20230523Comments.pdf

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-01 Page 1
Idaho Conservation League, Comments
Marie Callaway Kellner (ISB No. 8470)
710 N 6th Street
Boise, ID 83701
[phone]
[e-mail]

Attorney for the Idaho Conservation League

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO
POWER COMPANY’S
APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVINENCE AND NECESSITY
FOR THE BOARDMAN TO
HEMINGWAY 500KV
TRANSMISSION LINE
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CASE NO. IPC-E-23-01

IDAHO CONSERVATION LEAGUE

COMMENTS

COMES NOW the Idaho Conservation League (“ICL”) with the following brief
comments on Idaho Power’s (“IPC” or “Company”) request for a Certification of Public
Convenience and Necessity (“CPCN”) for the Boardman to Hemingway (“B2H” or “line”)
transmission line. ICL offers qualified support for the line and recommends the Commission
approve the Company’s requested CPCN. In accordance with Commission Rules of Procedure,
IDAPA 31.01.01.203, and Order No. 35731 in the above captioned docket, ICL submits these
comments.
Comments
ICL commends the Company for past and ongoing line planning in recent Integrated
Resource Plan (“IRP”) cycles. This application, the attached testimonies, and both the
Company’s acknowledged 2021 IRP and in-process 2023 iteration adequately demonstrate that
the B2H line allows the Company to develop a de-carbonized least-cost, least risk resource
RECEIVED
2023 May 23, 4:17PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-01 Page 2
Idaho Conservation League, Comments
portfolio. Though we maintain questions as to whether the size and configuration of the line is
best optimized to reduce customer costs and promote non-carbon development relative to local,
mid-sized and distributed generation, we reserve those questions here in recognition that the
transmission capacity afforded by the B2H project benefits long-term grid stability and
renewable integration. Nor do these comments concern siting issues, which have been addressed
or litigated elsewhere. As modeled, the B2H line is broadly necessary for the company to address
projected load-growth, regional resource adequacy and diversity, and market integration. For
these reasons and those offered in the Company’s application, ICL recommends the Commission
grant the requested CPCN.
However, we urge the Commission to consider the Company’s contention that the B2H
line is necessary to develop a de-carbonized resource portfolio. From early stages of planning
and marketing materials to this current application, the Company has stated the B2H project will
provide transmission capacity needed to integrate increasing volumes of renewable power and to
meet its clean-energy goals. We believe the Company’s planning shows this is so. But, to the
best of our knowledge, we also note that the Company is under no obligation from this
Commission to procure clean or carbon free resources, despite continuing representation of this
intention in filings. To the extent that the Company justifies the line as a pathway to
decarbonization, we recommend that the Commission condition this CPCN on renewable
development or otherwise limit transmission of new thermal generation or operation of existing
resources past presently planned exit dates. As an alternative to a binding condition on the
requested CPCN, reporting on renewable resource development unlocked by the B2H line could
hold the Company to a degree of accountably on its contended purpose for the line.
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-01 Page 3
Idaho Conservation League, Comments
Finally, while we respect the Company’s proposal to defer ratemaking treatment to a later
docket, we note that this arrangement and its current minority ownership agreement exposes
Idaho based customers to potential risks of cost-overruns and delay. We encourage the
Commission to consider conditions or mechanisms to mitigate or cap financial risks to
ratepayers.

Conclusion
ICL recommends the Commission grant the Company’s requested CPCN for the B2H
project and consider conditions to ensure promised renewable development. B2H is necessary to
develop the Company’s preferred least-cost, least-risk portfolio and open credible pathways to
local and regional decarbonization. The Company’s application, public involvement, and long-
term IRP planning all support approval of a CPCN. Additionally, we encourage the Commission
to condition approval on clean energy commitments or reporting and limits to financial risks
passed on to rate payers.

DATED: May 23, 2023 /s/ Marie Callaway Kellner
Marie Callaway Kellner
Attorney for the Idaho Conservation League
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-01 Page 4
Idaho Conservation League, Comments
CERTIFICATE OF SERVICE

I hereby certify that on this 23rd day of May 2023, I delivered true and correct copies of
the foregoing COMMENTS to the following persons via the method of service noted:

/s/ Marie Callaway Kellner

Marie Callaway Kellner (ISB No. 8470)
Attorney for the Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
[e-mail]

Electronic Mail Only (See Order No. 35058)

Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
[e-mail]

Commission Staff
Michael Duval
Deputy Attorney General
Idaho Public Utility Commission
[e-mail]

Idaho Power Company
Donovan Walker
Timothy Tatum
P.O. Box 70
Boise, ID 37707-0070
[e-mail]
[e-mail]
[e-mail]

Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave, Suite 100
Pocatello, ID 83205
[e-mail]

Lance Kaufman
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]

Industrial Customers of Idaho Power
Peter Richardson
Richards, Adams PLLC
515 N. 27th Street
Boise, ID 83702
[e-mail]
Dr. Don Reading
280 S. Silverwood Way
Eagle, ID 83616
[e-mail]

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-01 Page 5
Idaho Conservation League, Comments

Micron Technology, Inc.
Jim Swier
8000 S. Federal Way
Boise, ID 83707
[e-mail]

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]

City of Boise
Ed Jewell
Darrell Early
Deputy City Attorney
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]

Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
[e-mail]

IDAHO PUBLIC UTILITIES COMMISSION, Case No. INT-G-22-7 Page 6
Idaho Conservation League, Petition to Intervene, December 15, 2022