20210817Comments.pdf

Benjamin J. otto (ISB No. 8292)
710 N 6ft Street
Boise,ID 83701
Ph: [phone] x ll2
botto@idahoconseryation. org
Attomey for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPANY'S
APPLICATION FOR A
DETERMINATION
ACKNOWLEDGING ITS NORTH
VALMY POWER PLANT EXIT
DATE
tPC-E-2t-t2
ICL COMMENT
CASE NO. IPC-8.2I-I2
IDAHO CONSERVATION LEAGUE
COMMENTS
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The Idaho Conservation League recommends the Commission accept Idaho Power's
commitment to exit the North Valmy plant by 2025. Through both the Integrated Resource Plan
process as well as three dockets specifically examining the Valmy exit plan, Idaho Power has
established that exiting by 2025 appropriately balances the extra costs of fossil fuels against the
need to reliably serve load while transitioning to lower cost resources.
ICL has advocated for accelerating Idaho Power's exit from the Valmy plant since the
2015 Integrated Resource Plan showed that rapidly exiting Valmy would save customers money.
When acknowledging the 2015 Plan, the Commission encouraged Idaho Power to "more clearly
explain" the choice to pursue a2025 exit rather than earlier dates that could save additional
costs. Order No 33441 at 12. Building on this analysis, in May 2017 ICL,Idaho Power, PUC
Staff, and others entered into a Settlement whereby the Company would negotiate with the plant
co-owner, NV Energy, to exit the Valmy Units in 2019 and2025 respectively. The Commission
approved that Settlement, noting the accounting mechanism used for accelerating cost recovery
resulted in a mere l.l7% rate increase while avoiding future isks. Order No. 33771. In May
2019, the Commission found the Framework Agreement with NV Energy enabling Idaho Power
to exit Unit 1 in20l9 and Unit 2 no later thart2025 was "in the public interest" and "prudent and
commercially reasonable". Order No. 34349. To explore the potential for even more cost
savings, the Commission directed Idaho Power to continue to explore earlier exit dates. 1d
I
August 17,2021
The 20l9Integrated Resource Plan revealed the potential for additional customer savings
from exiting Valmy as soon as2022.ICL participated in that process which used an improved
planning method - capacity expansion software - to examine resource options. While that process
was technically challenging, the Commission acknowledged Idaho Power's substantial efforts to
refine and validate the analysis and results. Order No. 34959. The 2019 Plan showed that exiting
Valmy Unit2by 2022 instead of 2025 could save customers between $1.7 million and $2.9
million, depending whether the preferred portfolio included more gas plants or the Boardman to
Hemingway transmission line.l The 2019 IRP is the third consecutive resource plan to show that
exiting the Valmy plant as soon as practical is a least cost strategy and that Idaho Power has a
variety of options to maintain reliability while transitioning to clean energy.
While the overall record supports exiting Valmy earlier, ICL accepts Idaho Power's
proposal to exit Valmy Unit 2 no later than2025. We will continue to work with the Company as
they explore options to maintain system reliability while pursuing lower cost clean energy
resources. See Ellsworth Direct at 39. The clear trend in the industry is continually declining
prices for solar paired with storage - a likely option to replace Valmy, which IPC only forecasts
needing during the summer. Another emerging option is to refine and expand Demand Response
and other customer-facing programs because these more granular resource options may be a
better fit for Idaho Power's resource needs that change throughout the year. We look forward to
the responses to Idaho Power's outstanding All-Source Request for Proposals that will provide
the most relevant information about the cost and timeline for flexible, cost-efifective replacement
options.
Based on the 2015, 2017 , and 2019 Integrated Resource Plans; three dockets focused on
the Valmy plant; and Idaho Power's commitment to ongoing optimization, the Commission can
be confident that approving Idaho Power's final exit from Valmy by 2025 remains in the public
interest, prudent, and commercially reasonable.
ICL respectfully submits these Comments on the 17th day of August,2021.
/s/ Beniamin J Otto
Idaho Conservation League
1 See20lg IRP page ll7-llg,compare portfolios PGPC(I) and PGPC B2H (1) in Table 9.5 (Manual Portfolios
with Valmy exit in 2025) to Table 9.7 (Manual Portfolios with Vakny exit2022)
LPC-E-2[-12
ICL COMMENT 2
August 17,2021
CERTIFICATE OF SERVICE
I hereby certifr that on this 17th day of Augnst202l,I delivered true and correct copies
of the foregoing COMMENTS to the following persons via the method of service noted:
/s/ Beniamin J Otto
Idaho Conservation League
Electronic mail only (See Order 35058)
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
secretary@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Matt Larkin
lnordstrom@idahopower. com
mlarkin@idahopower. com
dockets@idahopower. com
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
dreading@mindspring. com
City of Boise
Mary Grant, Deputy City Attorney
Boise City Attorney's Office
[e-mail]
bo i sec ityatt omey @cityo fboi se. org
Micron Technologt, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Holland & Hart, LLP.
darueschhoff@hollandhart. com
tnelson@hollandhart. com
aclee@hollandhart. com
glgarganoamari@hollandhart. com
Jim Swier, Micron
[e-mail]
IPC-E-21-t2
ICL COMMENT J
August 17,2021