20070112Comment by CPR.pdf

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Citizens Protecting Resources
42 West 600 South
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Jerome, ID 83338 !".-'V;._i' :
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8 January 2O0 20il7 JM~ 12 (H"1 8:
Idaho Public Utilities Conwission
P. O. Box 83720
Boise, ID 83720-0074
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Re: Case Number IPC-06-
Dear IPUC:
Thank you for requesting public input on Idaho Power Compnay s (IPC)
2006 Intrgrated Resource Plan (IRP).
Citizens Protecting Resources (CPR) was organized in response to Sempra
Energy s proposal to construct a large, merchant coal-fired power plant near
the Midpoint Substation northeast of Jerome. CPR is a diverse mixture of
people, primarily from Jerome County, which was one of the main "political
forces" responsible for the two-year moratorium, the ongoing effort to update
Idaho s Energy Plan, Idaho s decision to opt out of the Federal Mercury Cap
and Trade Program, and several more local decisions relating to energy, growth,
environmental and quality of life issues. CPR remains active to fu'lfill its
mission which is "by working with others, to preserve the clean environment
and high quality of life enjoyed by Magic Valley citizens.
CPR recognizes that IPC is in the business of selling electricity notrestricting its use. Therefore, it is not surprising that the IRP emphasizes
supply and includes only a token amount of demand side management (DSM).
While wasting electricity through inefficient use may be good for IPC (the
more they sell the more money they make) it is NOT good, and in fact should
be unacceptable, public policy.
We encourage IPUC to do everything within your power to mandate, or at
least strongly encourage, efficiency and DSM. It may be necessary to make
DSM revenue neutral for IPC. Modifying rate structures is also a proven
technique for encouraging DSM.
The other obvious shortcomming in the IRP is its low emphasis (actually
deemphasis) on non-hydro renewable energy sources. CPR believes IPUC (or the
State Energy Plan) should require aggressive renewable portfolio standards.
Regarding the questions asked on pages 6 and 7 of the IRP, IPC should
acquire green tags and such costs should be recoverable.
CPR is disappointed that IPC chose to pursue Portfolio F2 rather thanFl. Fl has the .. . lowest risk-adjusted total portfolio costs..." (page 90),
. . . the smallest carbon risk." (page 79), and
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has the least variability...
due to yearly fluctuations in water flow(page 83).
In summary, CPR believes an IRP which relies much more on DSM and non-hydro
renewables and less on thermal is a superior one to that chosen by IPC.
Respectfully SUbmi te
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President Vice-president Secretary
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Treasurer