20220512Comments.pdf

JAYME B. SULLIVAN BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446 Deputy City Attorney BOISE CITY ATTORNEY’S OFFICE 150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500 Telephone: [phone] Facsimile: [phone] Email: [e-mail]
[e-mail]
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY’S APPLICATION TO EXPAND OPTIONAL CUSTOMER CLEAN ENERGY
OFFERINGS THROUGH THE CLEAN
ENERGY YOUR WAY PROGRAM
Case No. IPC-E-21-40
CITY OF BOISE CITY’S COMMENTS
The city of Boise City (“Boise City”) submits these formal comments on the application
submitted by Idaho Power Company (“Company”) for authority to expand and implement optional
customer clean energy offerings through the proposed Clean Energy Your Way program. Boise
City submits these formal comments pursuant to Rule 203 of the Commission’s Rules of
Procedure, IDAPA 31.01.01.203, and pursuant to the Notice of Modified Procedure, Order No.
35338, issued by the Commission on March 9, 2022.
1.Boise City recommends the Commission approve the Company’s application and
authorize the Company to (1) rename Schedule 62 “Clean Energy Your Way Program,”
and (2) maintain and expand procurement options for renewable energy certificates (RECs)
CITY OF BOISE CITY’S COMMENTS - 1
RECEIVED
2022 May 12, PM 1:30
IDAHO PUBLIC
UTILITIES COMMISSION
under Clean Energy Your Way – Flexible, and (3) establish a regulatory framework for
Clean Energy Your Way – Subscription that is available to all customers, and (4) offer the
Clean Energy Your Way – Construction option for Special Contract and Schedule 19
customers, and (5) procure resources to meet customer’s clean energy preferences through
these offerings outside of the current competitive bidding requirements. Boise City
commends the Company on its responsiveness to customer clean energy needs, identifying
opportunities for all customers to participate in the clean energy transition, and
collaboration with interested customers while developing potential offerings.
2. Boise City believes the Clean Energy Your Way – Subscription and Construction programs
are designed in a way that mitigates any harmful cost shifting to non-participating
customers while allowing customers with expressed clean energy preferences or corporate
commitments to procure clean energy. Additionally, Boise City believes the proposed
revisions to Schedule 62 would positively impact the Company’s identified clean energy
procurement needs. Boise City supports the Company’s proposed process requiring each
Clean Energy Your Way - Construction arrangement to be individually designed, within
the broader framework, to meet the customer’s needs while holding non-participating
customers harmless and to be individually presented to the Commission for approval.
Williams, Di. at 49-50.
3. Recognizing this is only Phase I of authorization for the Clean Energy Your Way –
Subscription offering, Boise City recommends the Company work to structure the program
management and staffing requirements to minimize administration and marketing expenses
while continuing to identify clean energy resource(s) for the initial offering. While Boise
City anticipates more than sufficient interest in the initial Clean Energy Your Way -
CITY OF BOISE CITY’S COMMENTS - 2
Subscription offering, reasonable pricing that fairly compensates customers for the
capacity and energy benefits their participation provides all Idaho Power customers will be
critical to the program’s success. Additionally, Boise City recommends the Company
identify and propose a mechanism that makes Clean Energy Your Way – Subscription
participation feasible for customers with low incomes, with specific attention to customers
eligible for the Low-Income Home Energy Assistance or Weatherization Assistance
Programs, in the Company’s Phase II request to the Commission.
4.For both the proposed Clean Energy Your Way – Subscription and – Construction
offerings, the Company seeks relief from the established competitive bidding requirements
for resource procurement. Application at 16-17. Boise City supports this specific request
and recommends the Commission exempt resources procured for these voluntary programs
from the current requirements under Commission Order No. 32745 that follow Oregon
Public Utility Commission resource procurement rules. Boise City believes this limited
exemption is appropriate because the costs of the resources will be individually and
voluntarily accepted by participating customers in both the Subscription and Construction
offerings and because the Company commits to make a showing to the Commission that
the Subscription program resource was competitively procured in Phase II of the Clean
Energy Your Way – Subscription approval process. Williams, Di. at 36.
5.As a customer with expressed time-bound clean energy preferences, and in recognition of
the range of aggressive clean energy commitments from corporate energy buyers in the
City of Boise and across the Company’s service area, Boise City recommends the
Company move as expeditiously as possible to procure resources to meet customer needs,
present Clean Energy Your Way – Construction arrangements to the Commission, and
CITY OF BOISE CITY’S COMMENTS - 3
continue to work collaboratively with stakeholders throughout the development and filing
of Phase II of the Clean Energy Your Way – Subscription offering to ensure the proposed
programs in this application are maximumly impactful.
6.In conclusion, Boise City commends the Company on its responsiveness to customer
feedback on existing clean energy options and the development of a new voluntary program
that promotes additionality, affordability, and system benefit. Boise City recommends the
Commission approve the Company’s application to expand optional customer clean energy
offerings and establish Clean Energy Your Way. Boise City looks forward to working with
the Company and stakeholders on program implementation.
DATED this 12th day of May 2022.
______________________________ Ed Jewell, Deputy City Attorney
CITY OF BOISE CITY’S COMMENTS - 4
CERTIFICATE OF SERVICE
I hereby certify that I have on this 12th day of May 2022, served the foregoing documents
on all parties of counsel as follows:
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Boise, ID 83702 [e-mail]

Personal Delivery
Facsimile
Electronic Means w/ Consent
Other: __________________
Alison Williams Idaho Power Company 1221 W. Idaho St. (83702)
PO Box 70 Boise, ID 83707-0070 [e-mail] [e-mail] [e-mail]
[e-mail]
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Facsimile
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Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714) PO Box 83720 Boise, ID 83720-0074 [e-mail]
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Emma E. Sperry Idaho Conservation League 710 N. 6th St.
Boise, ID 83702
[e-mail] [e-mail]
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Richardson, Adams, PLLC
515 N 27th. St PO Box 7218 Boise, ID 83702
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CITY OF BOISE CITY’S COMMENTS - 5
Dr. Don Reading 6070 Hill Road
Boise, ID 83703
[e-mail]
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Vicki M. Baldwin
Parsons Behle & Latimer 800 W. Main St., Suite 1300 [e-mail] [e-mail]
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Walmart Inc. [e-mail]
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Courtney White
Clean Energy Opportunities for Idaho Inc. 3778 Plantation River Dr., Suite 102 Boise, ID 83703 [e-mail] [e-mail]
U.S. Mail
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Law for Conscious Leadership 920 N. Clover Dr. Boise, ID 83703
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________________________________ Michelle Steel Paralegal, City of Boise
CITY OF BOISE CITY’S COMMENTS - 6