20151005Snake River Alliance Comments.pdf

RECfl iV Li]Comments of the Snake River Alliance
on ldaho Power company'sffi::Tgrated Resource e,h1tdtqPrb pil rrr htr
Ken Mitter, ctean Energy program Director, Snake nir"1,+1fi4{W#ffi' 18*,**
October 5,z0ts
The Snake River Alliance appreciates the opportunity to submit these comments to the ldaho
Public Utilities Commission in docket IPC-E-15-19, ldaho Power Company's 20L5 lntegrated
Resource Plan (lRP), on behalf of its members, many of whom are customers of ldaho Power.
The Alliance commends ldaho Power for its continued progress in making the IRP Advisory
Council (IRPAC) process increasingly transparent and accessible to the public. We would like to
see a greater and more diverse public participation in IRPAC meetings, however, and believe
that if ldaho Power were to more actively promote or publicize its IRPAC meetings, more of its
customers might attend and participate. Given that most of ldaho Power's customers cannot
attend these daylong meetings due to their work schedules or other circumstances, we
recommend that Company more creatively explore methods to increase public participation.
Nonetheless, ldaho Power deserves credit for welcoming the public at its IRPAC meetings and
allowing customers and other stakeholders to participate in a more conversational manner
during the course of the IRPAC meetings.
The Alliance recommends that the Commission accept ldaho Power's 2015 lRP, but we also
recommend that in so doing the Commission provides specific guidance, outlined below, as
ldaho Power undertakes development of its 20L7 lRP. We are disappointed that ldaho Power
did not have an opportunity to adjust this IRP to better reflect future load and other conditions
that have changed since the submittal of this lRP. lt should be clear to the Commission that
ldaho Power has more-than-abundant supply-side resources, which has led to the unfortunate
curtailment of certain demand-side resources, notably ldaho Power's three demand response
programs. We are concerned that emphasizing thermal power production resources while
interrupting demand response resources sends the wrong message to customers, and raises
questions about the Company's commitment to reducing its greenhouse gas emissions.
IRPAC PROCESS
The Alliance commends ldaho Power and its staff that worked on the 2015 IRP for the seeking
and acknowledging various views expressed by IRPAC members and by other members of the
public and stakeholders. The IRP team also conducted workshops in addition to the traditional
IRPAC monthly meetings to allow IRPAC members and others to engage in more detailed,
thoughtful discussions that helped inform the final product. IRPAC members were pleased with
ldaho Power's willingness to analyze more than 20 possible portfolios - a significant increase
from the number of portfolios analyzed in prior lRPs.
The company's IRP team regularly reached out to IRPAC members in meetings and informally to
make the process accessible and visible. We do note that, for various reasons, including some
beyond ldaho Power's contro!, non-IRPAC public participation in monthly meetings was
negligible although ldaho Power's IRPAC team regularly fielded questions from non-IRPAC
members, which improves the process.
We suggest ldaho Power work harder to publicize IRPAC meetings in a more visible fashion and,
as mentioned above, explore more creative, additional methods to engage with stakeholders
such as with periodic evening meetings to allow customers and others to provide input at
various stages of the IRP's development. This is not a criticism of the IRPAC process; rather a
suggestion on how to broaden public participation.
PREFERRED PORTFOLIO
This IRP is somewhat different from many earlier tRPs in that it was created at a time when
ldaho Power had little need for additional energy resources, and with July energy deficits not
occurring for all analyzed portfolios through 2025 or beyond. The December energy deficits do
not appear until far longer - beyond 2032 in most portfolios.
Because ldaho Power is so long energy, participants in the 2015 IRP process had the
opportunity to concentrate less on meeting near-term supply-side energy requirements and
instead focus more on such thing as various carbon emissions reduction scenarios (EPA Clean
Power Plan, carbon caps, carbon taxes, etc.) and, for the first time, serious discussions on
scenarios that would result in early closures of some plants in ldaho Power's coal fleet. That is
reflected in the preferred portfolio, 6b, which as discussed below envisions the early retirement
of both North Valmy coal units, but also development of the Boardman Hemingway
transmission project to offset some of the lost production stemming from the Valmy closures.
We understand why ldaho Power coupled coal plant decommissioning with large new
transmission, but we aren't convinced that developing and energizing B2H is the only scenario
in which coal and Valmy in particular can be phased out over time. Part of our concern is that
B2H has a long (and understandable) history of development delays and soaring costs.
However, this portfolio assumes that if 500MW of B2H installed capacity is not built on time,
there a strong likelihood that additional new natural gas generation beyond the 300MW of
installed capacity from a CCCT in 2031 will be the default resource in this portfolio.
Also as discussed below we are pleased that ldaho Power is embarking on new pilot projects
such as ice-based thermal energy and community solar. We have been frustrated in the past
that solar "pilot" projects have been included in prior lRPs, but that for various reasons never
materialized.
Also, as other commenters will certainly point out, Portfolio 6(b) is not the least cost portfolio
of those analyzed. For instance, Portfolio t has a lowest cost relative difference to the "status
quo" Portfolio l that is 5103,880,000, while Portfolio 6(b) has a lowest cost relative difference
to status quo of 5t78,464 - a difference of about S75 million lP. LL7l. Portfolio 9 would retire
the Valmy units in 2019 and 2025 and also include demand response, B2H, and a simple cycle
turbine. We recommend at least one Valmy unit be retired by 20L9, and that both are retired
no later than 2025.
lmportantly, this is the first ldaho Power IRP in which portfolios containing coal plant
retirements outperformed ma ny portfolios:
"As previously noted, portfolios with early North Valmy unit retirements performed well
in the 2015 IRP analysis; analyses show favorable economics for portfolios with the
retirement of North Valmy Unit 1 as early as 2019. However, these portfolios carry
considerable risk associated with the following factors" (P. 10).
Those factors include uncertainty related to the Clean Power Plan, although as we point out
many such uncertainties have been reduced since the Clean Power Plan's release in final form
in August. Other uncertainties include the complexities of closing plants owned by multiple
utilities, although in the case of Valmy all indications are that co-owner NV energy is pursuing a
retirement scenario more aggressive than that of ldaho Power' and also related to ldaho
Power's PURPA solar obligations, but again that picture is clearer today than when the 2015 IRP
was submitted to the PUC.
It is helpful and in many cases important for an electric utility portfolio to look out into the 20-
year time frame, particularly when examining emissions such as CO2, NOx, SO2 and Hg (P. 125),
but as this IRP correctly notes, attempting to project such emissions without more clarity
regarding the future of such assets as Jim Bridger Units 1 and 2 make such projections
problematic.
COAL PLANTS AND CLEAN POWER PLAN RULE 111.(D)
We are encouraged that the 2015 IRP does not attempt to forecast future carbon prices in their
myriad forms. Prior lRPs have attempted to do so, but forecasting carbon constraints or costs
has proven impossible. We agree with ldaho Power that it is far more effective to view the
carbon issue partly through the prism of EPA's Clean Air Act Section 111(d) amendment to
curtail carbon emissions from existing power plants. This, too, is an inexact science inasmuch as
the IRP was prepared in advance of the release of the final Rule 111(d), but it is a step in the
right direction. Furthermore, ldaho is only in the formative stages of determining a compliance
and implementation plan to submit to EPA, including whether the state may join a possible
regional alliance of states for overall compliance, not to mention whether it will lean more
toward a rate-based or mass-based plan. ln any case, we expect whatever implementation plan
ldaho puts forward must come to grips with the reality that ldaho Power's coal fleet generation
upon implementation of Rule 111(d) will be curtailed, even though it is located outside of
ldaho, or that the cost of the generation will rise exponentially if coal plant owners seek to
reduce plant emissions through expensive environmental retrofits.
ldaho Power is to be commended for addressing the Clean Power Plan sensitivity analysis in
such a thorough fashion. lt is true that ldaho's assigned emission reductions are far lower in the
final Rule 111(d) than in the draft, but compliance will nonetheless demand reductions at some
level. For instance, in analyzing the system-wide mass-based compliance category, the IRP
states (P. 115) that:
"Under this approach, system-wide emissions, which include emissions from Langley
Gulch and ldaho Power's share of Jim Bridger and North Valmy, are constrained to
6,332,020 tons of CO2 from 2O2Oto 2029, and to 5925,874 tons of CO2for 2030 and
beyond."
The IRP states further in reviewing emissions-intensity compliance using the EPA's compliance
building blocks, which have changed, and in some cases significantly, since the final rule was
issued subsequent to completion and filing of this IRP:
"ldaho Power makes the following assumptions in using the EPA's building blocks as the
basis for CAA Section 111(d) compliance:
,/ Boardman coal plant I reduced to a zero production level and retired by year-end
2020;
,/ North Valmy coal plant is reduced to a zero production level and retired as early
as year-end 20L9 or as late as year-end 2025; until retirement, ldaho Power's
share of North Valmy is assumed to have an annual constraint equal to its 2012
production level (lPC share =8L4,264 MWh);
,/ Jim Bridger coal plant is reduced to a production level 53,320 MWh less than its
2OL2 production level of 4,54L,772 MWh (lPC share); the re-dispatch of Jim
Bridger is to a new 95MW CCCT under construction in Wyoming.
We expect that in the interim between the 2015 and 2O!7 lRPs, ldaho Power will address the
issues of the future Jim Bridger Units l and 2. We understand that the PUC-approved selective
catalytic reduction (SCR) addition to Bridger 3 and 4 is well under way, extending the life of
those units despite the inevitable carbon control requirements that are now reality. We didn't
believe then that the investment was in the best interest of ldaho Power customers, and we are
certain that adding SCRs to Units 3 and 4 will not be - particularly given the regulatory
landscape wil! be much more in focus leading up to the next lRP. We urge the Commission to
impress upon ldaho Power that it would be placing itself at considerable risk in terms of cost
recovery in the event it pursues SCRs at those two coal units. And we are concerned that, as we
expressed in our testimony in IPC-E-13-15, that further investments in SCR technology are not
in the best interest of ldaho Power customers and that such investments do not address coal
plant carbon emissions.
Not included in this 20L5 IRP is the issue of the "socialcost of carbon" (SCC), also referred to as
the "social cost of climate change." We recommend that the Commission direct all ldaho
regulated electric utilities to address the social cost of carbon in future lRPs. lt is
understandable that SCC has not been addressed in prior lRPs, but there is ample data today to
warrant including the social cost of carbon in future utility resource plans. There now exist
measurable impacts that can be attributed to CO2 releases from utility coal plants apart from
the established climate impacts, and these now-quantifiable impacts must be included when
evaluating least-cost and least-risk comparisons of supply side resources for purposes of
analyzing IRP portfolios. The Northwest Power and Planning and Conservation Council
(www.nwcouncil.org) is addressing this issue as it crafts its 7th Power Plan for the four
northwest states, including ldaho. We encourage the ldaho Commission to review the growing
body of information on SCC and that it direct ldaho Power to address it in its 2017 lRP.
PILOT PROJECTS
As mentioned above, we are encouraged by ldaho Power's identification of three proposed
pilot projects (PP. 6-8): Solar photovoltaic to address distribution feeder voltage loss; ice-based
thermal energy storage; and community solar.
As ldaho Power states (P. 7)the Community solar pilot, which in this IRP has not been fully
formed, can take several shapes depending on ownership, source of financing, project host,
subscriber motive, and others. Ultimately, however, a primary goal of any community solar
project should be to provide the opportunity to buy solar power if for some reason they are
otherwise unable to install their own rooftop PV, such as tree coverage over the roof living in
multi-family housing. This is different from ldaho Power's green power program in which
customers can designed a charge on their bills to finance programs such as Solar 4R Schools but
does not allow them to receive direct benefits from investing in solar PV off of their residence.
One community solar model can allow customers to purchase solar power from a central
station, along with other customers also buying shares, and have that generation offset part of
their bills, so they benefit directly from their green power investments.
ldaho Power states on P. 8 that:
"lt is important to note that ldaho Power's load and resource balance indicates an
investment in any ne generation, including solar generation, is neither needed nor
economic to pursue at this time or during the four-year action plan horizon. However, as
regulations governing carbon emissions mature, additional renewable generation may
be warranted, and community-shared solar could be a viable option to help satisfy some
future carbon intensity targets."
It is also important to note that the amount of generation that would be produced in the early
stages of community solar development would be, in the scale of ldaho Power's resources, all
but imperceptible. By all indications, ldaho Power continues to struggle with what it perceives
as challenges integrating solar onto its system. We stress that this is a pilot project designed to
help ldaho Power become more familiar with solar integration, not to mention well-established
customer demand for clean energy such as solar. We have watched too many solar pilot
projects in ldaho Power lRPs undeveloped, including for reasons we take issue with, and urge
the Commission to hold ldaho Power accountable for implementing its community solar pilot
projects so all customers can be assured the company is committed to pursuing solar power as
part of its supply-side portfolio.
Subsequent to its filing its 2015 lRP, ldaho Power convened a meeting of its IRPAC and all
interested parties to discuss possible community solar pilot project models. This meeting, held
on Oct. 7,2Ot5, was very productive and
The issue of ice-based thermal energy storage is one that has come up during discussions in
prior lRP. The technology is mature and has been implemented by many utilities as a load-
shifting demand response technology. We are pleased ldaho Power is likewise considering ice-
based TES and urge the Commission to support this pilot.
Solar photovoltaic to address distribution feeder voltage loss is also a proposal that warrants
PUC's interest. As with community-based solar, this is yet another opportunity for tdaho Power
to gain more familiarity with solar integration at various scales. ldaho Power says it will report
on its early experiences in the 2Ot7lRP, and we encourage the Commission to ensure that
occurs. Not only can this technology reduce the problem of voltage losses at the end of the
feeder, it can also reduce unnecessarily expensive distribution upgrades.
TRANSMISSION
The Alliance first and foremost supports non-wires solutions to load and resource balance
challenges. lnasmuch as investments in transmission infrastructure have waned regionally and
nationwide, however, we understand the need for certain well-planned and well-sited
transmission projects. ln the lntermountain and Pacific Northwest, it is clearthat many of our
transmission pathways have become severely constrained.
Because of the planning and development horizon for purposes of regulatory approval,
Boardman to Hemingway presents some challenges. The Alliance generally supports 82H
development as helping to move energy to and from ldaho to West Side markets in part
because our respective peak seasons do not coincide, so excess power can be move to areas
needing that generation depending on their seasonal loads. As a summer peaking utility, ldaho
purchases energy from Mid-Columbia energy trading market to meet its peak, and then sell
excess power to the Pacific Northwest during that region's winter and spring peaks.
The Alliance does not oppose ldaho Power's inclusion of B2H in its preferred portfolio and we
also commend ldaho Power's sharing of information regarding the B2H process to date, but
given the gravity of a B2H delay could have on the balance of ldaho Power's preferred portfolio
and the potential for increased CO2 emissions, such as with new natural gas generation
projects, we urge the Commission to require quorterly public reports on the status of the B2H
project. We are not proposing disclosure of confidential or proprietary information, but in the
spirit of allowing public information to such information a willingness to inform in a direct way
how the status of the Boardman to Hemingway project.
SOLAR POWER
As the Commission knows, the Alliance is at odds with both ldaho Power and the Commission's
respective positions on utility-scale solar power, and, respectfully, the Commission's conclusion
in Order No. 33357 in Case No. IPC-15-01. We believe the Commission should direct ldaho
Power - and for that matter o// regulated utilities under its jurisdiction - to ensure the levels of
solar power production as called for in the current ldaho Energy Plan, which states, in part:
"Southwest ldaho's solar potential is very similar to that of the desert southwest, which
has the highest solar potential in the United States. This allows ldaho many
opportunities for solar power applications; however, despite its excellent solar resource
potential, ldaho is behind much of the rest of the country in solar installations. lt is
estimated that a total of 1 to 1.2 MW of solar PV is currently installed in ldaho. ln 2010
alone, the Solar Energy lndustry Association estimates 7,737 MW of PV were installed in
the US."
According to the U.S. Department of Energy's Nationa! Renewable Energy Laboratory (NREL),
ldaho's "total estimated technical potential" for urban and rural utility-scale photovoltaics is
23,195 GWh and 3,936,848 GWh, respectively, ranking ldaho among the most favorable of the
states for its solar potential. Yet for a variety of reasons, ldaho is not contributing a single
megawatt of solar power to the western grid. And according to NREL (U.S. Renewable Energy
Technical Potentials: A GIS-Based Analysis, JulV 2OL2l NREL/TP6A20-51946), ldaho also has 3
gigawatts of estimated technical potential for rooftop photovoltaics; yet again we are seeing
rooftop PV installations stymied by resistant utilities.
On P. 34 of the lRP, ldaho Power discusses its obligations to comply with Oregon solar pilot
requirements:
"Under the Oregon Solar PV Capacity Standard as stated in ORS 757.370,|daho Power is
required to either own or purchase the generation from a 500-kW utility-scale solar PV
facility by 2020. Under the rules if the utility scale facility is operational by 2016, the
RECs from the project would be doubled for purposes of complying with the State of
Oregon RPS. ldaho Power does not plan to build or acquire the generation from a 500-
MW solar facility in Oregon prior to 20L6, as the company already has sufficient RECs to
meet the Oregon RPS requirement and no near-term needs for additional generation.
The company will further evaluate this requirement in the 2017 IRP and determine the
best method of meeting the 2020 compliance deadline."
We urge the Commission to direct regulated electric utilities and interested stakeholders to
explore why these troubling trends are taking place.
Clearly, there exists a decoupling of the intentions of the ldaho Legislature in the 2012 ldaho
State Energy Plan to promote renewable energy development, including solar power, and what
is happening in 2015 - or rather what is not happening in 2015. We ask that the Commission
reiterate its intent that the spirit of the 2012 ldaho Energy Plan envisions robust development
of solar energy at the utility and residential and commercial levels should be encouraged and
that ldaho's regulated electric utilities plan for and encourage solar power development in their
respective service territories. lf the Commission disagrees with the Legislature's intent as
reflected in the state Energy Plan, we urge it to provide guidance to the Legislature as it
prepares to update the Energy Plan in the coming Legislative interim session.
PURPA issues aside, we believe the Commission should inquire further to ldaho Power why it is
not attempting to secure RECs that could be doubled for purposes of complying with the
Oregon RPS. lf ldaho Power doesn't intend to "build or acquire the generation from a 500MW
(sic)facility in Oregon prior to 2OL6, it should better explain its intentions to comply with its
obligations in Oregon. At a minimum, this apparent typographical error (500-kW versus a 500-
MW)facility should be addressed.
RISK
The Snake River Alliance is concerned about the impacts that ldaho Power's proposed coal-
plant upgrades will have on its customers, and those concerns are expressed in more detail in
our testimony in IPC-E-73-L6. We believe the risks associated with this investment regime -
and they are considerable - must be considered as always as the Commission deliberates the
relative risk that should be assigned to ratepayers and to shareholders.
As the Commission is hearing through public comments and as we have noted above, there are
lower risk and lower cost portfolios than Portfolio 6(b). Our preference is that the Commission
direct ldaho Power to pursue one of those alternatives, particularly in light of the Company's
acknowledgement that a 2019 retirement of one of the Valmy coal units would benefit
customers despite possible risks. We do not oppose Portfolio 6(b); we suggest instead that
there are alternatives that may better serve customers' interests.
MISCELLANEOUS 2015 IRP MATTERS AND RECCOMENDATIONS TO THE COMMISSION
,/ The Alliance believes that tdaho Power's estimate of the number of currently licensed
electric vehicles in its service territory is inaccurate and must be recalibrated to reflect
the actual number of electric vehicles license and operating in ldaho. Unless and until
that occurs, any and al EV projections and more importantly the impacts, including
benefit, from electric vehicle integration onto ldaho Power and other grids cannot be
analyzed. The narrative on P. 10 in Appendix A must be updated for the 2017 lRP. A staff
member from The Alliance joined ldaho Power and many other EV owners on Sept. 20,
20L5, at an EV event that featured more than 35 vehicles. lt is evident that ldaho Power
must continuously update its forecasts for EV penetration, as it will influence the
company's load forecasts. This is understandable inasmuch as the EV technologies and
penetration numbers change so rapidly. We suggest the Commission direct ldaho Power
to continue to freshen its EV projections, and the implications for its system, more
frequently.
,/ The Alliance encourages the PUC to direct ldaho Power to conduct a complete
investigation and report on the findings of that investigation of the 1954 Columbia River
Treaty. CRT negotiations will have significant impacts on the operations of the Snake
and Columbia river operations and ecosystems going forward, and the Alliance believes
ldaho must be an important player in treaty negotiations and that those negotiations
well represent ldaho's concerns about protecting habitat of its cherished fish runs and
populations. ldaho Power is a member of the Columbia River Treaty Power Group and
the coming changes to the CRT may well impact ldaho Power's hydro system and
generation. The ldaho Legislature,in a2OL4 Joint Memorial (No. 10), noted that possible
changes in such areas as flood control operations "could have a devastating impact on
irrigation project reservoir supplies in ldaho." The Alliance doesn't share the alarm
expressed in that Joint Memorial, but we believe ldaho and ldaho Power and ldaho
Power's customers have a direct stake in how the CRTR is revised post-2024 and we
believe the Commission should direct ldaho Power to address this issue in its 2017 lRP.
As referenced above, the Alliance suggests that the Commission direct ldaho Power to
address the issue of the social cost of carbon. lt will be difficult if not impossible to
monetize the impacts of coal-fired generation on the environment, on utility customers,
and on utility shareholders without such a calculation. The lack of precision in
addressing SCC was understandably appropriate in excluding it from prior lRPs, but as
we are seeing with utilities in our region and nationwide, the time has come for our
electric utilities to include SCC calculations in their resource planning processes.
We agree with the decision in the IRP to downsize the proposed Shoshone Falls upgrade
(PP. 130-131). As we mentioned in our comments on ldaho Power's 2013 lRP, we
believe a 50MW expansion at the Shoshone Falls Power Plant was unnecessary given
that the power that would have been produced would have been produced at times
when ldaho Power doesn't need the energy. We support ldaho Power's assertion that
"While the analysis indicates some economic benefit from the incremental energy, the
50MW Shoshone Falls expansion cannot be linked to an IRP-determined resource need,
as it provides little to no capacity or energy during peak summer load months."
ln the IRP's discussion of Additional Firm Load (P.7911, there is a discussion of tdaho
Power's large customers. ln the section on ldaho National Laboratory (P. 80), the IRP
projects that the "forecast calls for loads to slowly rise though 202L, rise dramatically
through 2024, and stay near that higher levelthroughout the remainder of the forecast
period." lt does not indicate what might cause such a dramatic increase in load.
We believe that the issue of the Hells Canyon Complex relicensing should be more
thoroughly discussed in the 2017 lRP. lt is clear that the amount of relicensing costs that
will be rate-based is huge, but for purposes of power planning it would be useful for
customers to have a greater understanding of how the relicensing process is moving
forward and (understanding this is an IRP docket and not a rate case) how it may impact
customers.
The Alliance would appreciate the Commission directing ldaho Power to supply
additional information, to the extent it can, on its plans for possible participation in one
of the West's energy imbalance markets. The IRP addresses ElMs on P. L9, and as the
2017 IRP takes form more information should be available.
The narrative on the ldaho Strategic Energy Alliance (P. 13) is incomplete and should be
updated. As of the submittal of this lRP, the ISEA board had not convened a meeting in
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more than a year. The ISEA task force infrastructure is for the most part inactive, and
the ISEA's meetings in 2015 have been conducted without public notice. Allof this
renders the narrative relating to ISEA dated and inaccurate.
CONCLUSION
The Snake River Alliance appreciates this opportunity to submit these comments in IPC-E-15-L9.
We particularly appreciate the facilitation of the IRPAC meetings by Phil DeVol and Mark Stokes
and the entire IRPAC team on both the demand side and supply side of ldaho Power's
operations.
We have ongoing concerns about the coupling of developing the B2H transmission project and
the apparent corresponding retirement of the Valmy coal units in Nevada. We would oppose
any proposal to develop additional natural gas generation in the event the B2H timeline
continues to be delayed, and in any event we will continue to advocate for a prompt retirement
of the first Valmy unit by 2019 and a timely retirement of the second unit no later than 2025.
The Alliance appreciates the challenge ldaho Power confronted in developing an IRP in such an
uncertain federal regulatory environment, particularly regarding the Clean Power Plan. We also
want to reiterate that there currently are no feasible methods to eliminate or reduce CO2
emissions from existing coal-fired power plants, and that is something that we hope the
Commission acknowledges in the event tdaho Power intends to continue operations of its
existing coalfleet. lt is our hope that in its expected acceptance order in this IRP that the
Commission continues to make clear its previously stated concerns about further utility
investments in coal assets, as such investments will likely be rigorously opposed.
As we press for accelerated retirements of utility-owned coal assets, the Alliance is mindful of
the need to address the issue of potential "stranded assets" owned by our utilities. As the
Commission demonstrated in IPC-E-12-09 regarding the Boardman balancing account, however,
the issue of stranded assets is not one that is insurmountable.
Finally, we are grateful for the leadership of ldaho Power CEO Darrel Anderson and his
admonition to the IRPAC that members address these often-difficult issues in a frank and
respectful manner.
Respectfu lly submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
L7
208 344-9L6L
[e-mail]
www.sn a keriverall iance.org
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