20210507Comments(2).pdf

May 7, 2021

Ms. Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A Boise, ID 83714

SUBJECT: Idaho Public Utilities Commission Case #IPC-E-21-06; Written Comments
(Submitted Electronically)

Dear Ms. Noriyuki,

The City of Boise (“City”) submits the following comments on Idaho Power’s petition to
extend the filing date for their 2021 Integrated Resource Plan (IRP). The City
recommends the Commission extend the deadline from June to the end of December
2021. This extension will ensure sufficient time for Idaho Power to obtain robust feedback
through the Integrated Resource Plan Advisory Council (IRPAC) and meaningful public
engagement.

As a participant on the IRPAC, the City recognizes the detailed and technical
information that needs to be conveyed, discussed, and analyzed to ensure the inputs
and modeling process produce the best 20-year plan for Idaho Power customers. The
evaluation of increased renewable energy resources and demand-side management
opportunities are particularly critical to ensuring a least-cost, reliable, and responsible
resource mix.

In the 2021 IRP process so far, the City acknowledges the significant effort by Idaho
Power staff to present high-quality information in a virtual setting and to ensure
questions, comments, and feedback from IRPAC members are addressed. The current
deadline in June is an insufficient amount of time to cover the large number of
outstanding topics at the IRPAC, as outlined in Idaho Power’s published timeline, or to
complete and present the final Aurora results.

If you have any questions or need additional information, please contact the Climate
Action Division of the Department of Public Works at [phone].

cc: Lisa Nordstrom, Idaho Power
Allison Williams, Idaho Power

IPC-E-21-06 May 7, 2021 ICL Comment 1
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street Boise, ID 83701 Ph: [phone] x 112 [e-mail]

Attorney for the Idaho Conservation League BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY’S PTETION TO EXTEND THE FILING DATE OF ITS 2021 INTEGRATED RESOURCE
)
) ) ) )
CASE NO. IPC-E-21-06 COMMENT
The Idaho Conservation League (ICL) supports Idaho Power’s request to extend
the filing date for the 2021 IRP to December. As an active participant in the planning
process for the last decade or more, ICL agrees that the process and the public benefits
when customers and stakeholders have “amble time to provide input” and the plan has
been “fully discussed”. IPC Petition at 4. One example of an issue that remains
undeveloped is the gas price forecast. Idaho Power invited a representative of S&P
Global Platts to explain the firm’s confidential gas price forecast. That presentation was
nearly incomprehensible and lacked of any publicly available documentation. Since then,
customers and stakeholders have not seen any further information or been given the
opportunity to provide input or discuss this import issue. This reason alone is sufficient to
support extending the IRP process timeline.

Respectfully submitted this 7th day of May 2021. __/s/ Benjamin J. Otto____ Benjamin J. Otto
Idaho Conservation League
IPC-E-21-06 May 7, 2021 ICL Comment 2
CERTIFICATE OF SERVICE
I hereby certify that on this 7th day of May, 2021, I delivered true and correct copies of the foregoing COMMENT to the following persons via the method of service noted:
__/s/ Benjamin J. Otto____
Benjamin J. Otto
Electronic mail only (See Order 34602): Idaho Public Utilities Commission
Jan Noriyuki, Secretary
[e-mail] Idaho Power Lisa Nordstrom
Alison Williams
[e-mail] [e-mail] [e-mail]