20210817Formal Comments.pdf

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JAYME B. SULLIVAN
BOISE CITY ATTORNEY
MARY GRANT (ISB No. 8744)
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email : rnrgrant(D,cityofboise.ore
Attorney for Intervenor
lse.
BEFORE, THE
IDAHO PUBLIC UTILITIES COMMISSION
Case No. IPC-E-21-12IN THE MATTER OF IDAHO POWER
COMPANY'S APPLTCATION FOR A
DETERMINATION ACKNOWLEDGING ITS
NORTH VALMY POWER PLANT EXIT DATE CITY OF BOISE CITY'S
FORMAL COMMENTS
COMES NOW, the city of Boise City, herein referred to as "Boise City," and pursuant to
Rule 202 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA
31.01.01 .202), andpursuanttothatNoticeof ModifiedProcedure, OrderNo.35109, filedonJuly
74,2021, hereby submits its formal written comments and states as follows:
1. Boise City has an interest in ensuring that the retirement date of the coal-fired North
Valmy Power Plant Unit 2 ("Yalmy") positively impacts the environmental, health, and economic
concerns of Boise City and its citizens. Early retirement of Valmy aligns with Boise City's goals
of increasing utility-scale clean energy resources as a part of its community-wide goal of I00%
clean, affordable, and reliable electricity by 2035. Additionally, Boise City is a large customer of
Idaho Power with an expressed clean energy preference. Boise City believes that rapidly, yet
CITY OF BOISE CITY'S FORMAL COMMENTS - 1
deliberately, retiring the coal-fired assets from Idaho Power's portfolio, and replacing their output
with suitable clean energy alternatives, is critical to reducing system costs, promoting resilience,
and mitigating risk.
2. With some reservations, Boise City recommends the Commission acknowledge that, as
of August 2021, an exit date of December 31, 2025 for Valmy is appropriate. Boise City's
reservations stem from the not-current model inputs the Company relied on to analyze the
economic impact of a December 31, 2025, retirement date compared to alternative resource
options. Boise City believes the most accurate comparison of options would use results from the
Company's recently completed all source request for proposal ("AS-RFP") and inputs used in the
2021integrated resource plan ("IIU"'; as cost inputs for the alternative resource options modeled.
Instead, the Company relied on unvalidated "most up to date cost information possible" to model
alternative resource options to fill the capacity need created by a Valmy exit. Ellsworth, Di at32.
3. Boise City supports the Commission acknowledging the planned Decernber 31,2025,
Valmy exit date because Boise City asserts the Company complied with the Settlernent Stipulation
reached in IPC-E- I 6 -24, whichrequired the Company to use prudent and commercially reasonable
efforts to end its participation in Valmy Unit 2 by December 31, 2025. Additionally, Boise City
regards the information presented in this application as complying with the Commission's direction
in Order No. 34349 despite the Company not meeting the timeline in the order, due to delays
throughout the 2019 IRP process.
4. Boise City recognizes the December 31, 2022, exit date identified in the Second
Amended 2019 IRP is no longer the least-cost, least-risk option for the Company's system. This
is due to factors identified in the Company's application that may impact system reliability such
CITY OF BOISE CITY'S FORMAL COMMENTS - 2
as changing market conditions, additional demands on the regional electrical transmission system,
and extreme weather events, the impacts of which are still unfolding.
5. Boise City believes it is at least possible, if not probable, that a retirement date before
December 31,2025, would be economical and not compromise the reliability of the Company's
system. Boise City also contends that the analysis to determine whether an earlier retirement date
is economical could and should use price inputs determined by the results of the Company's 2021
AS-RFP, completed August ll,2l2l,and inputs to the Company's 2021 IRP. The Company could
conduct this additional modeling, receive the results, and if an earlier exit is economical, notifu
NVEnergy of its intent to exit the Framework Agreement on a timeline that would allow an exit
prior to December 31,2025. Then, the Company could issue an AS-RFP to fill the specific capacity
need created by the Company's exit from Valmy. Doing so would be a best practice and could
result in significant ratepayer savings. Boise City supports the Company's commitment to
continuing to evaluate an earlier exit date as it develops a least-cost and least-risk portfolio for its
2021 IRP. Ellsworth, Di at 39.
6. The Company's attempt to supplement the modeled resource cost data in this case with
a limited RFP did not provide useful information to evaluate replacement resource costs because
of the limited subset of proposals. Additionally, the issued RFP received zero responses, providing
no acfual cost information to assess operational savings from an earlier exit compared to firm
market purchases or new resource costs. The lack of response to the RFP supports the Company's
need to reevaluate the outdated firm market transmission assumptions used in the 2019 Second
Amended IRP; however, the structure of the issued RFP did not provide the Company the
opportunity to assess the most up-to-date resource costs from the market and to fully identiff all
least-cost feasible resources.
CITY OF BOISE CITY'S FORMAL COMMENTS - 3
7. If the Commission acknowledges the Dece,mber 31,2025, exit date of Valmy Unit 2, or
an earlier date, the Company will have a capacity deficit of 134 MWs of firm generation.
Application at 5. Boise City recommends the Commission direct the Company to issue an AS-RFP
to address this deficiency well in advance of the determined exit date. This would allow the
Company, stakeholders, and the Commission arnple time to evaluate actual costs submitted by
interested bidders and to compare new generation resources, firm market purchases, and
aggregated demand side resources, thereby allowing an informed decision regarding the least-cost,
least-risk option. The Company's resource decisions must be based on the best, most current, and
validated cost data available and not rely on data used in the IRP to forecast least cost, least risk
portfolios.
DATED this lTth day of August202l
Mary Grant
Deputy City Attorney
CITY OF BOISE CITY'S FORMAL COMMENTS .4
CERTIFICATE OF SERVICE
I hereby certifr that I have on this lTth day of August 2021, served the foregoing
documents on all parties of counsel as follows:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, lD 83702
j an.noriyuki@f uc. idaho. gov
Lisa Nordstrom
Idaho Power Company
PO Box 70
Boise, lD 83707
lnordstrom@idahopower. com
dockets@idahopower. com
Matt Larkin
Idaho Power Company
PO Box 70
Boise,ID 83707
mlarkin@idahopower. com
Matt Hunter
Deputy Attomey General
Idaho Public Utilities Commission
1 1331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
matt.hunter@puc. idaho. sov
Peter J. Richardson
Richardson, Adams, PLLC
515 N 276 St.
Boise, ID 83702
peter@richardsonadams. com
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
[e-mail]
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CITY OF BOISE CITY'S FORMAL COMMENTS - 5
Benjamin J. Otto
Idaho Conservation League
710 N. 6ft St.
Boise,ID 83702
botto@idahoconservation. ore
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, D 83707
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP
555 lTth Steet Suite 3200
Denvetr, CO 80202
darueschho@hollandhart. com
tnelson@hollandhart. com
aclee@hollandhart. com
el gareanoamari @hollandhart. com
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Mary Grant
Deputy City Attomey
CITY OF BOISE CITY'S FORMAL COMMENTS .6