20230523Formal Comments.pdf

JAYME B. SULLIVAN BOISE CITY ATTORNEY
Darrell Early ISB No. 4748 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]S Facsimile: [phone] Email: [e-mail]
[e-mail] [e-mail] Attorneys for Intervenor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE BOARDMAN TO HEMINGWAY 500-KV TRANSMISSION LINE
Case No. IPC-E-23-01 CITY OF BOISE CITY’S FORMAL COMMENTS
The city of Boise City (“Boise City”) submits these formal comments on the application
submitted by Idaho Power Company (“Company”) for a certificate of public convenience and
necessity (“CPCN”) for the Boardman to Hemingway 500-kV transmission line (“B2H”). Boise
City, 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. 35731, issued on April 10, 2023, hereby
submits its formal written comments and states as follows:
BOISE CITY RECOMMENDS THE COMMISSION ISSUE A CPCN FOR B2H
CITY OF BOISE CITY’S FORMAL COMMENTS - 1
RECEIVED
Tuesday, May 23, 2023 2:21:15 PM
IDAHO PUBLIC
UTILITIES COMMISSION
1. Boise City recommends the Commission grant the Company a CPCN for B2H, acknowledging
B2H will allow the Company to meet its summer 2026 capacity deficit and will likely facilitate
the future development of least-cost, least-risk portfolios. Boise City further recommends the
Commission consider conditioning the CPCN with additional requirements, based on the
unique attributes of this regional transmission line, to ensure risks to customers are
appropriately mitigated and that the benefits of B2H are proportionally received by customers.
2. Boise City believes the Company has reasonably demonstrated both a need for new resources
to meet capacity deficits and, through robust analysis over many integrated resource plan
(“IRP”) cycles, that B2H is necessary for the development of least-cost, least-risk energy
portfolios to reliably serve customer demand over time. The company’s 2021 IRP,
acknowledged by the Commission in Order No. 35303, identified more than $265 million in
cost-savings in the preferred portfolio with B2H compared to the best performing portfolio that
does not include B2H as a resource. See Idaho Power 2021 Integrated Resource Plan at 81,
available at
https://docs.idahopower.com/pdfs/AboutUs/PlanningforFuture/irp/2021/2021%20IRP_WEB.
pdf (last visited May 17, 2023). In addition to the results of the 2021 IRP, the Company’s
planning processes have consistently identified B2H as a cost-effective resource since 2009.
Application at 4. In the context of the continually growing capacity needs faced by the
Company, the robust economic modeling, alternative portfolios considered, sensitivity
analysis, and diverse scenarios tested in each IRP, the Company has sufficiently justified that
B2H is likely a least-cost resource required to meet customer demand.
RECOMMENDED CONDITIONS FOR A CPCN
CITY OF BOISE CITY’S FORMAL COMMENTS - 2
3. In evaluating the Company’s application for a certificate for B2H, Boise City recommends the
Commission consider the fundamental differences of a transmission resource compared to a
generation resource and whether additional conditions are appropriate to mitigate risk to
customers. Constructing B2H does not guarantee access to resources or immediately come
with firm market purchase agreements, even though B2H is modeled in the IRP inclusive of
market purchases the Company expects it to facilitate. Ellsworth, Di at 81. Additionally,
growing the Company’s reliance on market purchases will increase customers’ exposure to
market price volatility. This is significantly different from the Company’s recent solar and
storage resource procurement and associated applications for CPCNs. Lastly, while ratemaking
treatment is not directly at issue here, overall B2H costs are significant and the Company’s
45.45% ownership stake could create long-term affordability risks if costs continue to escalate
or the project is not delivered on time.
4. Boise City supports the Company’s application based on the assumption that B2H will deliver
on its promise to be a “Clean-Energy Superhighway.” B2H has the potential to facilitate access
to clean, low-cost energy resources and further hasten the transition away from high-cost,
volatile, fossil resources. To ensure this potential is realized, Boise City recommends
transparent, clear, annual reporting of resources delivered to the Company’s system via B2H
as a condition of the CPCN. This additional reporting would allow customers and stakeholders
to ensure B2H is indeed facilitating the “year-round access to reliable, clean, low-cost market
energy purchases from the Pacific Northwest” once operational. See Application at 3. This
reporting could be submitted for Commission review annually as a part of the Power Cost
Adjustment (“PCA”) filing, assuming costs associated with market purchases or other
contracted resources will be passed on to customers through the PCA.
CITY OF BOISE CITY’S FORMAL COMMENTS - 3
5.Given the significant ownership stake in the project, the Company’s lead role in constructing
the transmission line, and the yet-to-be-determined ratemaking treatment of B2H, the
Commission should consider proactive measures to ensure ratepayers are not ultimately
responsible for a project where costs unreasonably outweigh the direct, long-term benefits to
the Company’s system.
RECOMMENDATIONS SUMMARY
6.Boise City appreciates the significant progress made to date by the Company to ensure resource
adequacy and access to clean, affordable, and reliable regional resources. B2H is a key
component of regional decarbonization and has the potential to facilitate the buildout of new
renewable resources and strengthen the Western grid through resource diversity and reliability.
Specific to Idaho Power’s system, Boise City believes B2H can deliver cost-effective, reliable,
clean electricity and meet the Company’s near-term resource needs. Boise City recommends
the Commission grant the Company’s application for a CPCN for B2H and consider conditions
on project costs and reporting requirements as needed to ensure the transmission line produces
maximal benefit for Idaho Power’s system and customers.
DATED this 23rd day of May 2023.
______________________________ Ed Jewell Deputy City Attorney
CITY OF BOISE CITY’S FORMAL COMMENTS - 4
CERTIFICATE OF SERVICE
I hereby certify that I have on this 23rd day of May 2023, served the foregoing documents
on all parties of record as follows:
Commission Secretary Idaho Public Utilities Commission
11331 W. Chinden Blvd., Ste. 201-A Boise, ID 83714 [e-mail]
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Electronic
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Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Ste. 201-A
Boise, ID 83714
[e-mail]
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Idaho Power Company
PO Box 70 Boise, ID 83707 [e-mail] [e-mail]
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Other: __________________
Idaho Power Company PO Box 70 Boise, ID 83707 [e-mail]
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Industrial Customers of Idaho Power Richardson Adams, PLLC
515 N. 27th St.
P.O. Box 7218 Boise, ID 83702 [e-mail]
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280 S. Silverwood Way
Eagle, ID 83616 [e-mail]
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CITY OF BOISE CITY’S FORMAL COMMENTS - 5
Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen
Holland & Hart LLP 555 17th Street, Suite 3200 Denver, CO 80202 [e-mail] [e-mail]
[e-mail] [e-mail]
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Micron Technology, Inc. 8000 South Federal Way
Boise, ID 83707 [e-mail]
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Echo Hawk & Olsen PLLC
505 Pershing Ave. Ste 100 P.O. Box 6119 Pocatello, ID 83205 [e-mail]
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2623 NW Bluebell Place
Corvallis, OR 97330 [e-mail]
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Brad Heusinkveld Idaho Conservation League 710 N. 6th Street Boise, ID 83702
[e-mail]
[e-mail]
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________________________________
Michelle Steel, Paralegal
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