20100414RNP Comments.pdf

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April 14, 2010
2010 APR Ill Pr14:36
Commission Secretary i P /\ i ..
Idaho Public Utilities Commia§IRiT'li~s'~
PO Box 83720
Boise, ID 83720-0074
Renabl Northwet Pr
Re: Renewable Northwest Project Comments on Idaho Power Company's
2009 Integrated Resource Plan, Case No. IPC-E-09-33
Honorable Commissioners:
Renewable Northwest Project (RNP) appreciates the opportnity to
comment on Idaho Power Company's (Idaho Power) 2009 Integrated Resource
Plan (IRP). RNP is a non-profit advocacy organization promoting solar, wind
and geothermal resources in Idaho, Oregon, Washington and Montana. RNP's
members are a unique combination of environmental and consumer
organizations as well as a varety of businesses engaged in the development of
renewable energy projects.
RNP participated extensively in the IRP Advisory Council (IRP AC)
meetings and submitted comments to provide feedback to Idaho Power when
the IRP was under development. We found the dialogue between Idaho Power,
the IRP AC and interested stakeholders to be an essential tool in shaping key
decisions in the IRP, especially regarding the company's plans to reduce
greenhouse gas emissions over time.
RNP applauds Idaho Power for developing a resource portfolio that
allows for considerable curtailment of the company's coal-fired generation
from approximately 900 average megawatts (MWa) in 2012 to 0 MWa in
2029. Idaho Power's IRP strategically accounts for the cost, risk and
environmental concerns associated with future limits on greenhouse gas
emissions.
Our applause is tempered, however, by the company leaving open the
possibilty of choosing the 2-5 Limited Curailment portfolio instead ofthe 2-4
Wind and Peakers preferred portfolio. Idaho Power has stated in presentations
to the IRP AC and Commission that if the cost of carbon regulation is less than
$30 per ton, it may be more economical for Idaho Power to continue to operate
its coal resources and opt for the 2-5 Limited Curailment portfolio. While we
recognize that this alternative portfolio is in compliance with the Oregon
Public Utilty Commission IRP Guideline 8 (Order No. 08-339) requirement of
a trigger point analysis!, Guideline 8 also requires the utility to constrct the
best cost/risk portfolio that achieves consistency with Oregon energy policies
(including state goals for reducing greenhouse gas emissions). We believe the
2-4 Wind and Peakers preferred portfolio is the best cost/risk portfolio that
achieves this consistency.
! The utility should identify at least one C02 compliance "tuing point"
scenario, which, if anticipated now, would lead to, or "trigger" the selection of
a portfolio of resources that is substantially different from the preferred
portfolio.
Idaho Power's IRP should also be consistent with Portland General Electric's plans to
close the Boardman coal-fired power plant in 2020. Idaho Power has 10% ownership in the
plant. The 2-4 Wind and Peakers preferred portfolio offers Idaho Power the needed resource
flexibilty to manage the plant closure in 2020. For all of these reasons, we urge the Commission
to acknowledge the IRP's 2-4 Wind and Peakers preferred portfolio for 2020-2029.
We also urge the Commission to acknowledge the l-3 Gas Peaker & B2H preferred
portfolio for 2010-2019. We believe the company's commitment to 150 MW of wind energy and
40 MW of geothermal energy coupled with a responsibly-sited Boardman to Hemingway
transmission line wil foster the growth of new renewable energy resources in the Northwest
serving Idao Power customers.
Looking forward to the 2011 IRP we hope that Idaho Power wil seek to acquire
additional new renewable energy resources in the near-term. Although we are supportive of the
1-3 and 2-4 preferred portfolios, we are concerned that the portfolios rely too heavily on natual
gas-fired resources. We also urge Idaho Power to seek more resource diversity from solar,
geothermal, biomass, low-impact hydro and combined heat and power. Our region's renewable
energy resources are abundant, increasingly cost-competitive, and lack the fuel price volatilty
associated with natual gas.
Finally, we would like to address three public policy issues raised in the IRP. Regarding
Renewable Energy Credits (RECs), RNP disagrees with Idaho Power's recommendation to sell
its RECs from renewable energy projects until the company is required to use the RECs to
comply with a federal Renewable Energy Standard (RES). First, if Idaho Power sells the RECs,
the company wil lose the right to claim any environmental attributes (including emissions
reduction) associated with the power to their customers or shareholders. Second, Idaho Power
wil not be able to use the RECs for compliance with Oregon's 25% by 2025 Renewable
Portfolio Stadard, which allows for unlimited REC banking beginning January 1,2007. Finally,
Idaho Power should be retiring RECs in preparation for compliance with a futue federal RES,
which the company believes wil be passed by Congress in the near futue.
Regarding emissions offsets, RNP believes offsets that are real, verifiable and additional
are certinly worthy of exploration. However, we are concerned that Idaho Power's investigation
into purchasing emission offsets may divert the company from achieving emissions reductions
directly by reducing the output from emitting resources and taking advantage of energy
conservation and clean, renewable energy. To ensure offset purchases are a prudent investment,
the Commission should require Idaho Power to compare the risk, cost and environmental
benefits of strategies that directly reduce emissions from its resource mix to the purchase of
emissions offsets or offset options.
Regarding a solar pilot project, RNP strongly supports the development of a solar pilot
project in Idaho Power's service terrtory. We were pleased to see Idaho Power commission a
thorough solar feasibilty study, especially given that solar resources coincide very well with the
company's peak demand needs.2 We urge the Commission to initiate a stakeholder workshop
with Idaho Power to explore options for a solar pilot project. One option may be a customer-
2 It is importnt to note that the Black & Veatch study's photovoltaic (PV) costs are out of date;
PV module prices declined significantly across the U.S. in late 2009 and early 2010. A freely
available data source referring specifically to module prices is the Solarbuzz index. It is
important to note that this index emphasizes the cost of individually purchased, full retail price
modules, and equally weights all advertised module prices. The effect of these two
methodological choices is to produce prices that are tyically much higher than what a developer
purchasing wholesale would pay for modules, but the relative trending of the data is relevant and
accurately reflects market experience. The Solarbuzz data suggests a price reduction in average
modules of approximately 14 cents per Watt from the 4th quarter of2009 to the present day.
http://www.solarbuzz.com/Moduleprices.htm
subsidized solar project near a substation. This option is probably best pursued as a choice for
customers paricipating in Idaho Power's voluntar green power purchasing program. Another
option the worty of exploration is a ratepayer-fuded production-based incentive for distrbuted
solar PV and solar thermal resources. If the company is interested in pursuing utilty-scale solar
resources, Idaho Power should consider issuing a Request for Proposals for solar resources.
Than you again for the opportity to comment on Idaho Power's 2009 IRP. We look
forward to working with the company and the IRPAC to help shape the development of the 2011
IRP.
Sincerely,
~rr~'
Suzane Leta Liou
Senior Policy Advocate