20090109SRA Comments.pdf

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Jan. 8,2009 RECE!Vt'~
TO: Jean Jewell
Idaho Public Utilities Commission Secreta
472 West Washington
Boise,ID 83702
iDfi9 JAN -8 AM 11: 04
FROM: Ken Miler
Snake River Allance
Box 1731
Boise,ID 83701
Ph: [phone]
RE DOCKET IPC-E-08-24: IN THE MATTER OF THE APPLICATION OF IDAHO
POWER COMPANY FOR AUTHORITY TO RETIRE ITS GREEN TAGS
Dear Ms. Jewell:
Please accept the following comments on behalf of the Snake River Allance relative to the
Commission's docket, IPC-E-08-24.
The Snake River Allance is an Idaho-based non-profit organization established in 1979 to
address Idahoans' concerns about nuclear safety issues. In early 2007, the Allance expanded th~
scope of its mission by launching its Clean Energy Program. The Allance's energy initiative
includes advocacy for renewable energy resources in Idaho; expanded conservation and demand-
side management programs offered by Idaho utilities and the Bonnevile Power Administration;
and local, state, regional, and national policies and initiatives that promote sustainable and
affordable energy policies. The Allance is pursuing these programs on behalf of its members,
many of whom are customers of Idaho's regulated utilities, who are interested in promoting
clean and affordable energy initiatives.
The Alliance appreciates Idaho Power Company bringing this application to the Commission,
and for reasons outlined below, the Allance supports the Company's request and believes
retirement of Green Tags associated with renewable energy projects for which it has contracted
will benefit the Company, its shareholders, and most important its ratepayers.
FUTURE RENEWABLES REGULATIONS
Given the ~xisting climate in Washington, D.C., and across the nation and paricularly in the
Western United States, the Allance believes some form of renewable energy requirements will
soon be pl~ced on electric utilties. In its 2006 Integrated Resource Plan and more so in
discussions under way in the 2009 IRP under development, Idaho Power seems to recognze the
inevitabilty of some form of renewables portfolio standard (RPS), most likely at the federal
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level, which will require utilities to integrate more renewables into their portfolios. Such
requirements wil almost certainly not include the large hydropower resources that make up more
than 40 percent of the Company's existing portfolio, which means the Company must be in a
position to claim non-hydro renewables for its futue portfolios.
IDAHO POWER'S CURRNT RENEW ABLES PORTFOLIO
Idaho Power curently lacks the renewables portfolio to meet the anticipated goals that would be
set fort in a federal RPS. While the Company is receiving power from the Elkhorn wind project
in Oregon and the Idaho Raft River geothermal project (as well as the Fossil Gulch wind
project), the Allance believes the Company recognizes the need to aggressively seek additional
renewable resources. While the Company has more than 300MW of wind (mostly PURPA)
under contract, we are not convinced all of those projects will materialize. As such, we believe
the Company will by necessity seek additional wind, geothermal, solar, small hydro, or other
qualifying renewable projects as it seeks to meet its eventul obligations for renewables.
We believe the Company, its shareholders and its customers wil benefit from such planing.
Furhermore, we believe Idaho Power ratepayers demand increased amounts of renewables in
their energy mix. Developing these resources, or acquiring them, will help Idaho Power reduce
its risk in the face of futue regulations.
RETIRING THE TAGS IS THE BEST OPTION
Idaho Power could choose to sell the Green Tags flowing from future renewable projects, and
while that option would deliver short-term benefits to ratepayers (as has the sale of surlus S02
allowances), the benefit is transitory. The decision to retire the tags - and book the renewable
energy attibutes attached to them - is the prudent decision. Without the tas, the Company
canot claim the green attributes for what we expect wil be an increasing amount of renewable
energy in Idaho Power's portfolio. We believe - and Idaho Power's customers expect - that the
Company should receive credit for the renewable energy it generates or purchases and provides
to its customers. The Alliance agrees with the Company and Staff that, "By 'retiring' the Green
Tags, Idaho Power can clearly communcate the Company's renewable portfolio to customers,
meet customer expectations for increased use of renewable energy, and align with State interests
in promoting renewable energy."
CONCLUSION
The Allance agrees with Idaho Power that retention and retirement of existing and future Green
Tags associated with its renewable portfolio is prudent economic and environmental policy, and
we encourage the Commission to approve this application.