20090424Petition.pdf

esIDA~POR~
An IDACDRP Company
BARTON L. KLINE
Lead Counsel
April 24, 2009
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-13
IN THE MATTER OF IDAHO POWER COMPANY'S PETITION FOR
MODIFICATION OF THE FILING DATE FOR ITS 2009 INTEGRATED
RESOURCE PLAN ("IRP'J
Dear Ms. Jewell:
Enclosed please find for filing an original and seven (7) copies of Idaho Power's
Petition in the above matter.
I would appreciate it if you would return a stamped copy of this letter for. my file in
the enclosed stamped, self-addressed envelope.verm'~
Barton L. Kline
BLK:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
BARTON L. KLINE (ISB No. 1526)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Tel: [phone]
Fax: [phone]
bkline(ãidahopower.com
dwalker(ãidahopower.com
R ~. ~. i
1:: "/
20U9 APR 24 PM 12: 39
lJTl
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S PETITION FOR ) CASE NO. IPC-E-09-13
MODIFICATION OF THE FILING DATE )
FOR ITS 2009 INTEGRATED RESOURCE ) PETITIONPLAN ("IRP"). )
)
COMES NOW, Idaho Power Company ("Idaho Powet' or the "Company") in
accordance with RP 053, hereby requests that the Idaho Public Utilities Commission
("Commission") issues its order modifying Order No. 30317 issued on May 23, 2007, in
Case No. IPC-E-06-24, in which the Commission directed Idaho Power to file its "next
full IRP no later than the last business day of June 2009." (Order No. 30317, p. 2.)
Idaho Power requests that the Commission modify the filing date for the 2009 IRP from
the last business day of June 2009 to the last business day of December 2009. This
Petition is based on the following:
PETITION -1
i. BACKGROUND
1. In Order No. 30317, the Commission reviewed the Integrated Resource
Plan ("IRP") filing dates for its jurisdictional electric utilities, Idaho Power, Rocky
Mountain Energy, and Avista Energy and concluded it would be in the public interest if
Idaho Power filed its biannual IRP no later than the last business day of June 2009.
2. The Commission further ordered that the Company provide the
Commission a transitional IRP update in June of 2008. The 2008 IRP update would
address the progress of the Company's short-term action plan; any changes in load
forecast, existing loads, customer base, and purchase power contracts; and any
significant deviations from its 2006 IRP.
3. Idaho Power filed its 2008 IRP Update in June of 2008.
4. Since the completion of the 2008 Update, several major events have
occurred that make it desirable to delay the filing date of the 2009 IRP until the end of
2009 to allow the Company to include the following in the 2009 IRP:
a. Recent permitting delays have pushed completion of the Boardman
to Hemingway 500 kV transmission project beyond 2012, as stated in Idaho Power's
2008 IRP Update. With this delay, the Company plans to treat the Boardman to
Hemingway project as an uncommitted resource in the 2009 IRP. As an uncommitted
resource, the 2009 IRP will address whether the Boardman to Hemingway project
continues to merit inclusion in the Company's near-term resource action plan; and
b. Substantial changes in economic conditions have occurred since
September of 2008 when the load forecast currently being used for the 2009 IRP was
completed. Slowed local and national economic growth may impact the future growth of
PETITION - 2
Idaho Power's customers' electric loads and the Company believes it would be prudent
to update the sales and load forecast prior to completing the 2009 IRP. Idaho Power
expects to complete the new sales and load forecast in August 2009.
II. BOARDMAN TO HEMINGWAY PROJECT
5. Idaho Power has discussed possible upgrades to the transmission paths
linking the Company's load center to the regional energy market in the Pacifc
Northwest in its IRP filings for at least 10 years. Idaho Power discussed potential Idaho
to Pacific Northwest transmission upgrades in general terms in both the 2000 and 2002
IRPsand identified the 225 MW McNary to Boise transmission project in its preferred
resource portolio in the 2006 Integrated Resource Plan. In the 2006 IRP, Idaho Power
identified the 225 MW McNary to Boise transmission project as part of the Company's
20-year resource plan with a projected completion date of 2012. The IPUC
acknowledged Idaho Power's 2006 Integrated Resource Plan in Order No. 30281 in
March 2007. The Oregon PUC acknowledged Idaho Power's 2006 Integrated Resource
Plan in Order No. 07-394.
6. Since acknowledgement of the 2006 IRP, Idaho Power has refined and
finalized plans for the Idaho-Pacific Northwest transmission upgrades. Idaho Power is
now proposing to construct and operate a new 300 mile long single circuit 500 kV
electric transmission line between a new switching yard at the Boardman power plant
near Boardman, Morrow County, Oregon, to the new Hemingway substation, to be
located in Owyhee County, Idaho. Collectively these facilties are identified as the
Boardman to Hemingway project or the B2H project.
PETITION - 3
7. The Commission is well aware of the fact that there has been substantial
opposition in both Idaho and Oregon to potential routes for the B2H project. To respond
to the concerns of the Company's customers and others regarding how the construction
of the line might impact their various communities, the Company has commenced a
comprehensive and inclusive public process to identify proposed and alternative routes
required for the B2H transmission line.
8. A Community Advisory Process ("CAP") has been established to develop
routes for the Boardman to Hemingway project. This process wil involve local citizens
in the determination of line routes to submit to the Bureau of Land Management ("BLM")
for its review consistent with the requirements of the National Environmental Policy Act
("NEPA") and to the Oregon Energy Facility Siting Council ("OEFSC") for its review
under Oregon state law. The CAP membership wil be determined through consultation
with project stakeholders. Three local area Project Advisory Teams ("PAT") wil be
formed with representation from: private propert owners, community groups, land use
organizations, environmental organizations, and local, state, and federal government
agencies. These teams wil begin in May with the goal of developing acceptable routes
by the end of 2009. Public open houses wil be held allowing the team members to
gather community concerns and provide updates on the process. The CAP members
wil develop routing criteria with Idaho Power. Then the members wil apply these
criteria to detailed maps and generate route options. Once the options are developed,
the members wil evaluate the route options against the agreed-upon criteria to
determine the routes to take forward in the process.
PETITION -4
9. Additionally, the CAP wil include a Project Coordinating Team to bring
together the criteria and routes of the three CAPs. They wil gather the CAP routes and
align them across the length of the project. Finally, these aligned routes wil be
submitted to the government siting proæsses described above.
10. As part of its review of the B2H siting process, the Company has decided
to delay development of the Sand Hollow substation to serve the western Treasure
Valley electrical load. This delay has resulted in the removal of the substation from the
Boardman to Hemingway Project. Idaho Power wil continue to monitor and forecast the
western Treasure Valley load and recommend the timing for construction of a future
substation in order to reliably meet customer electrical demands.
11. The Company recognizes that undertaking this extensive collaborative
approach wil cause a delay in the permitting process. Because the B2H line route
traverses land in the state of Oregon, the line is subject to the jurisdiction of the OEFSC.
The OEFSC allows an Oregon-regulated utility to submit an Oregon PUC determination
that a particular energy resource is part of the utility's acknowledged IRP as evidence
that the energy resource is needed. Therefore, the Oregon PUC acknowledgement of
an integrated resouræ plan, including a full analysis of the Boardman to Hemingway
project, is a critical path item in the process of obtaining permits for the B2H line. The
Company has suspended its pending Oregon Energy Facility Siting Council permitting
process to allow the project Community Advisory Process to complete its task.
12. The fact that the Oregon EFSC process wil be delayed provides some
additional time for the Company to examine the B2H project in its 2009 IRP as an
PETITION - 5
uncommitted resource subject to review for continued inclusion in the Company's near-
term resource plan.
13. While Idaho Power believes that the transmission project from the Pacific
Northwest to the Boise area load center has been a part of its acknowledged IRPs since
the Company's 2000 and 2002 IRPs, the Company now has firmed up many of the
details of the proposed Boardman to Hemingway project, including its updated size and
transfer capabilties. To fully reflect the best available data concerning the B2H project
in the resource planning process, the Company proposes to include the B2H project as
a resource alternative and obtain acknowledgement of an IRP that specifically
addresses the B2H project as currently configured.
II. INCLUSION OF THE NEW SALES AND LOAD FORECAST IN THE IRP
14. Idaho Power completes its annual, full-featured sales and load forecast in
mid-August each year. Using that sales and load forecast, the Company prepares its
biannual IRP or its biannual update to the previously acknowledged IRP. Numerous
analyses and studies used to prepare the IRP documents use the load forecast as the
starting point.
15. Unquestionably, the current recession has temporarily slowed economic
growth and correspondingly affected Idaho Power's customers and their electric loads.
Because Idaho Power wil have completed a new load forecast in August 2009, the
Company has concluded that the data from the August 2009 forecast should be
considered in the development of the 2009 IRP.
16. As previously noted, the starting point for an IRP is the long-term forecast.
Substituting the August 2009 load forecast for the August 2008 load forecast means
PETITION -6
that much of the work that has already been done to bring the 2009 IRP to its nearly-
completed status wil need to be reviewed and reanalyzed. The inclusion of the B2H
project as an uncommitted resource choice wil also require re-performance of number
of analyses. These are the principal reasons why Idaho Power needs more time to
complete the 2009 IRP. The Company recognizes that a delay in the acknowledgement
of its IRP wil have a ripple impact on other activities the Company and the Commission
undertakes; nevertheless, the Company believes that a 2009 IRP that takes a new look
at the B2H project and includes the Company's 2009 load forecast justifies taking the
additional time and expending the additional resources.
iv. DISCUSSION
17. The Commission should allow Idaho Power additional time to file its 2009
IRP because it wil better serve the underlying purpose of the IRP process and better
serve Idaho Power's customers. The IRP proæss allows the Commission to evaluate a
utilty's planned resources and ensure they are reasonable, cost effective, and
necessary to ensure that Company customers receive adequate serviæs at reasonable
rates. The process also encourages substantial public participation in the plan
preparation.
18. Here, good cause exists to allow the modification of the filing dates. The
requested delay will allow additional public participation in the preparation of the plan as
it relates to the B2H project. Additional time wil also allow the Company to incorporate
the most recent sales and load forecasts. Thus, allowing Idaho Power additional time to
prepare and file its 2009 IRP benefits the Commission and Idaho Power customers
because it wil allow the Commission to evaluate the I RP based upon the most up-to-
PETITION -7
date load projections and economic conditions. The additional time also benefits the
public by allowing more participation in the planning proæss-one of the goals of the
IRP process.
V. CONCLUSION
Based on the foregoing, Idaho Power respectully requests that the Commission
issue its Order modifying the filing date for the Company's 2009 Integrated Resource
Plan from the last business day of June 2009 to the last business day of December
2009.
Respectfully submitted this 24th day of April 2009.
~~
BARTON L. KLINE
Attorney for Idaho Power Company
PETITION - 8