20110712ICL Comments.pdf

Benjamin Otto
ISBNo.8292
710 N 6th Street
PO Box 844
Boise) ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservation.org
RECEIVED
ZOIl JUL II PM 4: 48
Attorney for Idaho Conservtion Legue
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFCORP DBA )
ROCKY MOUNAIN POWER)S 2011 )
INTGRATED REOURCE PLA )CASE NO. PAC-E-11-10
COMMENTS OF THE IDAHO CONSERVATION LEAGUE
The Idaho Conservation League submits to following comments on Rocky Mountan
Power's (RMP) 2011 Integrated Resource Plan. As described in further detail below) ICL
applauds RMP)s treatment of demand side resources) but has serious questions about both the
substance and proces of this IRP. Because of these failures of both substance and proces) ICL
believes the Commission should defer accepting this IRP until furter details are available.
RMP)s treatment of demand side management (DSM) options provides a model this
Commission should require of all Idaho utilties. RMP divides DSM into four clases based on
resource characteristics. i By focusing on resource characteristics) instead of specific programs)
this analytcal model moves DSM closer to equal footing with traditional supply side resources.
For example) when considering supply side resources a utilty considers factors such as the need
for energy or capacity) the relative reliabilty) the range of costs within each resource ty) and the
time needed to acquire the resource. Based on these factors a utilty may choose a peakg gas
turbine or a baseload geothermal resurce. Further) the utility makes a preliminary choice on the
size and specific technology) e.g. an aeroderivative SCCT or a frame SCCT. This analytica
process allows the utility to consider a wide range of potential resources without relying on a
specific project. If the IRP determines a specific resource tye is the preferred option then RMP
issues a request for proposas to choose the specific project.
i See IRP at 90 (clas 1) diect load control) class 2) energ effciency) clas 3, rates and pricing,
clas four consumer education).
ICL Comments on 2011 IR 1 July 11,2011
By clearly delineating DSM options into four clases based on resource characteristcs
RMP ca apply this same analytcal process to DSM resources. For example, RMP fed various
resources into their system optimizer model, including different classes of DSM. The model
output revealed that acquiring up to 1200 MW of cost -effective energy effciency programs (clas
2 DSM) is the least cost, least risk option. RMP plans to acquire these new resurces through
current and future RFP processes.2 As a result, RMP has identified a clear goal for future DSM
acquisition and can use the RFP process to find the most innovative and cost effective manner to
achieve this goal.
In addition to this analytical model, RMP also directly considers, as clas 3 DSM
resources, the impact that rate design and other pricing options ca have on their electca
system. While ICL acknowledges that projecting energy savings attributable to rate designs can
be diffcult, RMP should be rewarded for makng this effort. By considering the entire range of
resources from traditional generation to energy effciency and on through to rate designs that
drive behavior changes RMP is undertakng true integrated resource planning.
Despite RMP's laudable treatment of DSM, the 2011 IRP fails to adequately analyz
several other resource ty. Most criticaly, RMP asumes unabated coal plant use despite
requiring bilions of dollars in pollution control upgrades. True integrated resurce planning
should at least consider whether committing to these expenditures is the least cost, least risk
option for meeting energy demand. Moreover, RMP has this information since RMP witnes
Chad Teply briefly discussing considering plant retirement instead of pollution controls in the
company's recently fied rate cae, PAC-E-II-12. The rate case is the appropriate foru to
determine whether specific investments are recoverable. But the IRP proces is the appropriate
forum to consider all options to meeting RMP's resource needs, including changes to exsting
resources.
Further, as explained in the attached letter from public interest energy advoctes from
'across the utilty's servce territory, the public did not have a meaningful chance to participate in
developing this IRP. While RMP did convene public meetings, the attached letter highlights
RMP's failure to incorporate public comments and factual information. This failure of
meaningf public parcipation is highlighted by RMP's fiing on June 28th of a 50 page
addendum consisting of detailed technica analysis. Detailed examples, and the resulting impacts
2 See Action Item 6, IRP at 16.
ICL Comments on 2011 IRP 2 July 11,2011
on the IRP analytical results, will be further iluminated through the more robust regulatory
review processes undertaken in Utah and Oregon. This Commission should wait for the beefit
of these revew proceedings before issuing any final order on this IRP.
Because these failures of substance and process this Commission should defer issuing any
final decision on this 2011 IRP until the results of the regulatory review proceses in thes states
concludes. Deferrng any final order on this IRP wil not negatively affect RMP because the
Idaho revew process does not result in any specific endorsement or approval of any of the action
items. In accepting RMP's 2009 IRP this Commission stated CCit is the ongoing planning process
that we acknowledge, not the conclusions or results.))3 RMP failed to use complete information
and provide for meaningfl public paricipation, thus this Commission should not accept the
2011 IRP as the result of an adequate ongoing planning process.
WHEREFORE ICL respectfuy requests the Commission consider the foregoing comments.
DATED this 11th day ofJuly 2011 .
R7 submitted#~Bei1 J. Otto
Idaho Conservation League
3 PacifiCorp 2007 IRP Acceptance of Filg, PAC-E-Q9-Q6, at 10 (September 15, 2009).
ICL Comments on 2011 IRP 3 July 11, 2011
CERTIFICATE OF SERVICE
I hereby certify that on this 11 th day of July, 2011 true and correct copies of the foregoing
COMMENTS OF IDAHO CONSERVATION LEAGUE were delivered to the following persons
via the method of servce noted:
Hand delivery
Jean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilties Commission
427 W. Washington St.
Boise, ID 83702-5983
Email only:
Ted Weston, Idaho Regulatory Afairs Manager
Daniel Solander, Reguatory Counsel
PacifiCorp/dba Rocky Mountai Power
201 S. Mai St., Suite 2300
Salt Lae City, UT 84111
Ted Weston~pacificorp.com
Daniel.Solande~acificorp.com
lb'~
Benjamin J. Otto
Idaho Conservation League
ICL Comments on 2011 IRP 4 July 11,2011
July 11, 2011
Utah Public Service Commission
Wyoming Public Service Commission
Idaho Public Utilities Commission
Dear Commissioner:
We acknowledge the challenges inherent in producing a document like PacifiCorp's
2011 Integrated Resource Plan. The company's multi-state obligation coupled with the
nation's uncertain and changing energy future make the IRP an arduous-though never
more essential-exercise. As groups who work in each state in PacifiCorp's Rocky
Mountain Service terrtory, we are deeply invested in being constructive partners,
encouraging the company to provide energy that is reliable, clean, and affordable. It is in
the spiri of this partership that we are wriing to express grave and uniform concern
regarding PacifiCorp's recent 2011 Integrated Resource Plan (IRP).
We believe the defects in this IRP-both with the document itself as well as the process
that produced it-are so fundamental as to threaten the integrit of the entire proc.
We, the undersigned groups, have therefore decided to take the unprecedented step of
wriing to each state Commission in PacifiCorp's Rocky Mountain service terrory to
express our concerns.
PacifiCorp's 2011 IRP has four profound weaknesses. First, the company's analysis
artifcially disadvantages clean, renewable energy by assuming restrctvely high prices
for solar and storage resources, and by assuming equally unrealistic capacit values for
wind resources. Company offcials proved unwiling to provide justification for these
assumptions.
Second, the company ignored a great deal of factal input that would have led to les
objectionable approaches. Dozens of comments were filed - and disregarded - which
urged the company to incorprate up-to-date cost estimates that show rapidly
decreasing costs for renewable energy.
Third, PacifCorp plans to charge ratepayers $4.2 bilion for polluton control retrofi to
its aging coal fleet, with no evidence that this is a wise course. Some of these plants
pre-date the EPA and most are older than the Clean -Air Act Amendments, wih which
they struggle to comply. The IRP neglects to analyze which plants can be ecnomically
retrofited to protect human health and comply with regulation, and which can ultimately
be phased out and replace with renewable energy.
Finally, PacifiCorp ignores the wide-ranging health damages caused by coal plant
pollution. These damages are significant, valued at $1.6 billon from Utah plants alone.
These damages represent the impact of fine. particles, oxides of nitrogen and sulfur, and
other pollutants on the health and lives of ratepayers and citizens across PacifCorp's
service area.
While the IRP is designed to provide a forum for making intellgent, transparent, and
balanced energy decisions to provide reliable power while also protectng ratepayers,
the present IRP does not do that: The IRP commits ratepayers to fund increasingly
expensive retrofits for an outdated and dirt coal fleet, without considering other cost-
effective, non-polluting alternatives, such as wind power. While such a plan might
protect PacifiCorp executives and shareholders, it is unfair to ratepayers, who by 2023
are projected to be paying $360 millon a year for retrofits. The IRP fails to analyze the
prudence of those costs.
We, the undersigned member organizations, are commited to working in our indivdual
states to ensure that future electricity planning processes are more balanced,
transparent, and informed. The current IRP process - both ineffecive and inaccible
- must change, incorporating reforms such as: better mechanisms to consider public
comment in a timely and meaningful way, before key and irreversible decisions are
made; responding to data requests in a timely and transparent manner; accounting for
the substantial and well-understoo health damages from sources such as coal plant
pollution; and a comprehensive evaluation of the risks to ratepayers of investing in coal
plant pollution abatement systems rather than non-polluting renewable energy
alternatives.
Ratepayers in our respective states stand at the threshold of a decade of being forced
to pay unprecedented rate increases - mostly to fund slight pollution reductions at aging
coal plants. We deserve to know whether our collective investments could be better
used to build non-polluting power generation like wind, solar, and geothermaL. To this
end, we ask the agencies responsible for reviewing the IRP to not acknowledge
PacifiCorp's 2011 IRP.
Thank you for your consideration of this important matter.
Sincerely,
Chrlstopher Thomas
Executive Director
HEAL Utah
Salt Lake Cit, Utah
"'vlnUnd
Direcor
Powr Rive Basin Rero Co
Sheran, WY
Benjamin J. Oto
Energy Associate
Idaho Conservation League
Boise, Idaho
Gloria D. Smith
Senior Staff Attorney
Sierra Club National
San Francisco, California