20020920Reply of Clean Energy Advocates.pdf

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Brad M. Purdy (ISB # 3472)
Attorney at Law
BarNo. 3472
2019 N. 1 ih St.
Boise, ID. 83702
[phone]
FAX: (208) 384:-8511
bmpurdv~hotmail.com
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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)
REPLY OF CLEAN ENERGY
ADVOCATES ON MOTION TO
INITIATE FORMAL
PROCEEDING
Case No. IPC-02-
Idaho Power s objection to the Motion to Initiate Formal Proceedings by Idaho
Rivers United, NW Energy Coalition, Land and Water Fund of the Rockies, and Idaho
Rural Council ("Advocates ), is based primarily upon two grounds. First, that the Gamet
facility still exists as a possible future resource, and that the Company has until October
to file its "report or plan" regarding whether Gamet will actually be constructed. Answer
to Motion, p. 3. That report or answer will, presumably, also indicate the Company
ADVOCATES' REPLY ON MOTION TO INITIATE FORMAL PROCEEDINGS --
ORIGINAL
plans to meet future energy needs if Gamet remains financially unviable. Second, Idaho
Power contends that the availability and possible implementation of DSM is already
being addressed by the Energy Efficiency Advisory Group ("EEAG") pursuant to
Commission Order in Case No. IPC-Ol-13. Idaho Power states that: "(aJs those
programs are developed, funded and implemented, they will be included in the
Company s plans for meeting load." Answer to Motion at p. 4.
Neither argument is a valid excuse for the Company s deficient IRP. If Idaho
Power is permitted to file an IRP grounded on a resource which in all likelihood will not
be acquired, and also lacking in any serious discussion of potential cost-effective DSM
and renewable resources, then the IRP process itself is rendered meaningless.
Regarding Gamet, the Company has all but declared that potential resource to be
defunct; yet Gamet formed much of the foundation upon which Idaho Power s 2002 IRP
was constructed. The 2002 IRP should be rejected for that reason alone.
Idaho Power s statement that DSM resources will be "developed, funded and
implemented" sometime in the future highlights the concerns expressed by the Advocates
in the Motion and comments submitted in response to the Company s IRP. We hope
Idaho Power is correct that DSM implementation is actually forthcoming. The critical
point for purposes of the current Motion, however, is that the IRP fails to discuss what
those resources might be, even in the most general terms.
Even if detailed studies ofDSM potential are not complete for Idaho Power
service territory, the Company certainly is not working from a blank slate on this issue.
Excellent information is available through regional studies, experience of other regional
utilities during the energy crisis of 2000-0 1 , and Idaho Power s historical experience in
ADVOCATES' REPLY ON MOTION TO INITIATE FORMAL PROCEEDINGS -- 2
DSM, all of which could have informed the IRP, but were ignored by Idaho Power. The
testimony submitted in the Gamet case (IPC-01-42) by witnesses Tom Power, Bill
Chisholm and Jeff Brooks, demonstrated that there are many possible ways to avoid the
relatively high marginal cost and risky homogeneity of relying almost exclusively on
traditional hydropower and thermal-based generating plants (which use fuel sources
subject to the whims of nature and market price volatility) to meet essentially all future
energy needs. Should the Commission grant the pending Motion and hold formal
hearings in this matter, the Advocates intend to present testimony of these witnesses, as
well as Ms. Nancy Hirsh, Policy Director ofNW Energy Coalition.
The Advocates understand and anticipated reluctance to open a new docket for the
purpose of addressing the many, important issues facing Idaho Power and its ratepayers.
But we believe the IRP process, and perhaps general rate cases, are the only proceedings
in which the Commission and the public must take a comprehensive look at Idaho
Power s resources and plans. While the trend toward increasingly piecemealed review of
regulatory issues may have value in some respects, the IRP process is one of the few
opportunities we have to take a step back, and insure that the Company s long-term
planning is just and reasonable. If the Company s load/resource balance predictions are
even close to accurate, there is little time to waste in devising an IRP, and IRP process
that is meaningful for the Commission and the public. IRPs are only filed every two
years, and the Company is not required to update the data therein during the interim.
The Advocates are not suggesting that the Commission "micro-manage" Idaho
Power s resource acquisition decisions. Nonetheless, the Advocates strongly urge the
! Incidentally, Idaho Power s Attachment 1 to its Answer to- Motions neglected to
list the NW Energy Coalition as a participating member of the EEAG.
ADVOCATES' REPL Y ON MOTION TO INITIATE FORMAL PROCEEDINGS -- 3
Commission to take a more proactive role in scrutinizing Idaho Power s IRP and
ensuring that ratepayers' interests are properly addressed therein.
In sum, the IRP is grounded on a resource which is unlikely to be built, and does
not disclose all cost-effective resources to help the Company and the Commission
comply with the fundamental statutory mandate governing regulated monopolies such as
Idaho Power: to provide "adequate, efficient, just and reasonable" service. IC 9 61-302.
The Advocates view the IRP as, ideally, a "road map" toward that mandate, which should
include alternative routes. At present, the map is incomplete.
We recognize that a formal hearing process would be a departure from the
Commission s normal review ofIRPs. However, we believe such an investigation is
warranted in this case. The Advocates request that the Commission initiate formal
proceedings for the purpose of investigating cost effective resources which should be
pursued in the short and long term to the benefit of ratepayers.
Illiam M. Eddie
Land and Water Fund of the Rockies
ADVOCATES' REPLY ON MOTION TO INITIATE FORMAL PROCEEDINGS -- 4
CERTIFICATE OF SERVICE
I hereby certify that on this 20th day September 2002, true and correct copies of the
foregoing REPLY TO MOTION TO INITIATE FORMAL PROCEEDING were delivered to the
following persons via the method of service noted:
Via Hand-Delivery:
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Via U.S. Mail:
Barton Kline
Greg Said
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
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ADVOCATES' REPL Y ON MOTION TO INITIATE FORMAL PROCEEDINGS -- 5