20100415Comments.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 1895
RECE¡'-..)
20 i 0 APR I 5 M1 9= '2
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S 2009 INTEGRATED RESOURCE )PLAN (IRP) )
)
)
)
CASE NO. IPC-E-09-33
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission (Commission), by
and through its attorney of record, Scott Woodbury, Deputy Attorney General, and in response
to the Notice of Filng and Notice of Comment Deadline issued in Order No. 30986 on Januar
22,2010 in Case No. IPC-E-09-33, submits the following comments.
BACKGROUND
On December 28, 2009, Idaho Power Company (Idaho Power; Company) fied its 2009
electric Integrated Resource Plan (lRP) with the Commission. As required by Commission
Order No. 22299 (Case No. U-1500-165), Idaho Power's filing is a biennial planing document
that sets forth how the Company intends to serve the electric requirements of its customers. i
i The nonnal fiing date for Idaho Power's biennial IRP would have been June 2008. However, in Order No. 3028 i,
the Commission expressed a desire to receive the IRPs from each of its three jurisdictional electric utilties within a
narrower time frame. In response to that, Idaho Power proposed that it fie its next "full" IRP in June 2009. The
Commission accepted that proposed schedule on May 23, 2007, in Order No. 303 i 7. However, the desire to provide
additional infonnation on the proposed Boardman to Hemingway 500 kV transmission line (B2H) caused Idaho
STAFF COMMENTS 1 APRIL 15,2010
The complete 2009 IRP consists of four separate documents: (1) the 2009 Integrated
Resource Plan; (2) Appendix A - Sales and Load Forecast; (3) Appendix B - Demand-Side
Management 2008 Annual Report; and (4) Appendix C - Technical Appendix.
ST AFF REVIEW
Planning Overview
Idaho Power's 2009 IRP addresses available supply-side and demand-side resource
options, planning period, load forecast, potential resource portfolios, a risk analysis, and near-
term and long-term action plans. Idaho Power assumes that during two 1 O-year planning
periods, 2010-2019 and 2020-2029, it wil continue to operate as a vertically-integrated electric
utility while acquiring resources sufficient to serve all of its retail customers in its Idaho and
Oregon service territories. The 2009 IRP is the first fiing that bifurcates the planning period
into two distinct segments. The Company contends that this approach "prevents near-term
resource decisions from being influenced by the availability of resources that are dependent on
technological advancements in the second 10 years." 2009 IRP' p. 3.
Four resource portfolios were modeled for the first ten-year period. Included in this
planning period are certain resources the Company considers as "committed.,,2 2009 also marks
the first time in a number of years that an upgrade of the Shoshone Falls hydroelectric facility is
not identified as a committed resource, reflecting the uncertainty surrounding provisions in the
FERC relicensing amendment. Two of the portfolios reviewed include the Boardman to
Hemingway (B2H) transmission project, currently slated for completion in 2015. Completion of
B2H would provide Idaho Power with nearly 850 MW of additional import capacity from the
Pacific Northwest. B2H is not considered a committed resource as permitting delays,
specifically regarding siting through Eastern Oregon, have pushed back the completion date from
its original online target. Inclusion of the B2H transmission line in the Company's portfolios
permits continued assessment of B2H as a cost-effective endeavor in the near-term.
Five resource portfolios were analyzed for the 2020-2029 time period. Each portfolio
was designed to meet a potential federal renewable electricity standard (RES) as proposed in the
Power to request pennission to fie the 2009 IRP by year end 2009. The Commission granted Idaho Power's request
for delay to year end on May 19,2009, in Order No. 30815.
2 Each portfolio contained 150 MW of wind resources, 2-20 MW blocks of geothennal resources, and 300 MW
associated with the Langley Gulch natural gas facility. The inclusion of these is based on pending contracts and the
Commission's granting of a CPCN for the Langley Gulch project.
STAFF COMMENTS 2 APRIL 15,2010
American Clean Energy and Security Act (ACES; Waxman-Markey bil), which was approved
by the U.S. House of Representatives in June 2009, and is currently in consideration in the
Senate. Several of the portfolios for this planing period evaluated advanced technologies, such
as solar power tower, nuclear and integrated gasification combined-cycle (lGCC) facilities, as
well as traditional natural gas and wind generation. The top performing portfolios from each
time period based on cost and risk metrics provide the foundation for the Company's Action
Plan.
Idaho Power identifies four primar goals in its planing process: (1) to identify
sufficient resources to reliably serve the demand for energy within Idaho Power's service area
throughout the 20-year planing period; (2) ensure that the portfolio of selected resources
reasonably balances cost, risk, and environmental concerns; (3) give equal and balanced
treatment to both supply-side resources and demand-side measures; and (4) involve the public in
the planning process in a meaningful way. Staff believes that the 2009 IRP suffciently
accomplishes these four goals, as well as the guidelines set forth by the Commission.
Load Forecast
The 2009 IRP was prepared during a time filled with great uncertainty. Beyond the
issues surrounding the B2H transmission project, the local and national economies have seen
dramatic downward swings during the last two years. In Order No. 30815, the Commission
approved an extension to the Company's IRP fiing date, citing the benefits of incorporating the
most current sales and load forecasts into the final document. Instead of relying on a forecast
created in the summer of 2008, the final IRP was based on a more recent mid-2009 forecast.
While many believe the current financial crisis began in late 2007, much of the impact
was not felt until September 2008. There is little consensus on the exact cause or causes of the
recession, but the effects to Idaho Power are evident. Since the filing of the 2006 IRP' the State
of Idaho has seen a near tripling of its unemployment rate to over 9% in late 2009, and stagnant
to negative growth in labor force participation.3 For the years 2008 and 2009, real personal
income dropped for Idahoans. Also, residential customer growth, as measured by new housing
starts, is at a fraction of 2005 levels, while regional housing vacancies have climbed
3 Due to the way unemployment statistics are compiled, individuals who have given up searching for a job, are
'underemployed', or whose job search has extended beyond the four week window prior to the offcial employment
survey distribution, are not considered 'unemployed'. This is considered 'hidden unemployment', and leads to the
unemployment rate understating the true level of joblessness in Idaho.
STAFF COMMENTS 3 APRIL 15,2010
precipitously in the same timeframe. As a result, Idaho Power witnessed an overall decrease in
sales in 2009, a phenomenon that has not occurred in some time. Though the Company foresees
a rebound in 2012, Staff believes each of these factors contributed to a significant decrease in
forecasted sales for Idaho Power, especially in the near-term planing horizon.
In fact, not only did Idaho Power's 2009 load forecast show lower sales relative to the
2008 forecast, the 2009 IRP continues a trend of relatively lower sales forecasts compared to
previous IRPs since the 2004 filing. The 2009 IRP projects a growth in annual average energy of
0.6% throughout the planning period, compared to an annual growth rate of 1.5% used in the
2006IRP. This difference results in a decrease of over 400 average megawatts (aMW) between
the two IRPs for the year 2025, the last comparable year. The peak-hour forecast in the 2009
IRP is nearly 30% lower than that of the 2006 IRP for comparable years. As a result, Idaho
Power's average load is expected to increase by 13 aMW annually and summertime peak-hour
loads are expected to increase by 53 MW (or at a 1.5% annual growth rate) anually through
2020-2029. Staff notes that for the first time, Idaho Power foresees consumers responding to
expected price increases by reducing average usage over the planing horizon. Not only is it
predicted that real electricity rates wil rise at an average rate of 3.3 % a year, a lower relative
increase in natural gas prices may lead to advantageous fuel-switching opportunities to the extent
customers have the ability. Offsetting a portion of the decline is the addition of large industrial
loads, notably the Hoku Materials facility in Pocatello. Idaho Power estimates Hoku wil require
74 aMW of energy each year and add 82 MW to peak demand by 2012.
Idaho Power's load forecasts also include savings from existing energy effciency
programs. Given the recent increased commitment to energy effciency by the Company and
favorable cost-benefit ratios due to rising costs of alternative resources, Staff believes the
decrement to load attributed to these programs may factor into the reduced forecasted growth
rates, especially for the industrial and irrigation classes.
Idaho Power continues to use 70th percentile water conditions and 70th percentile average
load for energy planing. For peak-hour capacity planing, Idaho Power uses 90th percentile
water conditions and 95th percentile peak-hour load. Under these planning criteria, and
accounting for additional demand-side management (DSM) programs, Idaho Power expects to
see substantial energy deficits in 2023 and beyond once committed resources are included in the
analysis. Substantial peak-hour deficits are expected to occur in 2017 and grow significantly to
over 1,800 MW in 2029 once committed resources are included in the analysis. Staff continues
STAFF COMMENTS 4 APRIL 15,2010
to support the conservative planning criteria Idaho Power has utilzed in its previous three IRPs,
as it reflects a concerted effort to balance reasonable expectations of the future while planing
for less than ideal load and generation scenarios.
The Company forecasts a significant increase in industrial load for 2011 and 2012,
presumably reflecting the additional needs of the Hoku facility and an expected rebound in the
regional economy. Beyond that, industrial load is projected to grow at rates well below 1 % a
year. The addition of large customers is diffcult to predict, and unforeseen industrial relocation
into Idaho Power's service territory could burden a system that is already constrained. Another
scenario would be that the Company simply could not immediately serve the new load, causing
lost opportunities to both Idaho Power and the Idaho economy in general. Staff does not propose
a specific methodology for capturing the potential uneven additions of large load, but
recommends the Company continue to investigate the impacts this may have in future IRPs.
Planning Environment
Aside from the current economic conditions, Idaho Power has taken into consideration
the continuing realization that resource options wil be constrained by imminent environmental
regulations and climate change policies. Notably, Idaho Power initially constrained all potential
portfolios to meet greenhouse gas (GHG) emission reductions and federal renewable electricity
standards (RES) outlined in the Waxman-Markey bil. The Waxman-Markey bil proposes a
cap-and-trade system for reducing GHG emissions below current levels, similar to the SOi
trading system that has been in place for a number of years. The ACES Act also sets an RES
that requires utilities to generate up to 20% of electricity supplied to customers from renewable
resources, and allows for up to 25% of the RES requirement to be met by energy effciency
savings.
This is not the first IRP to address federal climate change regulation or RES
requirements. Previously, Idaho Power has included a carbon adder, or carbon tax, as a cost of
production in an effort to quantify the impact of regulation on fossil-fuel based generation.
While the IRP does provide an analysis of a carbon tax, the portfolios were designed with a cap-
and-trade system to curb GHG emissions in mind. Staff believes that this is an appropriate
methodological change in the current political environment, and supports the Company's
adjustment in its portfolio analysis. Staff does not agree with the Company's planing
assumption that all generation from its coal-fired facilities wil cease by the end of the planing
STAFF COMMENTS 5 APRIL 15,2010
period. Realistically, generation from coal-fired resources may be substantially curbed through
2050, but given the country's dependence on coal, it is hard to fathom that these plants would be
completely removed by 2029. As in the 1990s, Staff assumes that the market for pollution
control devices and advances in carbon capture and sequestration technology wil allow
continued fossil-fuel use, albeit at reduced levels. Should that be the case, the long-term need for
new resources may not be as great as that stated by the Company. Despite the differing opinions
regarding the future of coal resources, Staff does not believe the current IRP needs to be
modified on this issue. The impact manifests toward the end of the Company's planing
horizon, and there wil be a number of IRPs produced when federal regulation is more certain.
Beyond the potential for legislation at the Federal level, Staff acknowledges Idaho Power
must also plan around regional issues. The state of Idaho has no laws governing greenhouse gas
emissions or renewable portfolio standards. The 2007 Idaho Energy Plan, adopted by the Idaho
Legislature, provided recommendations for maintaining access to reliable, low-cost energy in a
sustainable, economically sound maner. Notable in the Energy Plan was the emphasis on cost-
effective energy efficiency and renewable resources to meet the needs of Idaho consumers.
While none of the recommendations bind Idaho Power in resource decisions, Staff believes the
intent of the Legislature has been echoed by the Company's shareholders. In May of 2009, a
majority of Idaho Power shareholders voted to ask the Company to adopt GHG-curbing policies.
Idaho Power has since responded by approving guidelines to reduce GHG emissions by 10-15%
by 2013.
The State of Oregon accounts for nearly 5% of the Company's system load. Oregon has
been quite proactive in regard to climate change legislation. In 2007, Oregon Governor Ted
Kulongoski signed into law House Bil 3543, a bil that directs the state to, among other things,
reduce GHG emissions by 10% by 2020. Oregon Senate Bil 838 was signed into law in 2007,
establishing renewable portfolio standards for electric producers. Idaho Power is also a
paricipant in Oregon PUC Docket UM 1452, a state initiative to investigate a solar photovoltaic
feed-in tariff pilot program initiative. This program may require Idaho Power to procure
between 100 kW and 300 kW of solar capacity from qualifying retail customers. Given the
small fraction of energy and capacity mandated, Staff does not believe the IRP planing
environment is hampered or constrained by the Oregon requirements.
One recent development that wil affect future resource planing concerns Idaho Power's
share of the Boardman coal-fired facility. At the time the 2009 IRP was being prepared Portland
STAFF COMMENTS 6 APRIL 15,2010
General Electric Co. (PGE), the majority owner of the Boardman plant, was planing to install
emission control equipment to comply with Oregon's 2008 Regional Haze Plan. Doing so would
allow the plant to continue operation through 2040. Since that time, PGE has changed its plans
and has submitted a proposal to the Oregon Deparment of Environmental Quality to cease
operations of the plant by 2020. Should the plan be approved, Idaho Power would lose its 60
MW share of baseload generating capacity from the Boardman plant. Staff believes there is
ample time to address this unexpected loss in generation in the Company's next IRP'
Energy Effciency and Demand-Side Management
In determining the load-resource balance, Idaho Power conducted an analysis of potential
cost-effective energy efficiency and demand-side management (DSM) programs to be
implemented during the planing horizon. While existing DSM savings are captured in the load
forecasts, the Company utilzed an updated DSM potential study performed by Nextant, Inc. to
determine the potential savings associated with new and expanded offerings. Idaho Power also
contracted with Quantec, LLC, to conduct a study of potential savings associated with
implementing more stringent appliance effciency standards in Idaho.
The Nextant study was originally prepared in 2007 and was updated in 2009 to faciltate
utilzing the results in the IRP' The study demonstrated that there are significant opportunities
for energy and peak savings in virtually all customer segments in Idaho Power's service territory.
Surprisingly, the study did not recommend any new programs for the irrigation class. The
Company contends that this is explained by the success of its Irrigation Energy Efficiency
Rewards and Peak Rewards programs. The Company has included in resource planing the
recently expanded Irrigation Peak Rewards Program. This has the potential to provide as much
as 260 MW of peak reduction by 2012.
The Quantec study demonstrated that Idaho Power can cost effectively acquire 127 aMW
of energy efficiency savings by 2029 through the adoption of several building code and
appliance standards. For this to manifest, it is imperative that the Company work closely with a
number of agencies at the state level to gain the necessary support. The Company's efforts in
market transformation through its support of the Northwest Energy Efficiency Allance (NEEA)
have been well documented of late, and Staff continues to be encouraged by the collaborative
nature Idaho Power has demonstrated recently regarding its DSM and energy efficiency
programs.
STAFF COMMENTS 7 APRIL 15,2010
Beyond the energy efficiency savings, Idaho Power has included a considerable
expansion of its three demand response programs (the A/C Cool Credit, Irrigation Peak Rewards,
and FlexPeak Management programs) in the 2009 IRP. In total, the three programs are expected
to provide 367 MW of peak reduction by 2012. Coupled with the savings associated with the
energy efficiency programs, Idaho Power projects it can reduce peak generation needs by over
400 MW by the end of the planing period. Staff believes that if the cost of new generation
increases at the rate witnessed in recent years, expansion of DSM programs wil continue to be a
cost effective means to meet the future demands of Idaho Power customers.
Portfolio Design and Selection
Idaho Power examined nine resource portfolios and numerous permutations as par of
preparing the 2009 IRP. Each portfolio was designed to not only meet peak and energy load
requirements, but also to satisfy potential RES requirements as outlined in the Waxman-Markey
bilL. In order to capture the proposed cap-and-trade system, Idaho Power reduced output from its
coal-fired facilities based on the number of allowances it expects to receive under the bilL.
Portfolio selection, through necessity of bifurcating the planning period, was a multi-step
process. The first-period portfolios were evaluated on total cost as well as operational and
quantitative risk characteristics, as has been done in the past. The resulting preferred portfolio in
the first 10-year planning period became the basis for designing portfolios for the second 10-year
period. As Staff noted earlier, Idaho Power included a number of committed resources in each of
the first-period portfolios. The initial portfolios for the first 1 O-year planing horizon are
summarized below:
2015
1.1 Sor 1.2 Gas Peater 10S GIs Peaker & B2H'1-4B2H
Reource MW Resouce MW Resoure M Resoue II
Wind"150 Wind"150 Wind"150 Wind"150
eeCT (langley Gulch)" 300 CCCT (langley Gulchr 300 CCCT (Lanley Gulch)" 30 CCCT (langleyGIlchT30
Geal"20 Geermal"20 Gethrmal-20 Geermal 20
SI hone Falls 49 Shohone Falls 49 Shhone Falls 49 Shoshone Fals 49
seCT (Lare Ae)20 SeCT (Frame Peaker)170 82H 250 B2H 250
Geothermal.20 Geemal 20 Gethermal 20 Geeral.20
Solar PT wISt 100 SCCT (Frame Peaker)170 seCT (large Aero)100 B2H 175
Solar PT wIS 100 SeCT (Large Aero)100
ardma 10 Hemin
Year
2012
2016
2017
2019i B2H- gwy
.Commllted Resurce
STAFF COMMENTS 8 APRIL 15,2010
Staff believes that while the number of initial portfolios modeled is somewhat scant in
comparison to previous IRPs, this is adequate given the level of committed resources in the near-
term. Staff notes that the B2H resource can be considered a proxy for market purchases (as well
as the Company's investment participation), namely from the Pacific Northwest. Idaho Power
continues to use the AURORA model to forecast market prices, along with portfolio cost
estimates. Staff is concerned that the prices used for market purchases may be understated in
light of potential carbon legislation. Purchases from the Northwest traditionally have been tied
to natural gas generation, the resource that tends to be on the margin during peak periods. These
facilities would not be immune to carbon legislation (both federally and regionally), and the
market price would undoubtedly reflect the additional cost associated with fossil fuel-based
generation. If the Company's price assumptions do not reflect this, Staff believes cost of market
purchases, and transmission-related investment in general, may be understated in the IRP.
Following a risk analysis, Idaho Power selected Portfolio 1-4 (Boardman to Hemingway)
as the preferred portfolio for the first 10-year planning period. Based on that decision, Idaho
Power created a second set of portfolios for the 2020-2029 timeframe. The portfolios are shown
below:
v_
2020
201
20
203
2024
2025
2026
2021
i..Hu..r..2.2 Gi Wft 24 II 2.. Wllo ..ii 201 tJll CUllnlRNMWRia_.MW Rß.lI .fl MW RiOl1"lI
Sor PT wIS 100 SCCT (Lrg,t)100
Wïnd 100 Wlrn 100 WI 100
SOPTwISt 100 Ganll Wet 20 SO pr wlSI tOO 'Mild 100 SCCT(IeMt)100
Nud 270GeI52 IGCCw/Sq.60 SCCT (Larg Aim)20
Soar PT wlSl 100 Glnay w.st 200 GiyWeI lOG
'Mnd 100 SCCT(l...I')20G SCCT (I.iiig"'ro)100
Gll!al 52 Ganay w.st 40 Sor PT wISt 100 Wlnd 400 WI 20
sccr (Larg "'1')100
NucÑl 40 Ganay Wet 600 SCCT (Lrge ,t)40 sccr (La Aero)40
Gateway we$!250 SO PT wIS 100 sccr (lai Mro)SO
..,
2028
2029
Staff believes that the Company's decision to separate the planing periods has facilitated
the exploration of technologies previously considered immature or cost-prohibitive, such as
concentrated solar generation and nuclear. It remains to be seen whether federal legislation wil
change the cost dynamics of large scale green generation, either through additional production
and/or investment tax credits or accelerating the reduction in costs of production, and Staff is
STAFF COMMENTS 9 APRIL 15,2010
uncertain to what extent the Company's analysis took this into account. Also of note, all but
Portfolio 2-5 assumed generation from the Company's coal plants would be curtailed to zero by
the end of the planning period. Idaho Power states that this is the primary rationale for adding
additional resources in the second planing horizon. Again, while Staff considers eliminating
current coal resources from the Company portfolio as planing to a worst case scenario, the rise
of carbon legislation to the exclusion of coal generation could certainly make currently cost
prohibitive resources more attractive.
Preferred Portfolio and Action Plan
After rigorous scrutiny, the Company opted for Portfolio 1-4 (Boardman to Hemingway)
for the first 10-year planning period and Portfolio 2-4 (Wind and Peakers) for the last 10 years of
the planing horizon as the preferred strategies. Period One includes completion of the Langley
Gulch CCCT (300 MW) in 2012, the Shoshone Falls Upgrade Project (49 MW) in 2015, and
assumes completion of the Boardman to Hemingway (B2H) Transmission Project in 2015. The
portfolio selected for the second half of the plan represents a strategy of adding wind resources
suffcient to provide energy and RECs along with simple-cycle natural gas plants to provide
peaking capacity and operating reserves necessary to integrate wind generation. The additional
wind (100 MW in 2022 and 400 MW in 2027) assumes completion of the Gateway West
Transmission Project (100 MW) by 2022. The selected portfolio adds supply-side resources
capable of providing 529 aMW of energy, 1,525 MW of capacity to peak-hour loads, and 425
MW of additional transmission capacity from the B2H line to the Pacific Northwest. The
selected portfolio also includes new and expanded energy efficiency and demand-side
management programs estimated to reduce average loads by 127 aMW and peak-hour loads by
438 MW by 2029.
Idaho Power further analyzed the impact of limited third-pary interest in the B2H
transmission line and limited coal curtailment through the use of alternative portfolios. Should
the Company be unable to partner on the B2H line (or its share of the investment exceeds the
next best alternative), its most likely preferred strategy would be Portfolio 1-2 (Gas Peakers),
which involves an additional 340 MW of simple-cycle combustion turbine (SCCT) peakers in
addition to the Langley Gulch plant. Staff is aware that Idaho Power and PacifiCorp have signed
a Memorandum of Understanding (MOU) regarding the potential opportunities to parner on
transmission projects that directly affect the B2H line. According to Idaho Power, the MOU
STAFF COMMENTS 10 APRIL 15,2010
enables discussions between the two utilities to better utilize the existing transmission system as
well as potential parnership on new facilities. Staff finds this encouraging as Idaho Power's
involvement on the much talked-about Gateway West project may be contingent on completion
of the B2H line. Also, the Company has recently made significant progress toward clearing the
siting hurdles it has faced in Eastern Oregon.4
The scenario of limited curtailment in lieu of total curtailment was assessed using
Portfolio 2-5 (Limited Curtailment). In this scenario, carbon emissions are reduced through
2020, and then left at that level through the remainder of the planning period. As the Waxan-
Markey bil currently stands, carbon emissions would be reduced to 17% of 2005 levels by 2020,
42% by 2030, and 83% by 2050. Should the alternative scenario come to fruition, the Company
would be investing in 1,400 MW less capital and transmission projects as compared to its
preferred portfolio. The 2050 timeline for further reductions affords the Company the ability to
monitor the maturation of new technology, and plan accordingly in the out years to responsibly
reduce its carbon footprint.
In the near-term, Idaho Power has effectively pursued the actions supported by its
preferred portfolio. The Company issued a Request of Proposal (RFP) for 150 MW of wind
generation in May of2009, and is finalizing its agreements with the selected developer. The
Commission granted the Company a CPCN for Langley Gulch Power Plant in September of
2009. In accordance with the Action Plans in its 2004 and 2006 IRPs, Idaho Power issued two
geothermal RFPs in 2006 and 2008. A contract to purchase the output from the 13 MW first
phase of the Raft River project has been signed and the project has been generating since mid-
2008. An agreement to purchase 22 MW of generation from the Neal Hot Springs Project in
Oregon has been submitted for Commission approval. Given the speculative nature of finding
feasible new sites for geothermal production, the Company believes it is best to negotiate
contracts once sites are proven rather than pursue new projects through the traditional RFP
process. The Company is currently waiting on FERC to approve an amended application that
may dictate whether the Shoshone Falls Upgrade is feasible.
Idaho Power contends that maintaining a diverse resource portfolio is the best way to
mitigate risk given the amount of uncertainty in the planing process. Staff believes that the
2009 IRP contains suffcient quantitative and qualitative analyses of the potential risk associated
4 According to the Company, as of early April 20 i 0, it wil soon submit its proposed route for B2H to the Oregon
Bureau of Land Management and Oregon Energy Facilty Siting CounciL.
STAFF COMMENTS 11 APRIL 15,2010
with carbon regulation, developing technologies, resource siting, and relying on market
purchases. Although the IRP is not intended to be a binding document for the Company's
actions, Staff notes that the 2009 IRP is unique relative to previous IRPs given the level of
resources the Company is actively pursuing in the near term. Based on it analysis, Staff believes
that Idaho Power's 2009 IRP satisfies the expectations and requirements of the Commission
Order Nos. 25260 and 22299.
STAFF RECOMMENDATION
Upon review of Idaho Power Company's 2009 IRP, Staff believes the Company has
performed extensive analyses, given equivalent consideration of supply- and demand-side
resources, and provided acceptable opportunities for public input, resulting in an integrated
resource plan representative of the Commission's directives. Staff, therefore, recommends that
the Commission acknowledge the Company's 2009 IRP'
Respectfully submitted this 15"' day of April 2010.
~APi4ii
Scott oodbury
Deputy Attorney General
Technical Staff: Rick Sterling
Bryan Lanspery
i: umisc:comments/ipce09 .33swrpsbl comments
STAFF COMMENTS 12 APRIL 15,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF APRIL 2010,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-09-33, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: bkline(Iidahopower.com
Inordstrom(Iidahopower .com
MICHAEL J YOUNGBLOOD
PRICING & REGULATORY SERVICES
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: myoungblood(Iidahopower.com
il~_
SECRETARY.
CERTIFICATE OF SERVICE