20090331ICL-RNP comments.pdf

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2009 MAR 31 At; 8: 43
March 30, 2009
Idaho Public Utilties Commission
PO Box 83720
Boise, ID 83720-0074
RE: Idaho Conservation League and Renewable Northwest Project Comments in Response to
the Industrial Customers ofidaho Power Petition for Reconsideration of Order No. 30720
Granting Idaho Power Company Authority to Retire its Green Tags, Case No. IPC-E-08-24.
The Honorable Commissioners:
Idaho Conservation League (ICL) and Renewable Northwest Project (RNP) appreciate the
opportunity to submit comments in support of the Commission's Order No. 30720 granting Idaho
Power Company the authority to retire its Green Tags (i.e. Renewable Energy Certificates (RECs)).
For Idaho Power and other utilties to claim renewable energy in its portfolio, REC retirement is
required. Renewable energy provides many benefits to utilties and their customers. ICL and RNP
applaud Idaho Power for taking this action to facilitate renewable energy inclusion in its portfolio.
The Commission decision in Order 30720 rightly prioritized the financial and environmental values
derived from retirement of the RECs associated with energy generation. REC retirement wil ensure
Idaho Power is accurately accounting for the renewable energy serving its customers. ICL and RNP
add the following comments in response to Order No. 30743 granting Industrial Customers ofIdaho
Power's Petition for Reconsideration.
Shelf Life
The "shelf life" of a REC is variable depending on the type of market in which the REC is used. Idaho
Power has several options regarding the use of RECs that provide value to its customers.
First, Idaho Power could use banked RECs for Renewable Portfolio Standard (RPS) compliance. A
banked REC is a REC that is not used (retired) by a utility to comply with a RPS or voluntary
renewable energy progråm in the calendar year that it is generated. Instead, the REC is carried
forward and held (banked) for the purpose of compliance with a RPS in a subsequent year. Idaho
Power is subject to the Oregon RPS, which contains a REC banking provision and allows for using
banked unbundled RECs to meet up to 20 percent of a requirement for any compliance year. If a
national Renewable Energy Standard (RES) is enacted, Idaho Power may be able apply banked
RECs towards RES compliance. For example, RES legislation introduced in the U.S. Senate by
Senator Tom Udall calls for four year REC banking.
Idaho Power could also sell its RECs to other utilities for RPS compliance. Washington utilties may
use RECs from a compliance year, the preceding year, or the following year. A decision is pending
on the use of unbundled RECs to meet the California RPS, but that may be yet another market
available to Idaho Power.
Another market for RECs is the voluntary market. Green-e Energy, an independent program for
REC certification and verification, has a national standard for renewable energy products it
certifies. To be a Green-e Energy certified product, the renewable energy must be generated in the
calendar year in which the product is sold, the first three months of the following calendar year, or
the last six months of the prior calendar year.
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Once a REC is retired, for voluntary markets or RPS compliance, it may not be used to meet another
current or future RPS.
Monetary Value
WECC Green-e Energy Certified RECs for the back half of 2008 and 2009 are selling for between
$5.50 and $6 per REC and the national market price for the same REC vintage is around $1.30 per
REC. Older vintage RECs have little to no market value, having exceeding the Green-e Energy
vintage eligibilty.
Despite the lack of market value for older vintage RECs, renewable energy has environmental value
to customers such as reduced air pollutants and reduced fuel resource extraction. For example, the
320,000 MWh of renewable energy generated by Idaho Power facilities in 2007 and 2008 represent
over 190,000 metric tons of avoided carbon dioxide emissions. The lack offuel costs and associated
fuel price volatilty for Idaho Power's wind and geothermal generation presents significant
monetary benefit and risk reduction to ratepayers. Finally, a more diverse generation base provides
value to a utilty and its ratepayers. Ratepayers cannot reap these benefits unless RECs associated
with the power generation are retired.
Imaging
If Idaho Power includes energy from renewable resources in its portfolio, truth in advertising
requires REC retirement. Renewable generation presents environmental and financial values as
described above, not to mention the value associated with customer satisfaction from a cleaner
resource mix.
The Commission should continue to prioritize the value of financial and environmental risk-
reduction and truth in advertising derived from REC retirement. Upholding the Commission's
decision to grant Idaho Power the authority to retire Green Tags (i.e. RECs) associated with
renewable power generation accomplishes these priorities.
Please contact us with further questions by callng Renewable Northwest Project at 503-223-4544
or Idaho Conservation League at 208-345-6933.
Sincerely,
Suzanne Leta Liou
Senior Policy Advocate
Renewable Northwest Project
Betsy Bridge
Energy Efficiency Associate
Idaho Conservation League
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