED, this day of August, 2002.
Brad M. Purdy
Land and Water Fund of the Rockies
MOTION TO INITIATE FORMAL PROCEEDING -- 4