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PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 1
CASE NO. IPC-E-23-01
Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: (208) 478-1624
Facsimile: (208) 478-1670
Email: elo@echohawk.com
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
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
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.’S COMMENTS
COMES NOW Idaho Irrigation Pumpers Association, Inc. (“IIPA”) and pursuant to Order
No. 35731, herein provide its comments in support of Idaho Power Company’s (“IPC”)
Application, as follows:
Background
Nearly two-thirds of IIPA’s members are IPC customers. As customers, IIPA’s primary
interest in this docket is to ensure that IPC provides safe, reliable, and low-cost energy. A portion
of IIPA’s members also provide valuable demand response service to IPC. IIPA’s secondary
interest in this proceeding assesses the impact of B2H on IPC’s demand response program. IIPA
is generally supportive of the B2H transmission project. In these comments IIPA provides
observations on the regional energy characteristics that support approval of the project. However,
IIPA has not performed a comprehensive analysis and validation of IPC’s models and analysis of
project design or economics. Given the limited scope of IIPA’s review of this project, IIPA’s
comments should be understood to be supplemental to the review of other parties.
RECEIVED
2023 May 23, 4:13PM
IDAHO PUBLIC
UTILITIES COMMISSION
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 2
CASE NO. IPC-E-23-01
Reduced Energy Costs
Oregon and Washington have recently enacted legislation that puts energy service in
those states on a path towards 100% non-carbon emitting energy service by 2030 to 2040. The
regional market ramifications continue to evolve. However, it is likely this legislation will
significantly increase the value of inter-regional transmission. This is because within localized
geographies renewable generation is highly correlated. As a result, each incremental tranche of
localized renewable generation provides declining load carrying capability. The figure below
illustrates the ELCC for Portland General Electric for incremental wind generation.
All wind geographies face declining ELCC as the total capacity additions increase.
However, wind located in Montana, Wyoming, and Offshore have nearly doubled the ELCC of
generation located in Washington and the Columbia Gorge, which is geographically close to
PGE. This is because PGE (and most other Pacific utilities) already rely on over 1 GW of local
wind generation while PGE has no Wyoming wind generation. The low ELCC offered by
incremental wind means that if Pacific utilities procure enough local renewable generation to
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 3
CASE NO. IPC-E-23-01
satisfy 100 percent of capacity needs, they will have surplus energy supply which is expected to
create periods of very low cost and economic energy. PGE’s preferred portfolio will generate 6
GWa of zero marginal cost energy in 2043 while PGE’s retail load only requires 3 MWa in that
year.1 Other Pacific utilities are planning similar buildouts of renewable energy and it is
reasonable to expect market pressures will drive down wholesale prices in Oregon and
Washington. This is consistent with IPC’s claim that B2H will allow access to cheap clean
energy.2
In addition to causing low wholesale energy market prices, IIPA expects Pacific carbon
standards will lead to substantial market capacity even in hours where local utilities face capacity
shortfalls. This is because the Pacific Northwest will have a large fleet of natural gas generators
that will be constrained from providing capacity service to local consumers due to carbon
restrictions. As Pacific Northwest utilities begin to approach the zero carbon emissions line,
existing gas generation facilities will be prevented from service capacity needs even in peak
hours. The figure below illustrates this by showing PGE’s plans to increase wholesale sales
related carbon emitting resources while simultaneously decreasing retail sales thereof.
1 This approximation is calculated from PGE’s 2023 IRP Tables 2 and 3 and Figure 42.
2 Application Page 3.
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 4
CASE NO. IPC-E-23-01
Note that after 2040 PGE’s retail customers will be served by 100 percent carbon free
energy while wholesale sales emissions will be higher in 2043 than in 2023, despite the closure
of PGE’s coal fleet in 2030 and despite the fact that PGE’s portfolio adds no carbon producing
generation in the planning period. Note also that PGE’s wholesale purchases of emitting
resources declines from 2 million MTCO2e to zero over the same time period. All of these
emitting resources will be available to serve capacity needs in states that do not have as strict
carbon standards as Oregon and Washington.
Coinciding with an increase in the availability of low cost clean energy and low cost
emitting capacity will be a shortage of non-emitting capacity. Recent heat domes in the Pacific
Northwest have illustrated the inability of wind to provide non-emitting capacity to the region.
Heat domes are driven by the absence of jet-streams and cause a negative correlation between
demand and supply of renewable energy. The 4-hour storage resources that utilities are planning
to procure are insufficient to outlast extended heat dome events. This will lead to an ongoing
struggle for non-emitting and reliable capacity.
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 5
CASE NO. IPC-E-23-01
IPC is well placed to take advantage of the Pacific Northwest’s aggressive carbon
legislation by securing low-cost energy when renewables are producing, selling clean hydro
capacity, and purchasing low cost emitting capacity. IPC can accomplish this while
simultaneously reducing its own carbon footprint.
To see this, suppose that IPC imports 100 MWa of clean energy from the Pacific
Northwest and uses this energy to offset 100 MWa of coal generation. This results in a reduction
of approximately 800,000 MTCO2e reduction for IPC and lowers IPC’s total power costs.
Suppose that IPC further sells 100 MW of clean capacity (i.e. hydro or geographically diverse
wind and solar)3 to the Pacific Northwest at a high price and purchases 100 MW of gas fired
capacity at a low price. This further reduces power costs and adds minimally to IPC’s carbon
footprint.4
Increased System Reliability
IPC is facing a capacity shortage as peak demand grows and coal fired generation reaches
end of life. B2H will support IPC’s system reliability. IPC’s solution to its energy shortage is
new solar generation. However, IPC is already experiencing the consequences of non-
geographically diverse solar generation. IPC’s capacity needs, net of renewable generation, are
driven by a small number of hot summer days. Due to heavy solar penetration this need is limited
to a few hours in the evening when air conditioning load remains high but solar generation drops
off. It is not cost effective to build a new capacity resource to satisfy a capacity need that only
occurs for a few hours each year. As noted above, transmission is essential to bring geographic
diversity to non-emitting generation resources.
3 PGE’s action item 4 includes pursuing capacity contracts in bilateral markets.
4 Assuming 100 hours of capacity service and 0.5 MTCO2E per MWh, this is approximately 50 MTCO2E.
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 6
CASE NO. IPC-E-23-01
Beyond the renewable resource diversity benefits, B2H enhances reliability by providing
access to a market that experiences peak demand in different seasons and times of day than IPC.
IPC is summer peaking while many Pacific utilities are winter peaking. The same policy goals
that are driving pacific utility transitions to zero carbon emissions will also drive heavy building
heat electrification. For example, Puget Sound Energy recently eliminated gas customer line
extension allowances to curb growth of residential gas customers. It is reasonable to expect that
the Pacific Northwest will continue to be winter peaking for the foreseeable future. The winter
peaking nature of Pacific states, combined with their abandonment of emitting capacity
resources, means that it is likely that market energy will be available to serve IPC’s summer
capacity needs.
When market energy is available, market access is one of the most reliable system
resources. Energy deliveries from firm market purchases are typically backed by a basket of
generation resources and rarely fail to deliver, while even the most reliable gas turbines are
subject to frequent planned and unplanned outages.
Positive Impact on Irrigation Demand Response
IIPA expects B2H to be complementary to IPC’s irrigation demand response program by
increasing market access. Increased market access has the potential to reduce demand response
curtailment hours, shift curtailment hours to more practical times of day, and increase value of
curtailments to IPC.
Market access reduces the number of times per year the irrigation demand response
program is called on. IIPA has observed increasing total hours of irrigation curtailment for
participants in IPC’s demand response program associated capacity shortages. IIPA expects that
increased market access will reduce the need to regularly curtail irrigation customers. Many
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 7
CASE NO. IPC-E-23-01
current participants in the irrigation demand response program face substantial crop damage if
curtailment occurs too regularly. A preferred outcome for IIPA is that the irrigation demand
service only provides emergency capacity service rather than regular capacity service.
Market access shifts time of day for irrigation demand response to preferrable times. IPC
recently requested to extend the hours of irrigation curtailment later into the evening. This is due
in part to solar resources providing reduced evening energy. B2H market access will increase
capacity resources in all hours of the day, not only during peak load. Further, this access will be
west of existing solar resources. Western solar resources generate at later hours than eastern
resources. IIPA expects both these factors will reduce the need for IPC to dispatch irrigation
curtailment in latter time blocks. This outcome is preferrable for many irrigators who face labor
and technical issues with late curtailments.
Market access increases the participation payments for demand response. The previous
discussion illustrates that Pacific states will face increasingly volatile market prices. To the
extent that irrigation curtailments occur when Mid-C prices are spiking, B2H may lead to higher
value for irrigation demand response.
Conclusion
IIPA’s general assessment of regional markets, and IIPA’s consultant’s familiarity with
Pacific clean energy plans, supports the finding that a Certificate of Public Convenience and
Necessity for B2H is in the public interest and should be issued by the Commission.
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 8
CASE NO. IPC-E-23-01
DATED this 23 day of May, 2023.
ECHO HAWK & OLSEN
_____________________________________
ERIC L. OLSEN
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 9
CASE NO. IPC-E-23-01
CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 23rd day of May, 2023, I served a true, correct and
complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to Intervene
to each of the following, via U.S. Mail or private courier, email or hand delivery, as indicated
below:
Donovan E. Walker
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
dwalker@idahopower.com
dockets@idahopower.com
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Timothy E. Tatum
Idaho Power Company
PO Box 70
Boise, Idaho 37707-0070
ttatum@idahopower.com
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Riley Newton, Deputy Attorneys General
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8, Suite 201-A
P.O. Box 83720
Boise, ID 83720-0074
riley.newton@puc.idaho.gov
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Michael Duval, Deputy Attorneys General
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8, Suite 201-A
P.O. Box 83720
Boise, Idaho 83720-0074
michael.duval@puc.idaho.gov
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
lance@aegisinsight.com
U.S. Mail
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Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 10
CASE NO. IPC-E-23-01
Peter J. Richardson
Richardson, Adams, PLLC
515 North 27th Street
Boise, Idaho 83702
peter@richardsonadams.com
U.S. Mail
Hand Delivered
Overnight Mail
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Dr. Don Reading
280 South Silverwood Way
Eagle, Idaho 83616
dreading@mindspring.com
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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
jswier@micron.com
U.S. Mail
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Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street Suite 3200
Denver, Colorado 80202
darueschhoff@hollandhart.com
tnelson@hollandhart.com
awjensen@hollandhart.com
aclee@hollandhart.com
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Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 North Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
ejewell@cityofboise.org
dearly@cityofboise.org
boisecityattorney@cityofboise.org
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PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 11
CASE NO. IPC-E-23-01
Wil Gehl
Energy Program Manager
Boise City Department of Public Works
150 North Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
wgehl@cityofboise.org
U.S. Mail
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Marie Callaway Kellner
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702
mkellner@idaho conservation.org
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Brad Heusinkveld
Idaho Conservation League
710 North 6th Street
Boise, Idaho 83702
bheusinkveld@idahoconservation.org
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_____________________________________
ERIC L. OLSEN