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Home My WebLink About20131104Comment.pdfNovember 4,2013 - 7FF J —j:[ Idaho Public Utilities Commission Attn:Jean D.Jewell,Secretary CM1IS 472 West Washington Street Boise,Idaho $3702 RE:Case No.IPC-E-13-15 Application for 2013 Integrated Resource Plan Dear Public Utilities Commissioners, I have participated in Idaho Power’s IRP development process since the 2002 IRP.During the 10 plus years that I have participated there has been continuous improvement in the quality and relevance of the resource plans.Karl Bokenkamp,Mark Stokes and now Tom Noll have each done an excellent job in leading the integrated planning process.While there are still opportunities for improvement,in my estimation,the 2013 IRP is the best yet. Acknowledging that future resource investments are ultimately Idaho Power’s decision,I appreciate that the Company listens to input from affected and interested parties.Most members of the Advisory Council have taken their participation in the IRPAC process seriously and offered constructive and insightful comments and suggestions.Meetings have been conducted in a fashion that also allowed input from non-Council members of the general public. With the costs of upgrading coal plants to meet developing emissions standards still such an important topic,the removal of dissenting voices (specifically the Snake River Alliance)from membership in the Advisory Council is,in my opinion,regrettable.The demotion of the SRA notwithstanding,I believe that public input has been actively solicited and respectfully considered throughout the IRPAC process. Much has been said about deficiencies in the Company’s coal study (largely in case IPC-E-13- 16).Idaho Power should be applauded for at least considering retirement of existing coal resources in the 2103 IRP. Guided by multiple years of participation in the IRP development process,I request that the Commission consider two suggestions for improvement in subsequent IRPs:one related to the IRPAC process;the other related to the analytical methods employed. Changes in the sequence in which materials are presented at IRP meetings could make Advisory Council members more productive and their contributions more effective In my estimation,the IRP development process could be substantially improved by presenting materials to the IRPAC in a more logical sequence.To illustrate this concept,I’ve listed a six step problem solving process (steps shown centered and numbered just below)with the six steps ruiming from problem identification through submittal of a completed IRP.I’ve also color coded each of the 41 presentations made at the ten IRPAC meetings (shown with the meeting date and a summary of each topic presented at that meeting)to reflect where I see that topic fitting into the six-step process flow.As you can see from the mix of colors covered during each meeting, the topics aren’t presented in a particularly logical sequence. 1.Identify/define the Problem(s) ______ 2 Review inputs/constraints on possible problem solutions 3 Develop a set of possible problem solutions 4 Analyze benefits/costs of alternative — 6 Submit IRP to relevant Commissions Aug 2012 6-Aun-12 Review of B2H and Gateway West routes Sep 2012 6-Spn-12 Oct 2012 flctlO-1i 2012 Nov 2012 r5-Nav-12 Dec 2012 0c 1.2012 Background on Shoshone Falls upgrades Review 2013 summer 28-Jun-13 Submit IRP to ID PUC n eview 2011 C02 price Review C02 price forecasts Present Coal study Presad and resource ‘-orecasts methodology balance Background on DSM Review 2009-11 future Present Snake water for Further DSM update Present portfolio coal usage estimates hydro constraints alternatives and analysis Background on Present 2013 coal price 3 supply side transmission outages estimates forecasts cost estimates Status on 500kV Present PURPA production Present Snake .,.......,-urora modeling transmission prolects forecasts hydro forecasts solar intergration process Status on ID &OR PUC Present 2013 natural gas DSM updated for 2013 Background on distribution 2011 IRP reviews price estimates assumptions line voltage conservation Background on ID &Present 2013 C02 adder PUC IRP guidanr stimates Review 2011 supply side resource cost estimates Feb 2013 Mar 2013 Apr 2013 May 2013 Jun 2013 21-Feb-13 14-Mar-13 11-Apr-13 9-May-13 6-Jun-13 Present coal study Risk analysis of resource Risk analysis for resource Review additional portfolios Summarizes IRP peak alternatives portfolios for loss of Valmy 1 &2 load,9 portfi Alternative resources Review of Energy Efficiency Review 2013 specific water Bdckground on Energy snalyzed A ze seven portfolios and DSM ‘onditions Tmbalarice Markets Sustainability at IPC0 HecklerIPC-E-13-15 comments page 2 Review Peak day load orofile by r ‘“‘‘r tvoe Subsequent submittal of IRP to ID &OR PUC Different people will characterize the topics and/or process steps differently.Nonetheless, grouping the 41 presentations by where they fit in a process flow (an example is shown below) could provide multiple benefits. Meetin-j 1 Metinq_2 Meeting 3 Meeting 4 Meeting 5 Status on ID &eview of IReview of prior meeting Few of prior meeting 2011 IRP revi’” ________ d,.7________analyses Background a PUC IRP guidance itives and analysis Review additional portfolios ______________________________________ for loss of Valmy 1 &2 ivlew of prior meeting ation ly side :e cost estimates 2013 coal price Present sales and load -Background on Present 2013 natural gas Forecasts transmission outages once estimates Present load and resource Status on 500kV Review C02 price forecastsl ‘,alance transmission protects t coal study Summarizes IRP peak load,g portflios resources lySi5 of resource nrrtfnIinc - in resource Review 2011 C02 price DSM updated for 2013 forecasts assumptions Review 2009-11 future Present Coal swdy coal usage estimates methodology ________________ Present 2013 C02 adder Further DSM update estimates ___________________________ Present Snake water for Present 2013 supply side hydro constraints resource cost estimates Present Snake water for Review of Energy Efficiency hydro forecasts and DSM Background on wind and Background on Energy solar intergration Tmbalance Markets Background on distribution line voltage conservation Review of B2H and Gateway West routes Review 2013 specific water ‘onditions Sustainability at IPC0 Background on Shoshone FlIs upgrades Review 2013 summer operations 1.Reduced duplication Some topics were covered multiple times.For example,in the 2013 preparation cycle,DSM was covered in four different presentations.Transmission and water conditions were each covered in three separate presentations.fewer,better-integrated presentations could be used to cover these topics. 2.Improve comparability and avoid anomalies Twice in the 2013 preparation cycle “placemat”presentations were made.These presentations (which show supply side resource cost estimates)are called “placemat”because the presentations are accompanied by a handout printed on 11 by 17 paper (that page size being needed to show all the columns of information related to each resource).The 2011 cost estimates were presented at the August 6,2012 meeting.The 2013 estimates were presented at the December 1 3th meeting. Heckler lPC-E-l 3-15 comments page 3 In the handout (presented at the August meeting)which shows 2011 supply side resource cost estimates,the 30 year levelized cost of 1 MW solar panel array installed in the Treasure Valley was estimated at $150/MWhr (as shown immediately below). Supply.Sld.Resource Type Technology D.ecrlpttotv?rototype CapacIty (MW Assumed Construction TechnologIcal IS Y.eitTabI Prol.ct Rating)LocatIon(s)?(Years)Availability Lsvd Region Ceeh Solar -flat Plate PV (Distributed)PV panels that convert the suns rays 1 Treasure Yatey 05 Year 2012 *150directlytoelectricityLocatedata centralized plant or distributed on tap ofbuildings within a uldilys servrce tartary In the handout (presented at the December meeting)which shows 2013 supply side resource cost estimates,the 30 year levelized cost of 1 MW solar panel array installed in southwest Idaho was estimated at $220/MWhr (again shown immediately below). Supply-SIde Technology Capacity On-Peak AsaUm.d ConstructIon Year that 30 Year To4el 10 Yt Toat Resource Type O.scrlptlon/(MW Rating)Capacity LocatIon(s)?(Years)Technology Is L.aveliISd Laatla.d Prototype Project (MW)Region Available CoUiWh Coe4i?i wo Carbon with Carbon Solar-F)atPlatePV FlatPtabPV 1 0.75 Southwest O5Yw 2013 $220 hth1 Idaho IRPAC members don’t appear to bring all their handouts from earlier meetings to the subsequent meeting(s).Most IRPAC members probably never compared the 2011 placemat sheet given to them in August with the 2013 placemat sheet they received in December.If both 2011 and 2013 resource cost estimates had been presented during the same session,an interesting discussion may have ensued.Most industry observers saw solar prices fall dramatically from 2011 to 2013. It might have been valuable to understand why the Company estimated in this instance that they rose almost 50%over that two year period.Perhaps it was because the 2011 resource was “distributed”while the 2013 resource was “utility”.Regardless of the reason,I think the Advisory Council would be better served if the placemat presentations were made at the same meeting to identify anomalies like these two solar cost estimates. 3.Add reviews of prior meeting contents The observation that IRPAC members don’t all appear to bring handouts from earlier meetings to subsequent meetings leads to another possible process improvement.Many meeting facilitators Heckler IPC-E-13-15 comments page 4 begin each meeting with a review of what was addressedldecided at the prior meeting.If the topics presented at each meeting were all related to a particular process step,Tom Noll,or whoever was serving as the meeting facilitator,could begin the next meeting with a review of the issues identified and decisions made at the prior session.This could help IRPAC members get back into context quickly and in so doing improve the efficacy of their participation. 4.Reduce IRP preparation cycle tune to accommodate rapid change The pace of change in the electric utility industry seems to be rising rapidly.As conditions change assumptions can rapidly become outdated.Many businesses,when challenged by rapid changes in their business environment,try to reduce their process cycle times to better accommodate the rising rate of change.I think that by reorganizing the sequence in which topics are presented to the IRPAC,the total number of IRPAC meetings needed to produce the bi annual IRP could be substantially reduced. fewer meetings during the IRP development process could reduce both the IRP preparation cycle time and the time commitment of Advisory Council members.Additionally,fewer meetings during the IRP development cycle could free up Advisory Council members to participate in a couple of workshops during off years to address the most pressing concerns the Commission identifies when reviewing the submitted IRP. A changed analytical method could better address the system peak load problem. Load and resource balances show that over the next decade the primary challenge will come from growing system peak loads.I think it is time to bring additional tools to bear on the rising peak load challenge. 1.Current analysis undervalues distributed generation It’s having too much solar energy (drying crops and heating our homes and businesses)that causes the high summer irrigation and air conditioning loads that produce system peaks. Harnessing that surfeit of solar energy will eventually be part of the peak load solution.Several other commenters have already questioned the Company’s solar cost estimates.I question the way the Company values distributed generation.Solar generation located at or very near load eliminates both the 13%transmission losses currently borne bringing power from remote central generators to load and,if properly sited,helps defer transmission and distribution system Heckler IPC-E-13-15 comments page 5 upgrades.I don’t see that the current analysis adequately accounts for either of these benefits and by so doing dramatically overestimates the net costs of solar and other forms of distributed generation. 2.Use market mechanisms for summer peak problem Industrial Load,Irrigation Load, Commercial Load,and Residential Load 1,600 As the graph showing the July 12,2012 peak load above displays,irrigation adds to the base load in summer,but it is residential (read here,AC)loads that drive the peak.I request that you direct Idaho Power to review how time of day pricing for residential customers during the June 15th through August 15th peak period might be used in reducing peak load growth. 3.Combined electric and gas efficiency riders Opportunities for lowering air conditioning loads are currently being missed for customers that cool their homes and businesses with electric powered air conditioning in the summer but use 1,200 1,000 1,400 800 600 400 200 z x ===z z ========x =====I U).U a,.,_I-I-I-I.I F.,)F.,)F.,)F.,)F.)C i-F.U a,O 0 F.J U . Heckler IPC-E-13-15 comments page 6 natural gas to heat them in the winter.While this isn’t just an Idaho Power issue,I request that the Commission consider establishing a combined Idaho Power and Intermountain Gas efficiency pool to pay for improved weatherization for customers that heat with gas and cool with electricity.This could help reduce both customer bills and summer electric peaks while freeing up therms to be burned at Langley Gulch in the winter. In summary,I applaud Idaho Power for the improvements it has made in its IRP development process over the past decade and respectfully request that the Commission direct the implementation of the above listed potential future improvements. Michael Heckler 2245 Roanoke Dr Boise,ID 23712 Heckler IPC-E-13-15 comments page 7