Citizens for Responsible Land Use.pdf

Citizens for Responsible Land Use
PO Box 192
Middleton, ID 83644

August 28, 2002

Idaho Public Utilities Commission
472 W. Washington St
Boise, ID 83720

Subject: Draft 2002 IPC Integrated Resource Plan
IPUC Case Number IPC-E-02-08

Dear Commissioners:

Citizens for Responsible Land Use is a non-profit organization which exists in
part to advocate responsible energy production and consumption within the state of
Idaho. As an intervener in case number IPC-E-01-42, dismissed on July 24, 2002,
Citizens for Responsible Land Use (CFRLU) was prepared to present a case questioning
the validity of Idaho Power’s draft 2002 Integrated Resource Plan.

In the Garnet Case, CFRLU, together with Idaho Rural Council, submitted strong
written testimony in by Dr. Tom Power that thoroughly questions the validity of this
document as a true Resource Plan. According to Dr. Power, Integrated Resource Planning
was developed as a tool to integrate supply-side and demand-side resources into one
unified planning process. However, the 2002 IRP makes no effort to integrate supply-side
and demand side planning. Throughout the entire draft, there is only a very brief
discussion of conservation and demand side management. The discussion of “Existing
and Planned Resources,” and “Future Resource Options,” concludes by saying that
“conservation, demand side measures, and pricing options must be carefully designed and
targeted to cost effectively address the projected deficits.” There is no indication
however that Idaho Power, in its Integrated Resource process had done any “careful
design and targeting.”

For all practical purposes, the Integrated Resource Plan appears to be formulated
as a justification for the questionable Garnet Energy Facility. In the plan, Garnet is
considered an absolute resource, when we know that this is not the case! Now that the
future existence of Garnet Energy is doubtful, the process must be re evaluated. Idaho
Power has focused almost solely on a supply-side process, while rejecting true Integrated
Resource Planning. Demand Side Management opportunities should and must be
explored immediately.

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Idaho Power has a unique opportunity at this juncture to create a partnership with
its residential and commercial customers to make smart energy moves for the future of
Idaho. We sincerely hope that this happens.

Thank you for your time,

Jonna Weber
On behalf of Citizens for Responsible Land Use

cc: Jean Jewell, Commission Secretary
Barton Kline, Idaho Power Company
Greg Said, Idaho Power Company