20080225Snake River Alliance Comments.pdf

Feb. 25,2008 ;,1~ \
;t..¡
t:. f
Ken Miler
SNAKE RIVER ALLIANCE
Box 1731
Boise, ID 83701
Ph: [phone]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
FEB 25 Pr1~: 56
iDp¡f--tO PUBLIC
UnUTIES COMMISSIO;',
IN THE MATTER OF THE APPROPRIATE )
DISPOSITION OF PROCEEDS FOR THE )
SALE OF IDAHO POWER COMPANY'S )
2007 S02 ALLOWANCE SALES )
COMMENTS FROM THE SNAKE RIVER ALLIANCE
CASE NO. IPC-E-07-18
SNAKE RIVER ALLIANCE
COMES NOW, Snake River Allance ("Allance") in response to the Notice of Modified
Procedure issued in the above-referenced docket by the Idaho Public Utilties
Commission, Order No. 30495, and the IPUC's Jan. 15,2008, workshop regarding the
allocation of proceeds from S02 allowance sales.
The Snake River Allance is an Idaho-based non-profit organization, established in 1979
to address Idahoans' concerns about nuclear safety issues. The Allance's mailing address
is Box 1731, Boise, ID 83701.
In early 2007, the Allance expanded the scope of its mission by launching its Clean
Energy Program. The Allance's energy initiative includes advocacy for renewable
energy resources in Idaho; as well as expanded conservation and demand-side
management programs offered by Idaho utilties and the Bonnevile Power
Adminstration; and local, state, regional, and national policies and initiatives that
promote sustainable energy policies. The Allance is pursuing these progrs on behalf
of its members, many of whom are customers of Idaho Power who are interested in
promoting renewable energy and energy conservation and efficiency initiatives.
The Allance congratulates Idaho Power Co. for its creative approach to the allocation of
the estimated $10.1 milion at issue in this proceeding. While the ratepayer and
shareholder benefi~ from a 90 percent/l 0 percent disbursement though the Power Cost
Adjustment (PCA) is laudable, the Allance believes there are opportunities to better use
the fuds at issue, and salutes Idaho Power for identifying alternatives that might deliver
benefits beyond the time period covered by the PCA mechanism.
As referenced by Allance representative Ken Miler during the Januar workshop in this
case, the Allance agrees with the Idaho Energy Education Project and Mr. Bil Chisholm
that a portion of the S02 allowance sale proceeds should be allocated to energy
effciency and renewable energy education projects. The $500,000 figure referenced by
JEEP is both appropriate and would ensure that the proceeds have value far beyond the
one year envisioned by distributing the fuds through the PCA.
As for the balance of the proceeds, the Alliance supports investing the bulk of the fuds
in a blend of both renewable energy projects and conservation and effciency programs.
By doing so, we believe the fuds can be leveraged to deliver far more benefits - and
over a longer period of time - than if the fuds were used for one-time benefits to
ratepayers.
With regard to the Company's proposed investment to acquire rights to a wind project:
While we do not oppose such an investment and in fact salute the Company's
consideration of an investment in a renewable energy project, we would encourage the
Commission to ensure such an investment bears fruit within a reasonable time frame by
directing the Company to implement a time line to bring such a resource online. We
understand and appreciate the Company's desire to acquire its own renewable energy
resources; but if the Commission adopts this strategy we would hope it does so with a
mechanism that guarantees a timely deployment of the investment.
We also believe wind is not the only resource that can be acquired. The Company has
identified geothermal as a potentially valuable renewable resource and curently has an
RFP to acquire up to 100MW of additional geothermal generation. We believe an
investment in geothermal power is both sound from a ratepayer benefit, but also a
forward-looking resource acquisition in our evolving carbon-constrained energy world.
The Allance does not oppose the Company's suggestion that some of the funds might be
used to acquire renewable energy attributes such as green tags. However, if such an
investment is made, it must be for renewable energy certificates that represent new
renewable energy projects, as opposed to those curently in the company's PURPA
queue. In other words, we want to ensure that such an investment is made to develop new
renewable resources rather than those the company has committed to.
Finally, we encourage the Commission to consider an enhancement of the IEEP proposaland direct a greater amount be invested in enhanced energy efficiency and conservation
programs beyond those the Company is already committed to through its existing demand
side management (DSM) programs, which are fuded by the existing tariff rider. Whilewe could not support an investment in conservation programs that merely supplants
existing conservation and effciency spending, we do believe an investment in new
programs is both appropriate and would help extend the value of the fuds.
Similarly, we would support investing the proceeds in this case in "smar grid" or other
non-wires initiatives that, like conservation programs, will reduce the need for additional
fossil-fueled generation resources.
In conclusion, the Allance believes that since the proceeds at issue here are the result of
the Company's laudable efforts to reduce the environmental impacts associated with its
existing thermal power plants, the fuds should be used in ways that improve the
Company's clean-energy portfolio -: whether by investing in renewable energy,
conservation and efficiency programs, or a combination of the two. In addition, we
believe deployment of the fuds as outlined above comports with the 2007 Idaho Energy
Plan, which states unambiguously that Idaho and its utilties should emphasize energy
conservation and efficiency programs as their highest priority, followed by acquisition of
additional renewable energy resources in our utilties' portfolios.
On behalf of the Allance's Board of Directors and our members and supporters across
the state, the Allance appreciates the Commission's attention to this important matter
and its wilingness to consider both the proposals set forward by Idaho Power, but also
the additional innovative ideas advanced by numerous stakeholders hoping to maximize
the benefits of long-term investments in Idaho's clean energy future.
Respectfuly submitted,
Ken Miler
Clean Energy Program Director
Snake River Allance
Boise,ID
[phone]
kmiler¡ßsnakeriverallance.org