20111114ICL Comments.pdf

Benjamin Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idaoconservation.org
RECEIVED
2011 NOV 14 P~1 4: 41
UTI
Attorney for Idao Conservtion League
BEFORE THE IDAHO PUBUC UTIUTES COMMISSION
IN THE MA'IR OF IDAHO POWER )
COMPANYS 2011 INTEGRATED )RESOURCE PLAN )
)
)
CASE NO. IPC-E-ll-ll
COMMENTS OF TH IDAHO
CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League (ICL) with the following comments on Idao
Power's 2011 Integrated Resource Plan. ICL is a member of the IR Advisory Committee. As
an IRP AC member, ICL paricipated in developing this plan and provided both wrtten and
verbal comments thoughout the process. ICL commends Idaho Power for the inclusive process
used to develop this IR.
On the whole, the 2011 IRP is a reasonably fair discusion of the curent and future state
of affairs for Idao Power. Below we highight a few issues the Commission should consider when
reviewing and accepting this plan. In accepting the Rocky Mountai Power 2011 IRP the
Commission stated: ((It is the ongoing planning process that we acknowledge, not the conclusions
or results."! Accordigly, ICL's comments below focus on the process sued to evauate different
resource options and develop an integrted plan.
Energy Effciency
The process used to analyze the potential for energy effciency programs, both existing and
i Order No 32351 at 9.
ICL Comments on Idao power 2011 IR 1 November 14,2011
new, does not place these resource on equa footing with supply side resources. In reviewig the
potential for existing and new energy effciency resources the 2011 IRP ((placed primary emphasis
on the first five years (2011 -20 1 5) when reviewig progr potential; then future progr
performance was assumed to be held constant at 2015 levels, unless known codes and standads
or other mitigating circumstances jusifed raping the progr down early."2 The process of
lookig ahead only five year and then asuming no furher growth in progrs is unlike any other
resource type. The IRP does not look at the potential to develop simple cycle combustion turbines
by 215 and then asume no furher growth. Instead, the IRP weigh the costs and risks and plans
to acquie additional supply resources in the future accordig to the least-cost, least-risk mantra.
ICL encourges the Commission to adopt the Rocky Mounta Power planning process of
identifyg the cost effective level of energy efficiency as par of the resource portfolios.
Another example of the unequa treatment of energ efficiency is found in the analysis of
vaous resource costs. The IRP calculates that existing progrs have a levelized cost of 3.6 cents
per kwh and new progrs cost 5.1 cents per kwh.3 But these levetized costs never appear when
the Company considers new resources options meet load requiements. 4 In this instance, energy
effciency is not just on an unequa playig field, it is not on the field at alL. Ths process fais to
find the leas cost, least risk mix of resources.
Whe energy efficiency is clearly the least cost resource, there is some risk associated with
it. Foremost is some uncertaity is whether it is a sufficiently reliable and avaiable resource. The
2009 DSM Potential Study by Nexant documents substantial amounts of economic energy
efficiency potential yet to be acquied ICL commented on the 2009 IRP that the ((Commission
should diect Idao Power to redouble its efforts in the 2011 IRP to achieve the economic
2 IRP at 38.
3Idat40-42.
4 See Fogue 6.9 at page 77,
ICL Comments on Idaho power 2011 IRP 2 November 14,2011
potential for DSM documented in the Nexant report."5 In response, the Commission stated ((In
addition to economic barers there are also non-economic barers. An identification of barers
would be helpful in explaiing and understanding the Companys efforts and strategy to close the
gap between economic potential and achievable potential."6 The 2011 IRP mentions in a single
paragraph the non-economic barers includig "understandig of behaviors and decisions that
residential customers make in regads to energy efficiency investments(.J"7 The remaider of this
paragraph notes continued use of process evauations to understand these barers. ICL submits
that merely mentioning barers and future evauations is an insufficient process for explaiing
Idaho Power's efforts and strategy to acquie all cost effective energy effciency.
A more important risk factor is the impact of not acquig cost effective energ
efficiency. Idaho Power includes ((DSM varabilty' as a risk factor when evauating al of the
potential resource portfolio options.s Ths analysis shows that not acquig DSM has a larer
negative consequence than positive consequence for ratepayers. If Idaho Power has a low level of
DSM acquisition the cost of every portfolio wil increas by $49-$61 milion. But if Idao Power
achieves a high level of DSM the cost for each portfolio could decrease by $118 - $119 milion.
The faiure to achieve a high level of DSM wi negatively affect ratepayers regadless of any
portfolio option. Accordingly, the IRP planning process should include a robust strateg to ensure
Idao power acquires all cost effective energy effciency.
Carbon Issues
Planning for the risk of future carbon reguation is another important par of the resource
planning process. There are essentialy two ways to mitigate the risk of future caron reguation;
5 Order No. 32042 at 5.
6 ld at 19 - 20.
7 IRP at 39 - 40.
8ld at 102, 105-106.
ICL Comments on Idao power 2011 IRP 3 November 14,2011
either reduce the emission of carbon or purchas compliance tools, offsets or options. ICL
maitais that directly reducing carn emissions is the be policy and does not support using
ratepayer funds to purchas offsets. The only additional information about carbon offsets in the
2011 IRP compared to the 2009 IRP regads the collapse of the Chicago Climate Exchage, ((the
sole voluntar GHG reduction and offset tradig platform for North America and Brail."9
Meanwhie directly reducing carbon emissions does not rely in complex financial markets of
products.
The planning process for directly reducing reliance on carbon emitting resources should
begi with a unit-by-unit review on continued investments in Jim Bridger and Valy coal plants.
The IRP explains that plant modifications for emission controls at Jim Bridger are planned for
2015,2016,2021, and 2022, and that decisions to upgrde the boilers in units #3 and #4 ((are
curently being evaluated."10 But the IRP does not provide any furher details on the costs or risks
of this strategy. ICL encourges the Commission to require idao Power to develop an integrted
plan using both demand side and supply side resources to avoid these costly expenses and mitigate
carbon emission risk in future IRPs.
Solar Power
As in 2009, the 2011 IRP continues to demonstrte the rising potential for solar to be a
least cost, least risk resource. The overrding featue of solar today is the plummeting cost for
photovoltaic panels. When assessing the capital cost risk of solar resources the IRP
acknowledges the potential for fallng solar prices but then states "Solar-powered resources are
also estimated to have substatial potential for increase capital costS."1 1 Robust planning
9 ld at 10.
io ld. at 68.
II ld at 101.
ICL Comments on Idao power 2011 IRP 4 November 14,2011
processes begin with robust data. ICL has not seen any credible analysis that shows solar has "a
substatial potential" for rising capital costs. By using the specter of rising capital cost, the IR
inaccurately models the risk for solar resources.
The IRP does mention that Idaho Power continues to consider a Solar Demonstrtion
Project building on the 2009 IRP and solar potential study. While ICL encourges Idaho Power
to pursue solar as a resource, the proposed demonstrtion project is not the right direction. The
IRP states that par of the fåcilty "would be devoted to testing new PV panel technologies,
inverters, and other mounting and tracking systems.,,12 While importt information, this ty of
research is already being conducted at universities and labs including the Nation Renewable
Energy Research Laboratory. While the IRP review process is tyically focus on planing, not
outcomes, in this instance Idaho Power is anouncing its plan to pursue a CPCN for the
demonstration project. ICL encourages the Commission to weigh in early in this process. ICL
submits a more valuable use ofIdaho Power resources is to addrss issues like interconnection
stadads, met metering policies, and integrting distrbuted systems into the Company's larger
system. Accordingly, a demonstration project focused on rooftop solar is a beter use ofIdaho
Power resources.
Hells Canyon Relicensing
The IRP report that Idaho Power recorded $153 milion in relicensing costs of Hells
Canyon Complex on March 2011 and that "it is not possible to estimate the final total COSt.,,13
Final relicensing could require changes to the operation of the facilties, and thus resolving this
process is a major par of the integrated plan for meeting resource needs. ICL encourges the
12ld at 11.
13 ldat 14.
ICL Comments on Idaho power 2011 IRP 5 November 14,201 i
Commission to require a more robust discussion of the Company's efforts and strtegy to resolve
the relicensing process is a timely maner. At the conclusion of the next IR cycle this process
wil be in its tenth year.
WHEREFORE, ICL respectfuly requests the Commission consider these comments.
DATED this 14th day of November 2011.
Respectfully submitted,~~.
Benjamin J. Otto
Idao Conservation League
ICL Comments on Idao power 2011 IRP 6 November 14,2011
CERTIFICATE OF SERVICE
I hereby certify that on this 14th day of November, 2011 I delivered true and correct copies
of the foregoing COMMENTS OF IDAHO CONSERVA nON LEAGUE to the followig persons
via the method of servce noted:
Hand delivery
Jean Jewell
Commission Secretar (Origial and seven copies provided)
Idao Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
Electronic Mai:
Donova E. Waler
Jason B. Wiliams
Idao Power Company
1221 West Idao Street
Boise, Idaho 83707-0070
dwale~idaopower.com
jwiliams~idaopower.com
GregW. Said
Timothy E. Tatum
Idao Power Company
P.O. Box 70
Boise, Idao 83707
gsaid~idaopower.com
ttatum~idaopower.com
&~4õ
~Benjamin J. Otto
Idao Conservtion Leagu
ICL Comments on Idaho power 201 1 IRP 7 November 14, 201 1