20171120Comment.pdf

Diane Holt
From:[e-mail]
Sent:Sunday,November 19,2017 5:23 PM
To:BeverlyBarker;Diane Holt;Matthew Evans
Subject:Case Comment Form:Alan Hausrath
Name:Alan Hausrath
Case Number:IPC-E-17-11
Email:[e-mail]
Telephone:[phone]
Address:1820 N.7th Street
Boise ID,83702
Name of Utility Company:Idaho Power
Comment:I attended many of the Idaho Power 2017 IRP meetings,read the materials from the rest,and have a few
comments based on my experience there.I would like to thank Idaho Power for the opportunityto participate in the
process and for the friendly and generous way it was organized.
1.The development of the set of portfolios--the alternative energy futures studied--was not transparent and they
seemed to be chosen with a goal in mind:to justify the construction of the Boardman to Hemingway transmission line.
Because of this,the set of portfolios was restricted in breadth and did not seem to span the entire universe of
possibilities.For example,portfolios using more solar or wind were certainly conceivable,but they were never
presented or studied.The Commission should direct idaho Power (IPCO)to use a transparent process to develop
portfolios in the 2019 IRP and to study a set of portfolios that represents all of the reasonable possibilities.
2.IPCO was not consistent in their resource costs.They used Lazard'shigher end cost for solar power,but the lower end
cost for gas.This built in a bias toward gas fired generation and away from solar.With the release of Lazard 11.0,IPCO's
costs are even more outdated;their levelized cost of energy of $88 per MWh for utilityscale solar doesn't even fit into
Lazard'sestimated range of $46-$53 from LCOE 11.0.In addition,Lazard now predicts wind as the cheapest energy
source and IPCO doesn't intend to use any more than what they currently have.Part of the problem is that IPCO applies
current inflation rates to all energy resources.This clearly hasn't been true for solar for several years;prices keep
dropping.The Commission should direct IPCO to use the middle number from Lazard for each energy source in the 2019
IRP and not allow them to arbitrarily exclude the cheapest sources.
3.IPCO's study of the value of distributed energy resources to defer or eliminate T&D upgrades was infuriatinglylimited
and shallow.The Commission should direct IPCO to analyze the differingcosts of delivering power to a widespread and
representative set of points in its service area so that DER's and targeted efficiency measures can be properly evaluated
based on where they are applied.
4.IPCO consistently underestimates resources it can obtain from energy efficiency (EE).It assumes future savingsthat
are much lower than the levels currently being achieved by its cost-effective programs.The Commission
should direct IPCO to fairly evaluate energy resources it can obtain from EE in its 2019 IRP.
Thank you for the opportunityto comment.
Unique Identifier:174.27.81.44