20190227ICL Comment.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY
MOUTAIN POWER,S PETITION FOR
AN EXTENTION TO FILE ITS 2OI9
INTEGRATED RESOURCE PLAN
CASE NO. PAC-E-Ig-OI
IDAHO CONSERVATION LEAGUE
COMMENT
The Idaho Conservation League ('ICL") supports Rocky Mountain Power's request to
amend the filing date for the 2019 Integrated Resource Plan ("IRP"). Because the IRP is an
important foundational analysis for resource decisions, ICL believes the public interest is served
by adjusting the filing date to allow for a full analysis of the issues.
Obviously one of the most important components of this IRP cycle is to assess the
economics of Rocky Mountain's coal fleet as well as ensuring system reliability. ICL is aware the
Oregon Public Utilities Commission Staffrecently informed the parties to Oregon's IRP review
process of this coal analysis is not available until May 2019.
ICL reviewed Order No. 30262 where the Commission established the last day of March
as the filling date for biennial IRPs. We note the consideration applied there were tied to Rocky
Mountain Power's need for additional time to analyze relevant issues. That same logic applies
here. ICL supports amending Order 30262 pursuant to the Commission's authority to do so
under Idaho Code 6l-624.
Instead of setting a date now, ICL proposes the Commission direct Ro.ky Mountain
Power to file the IRP when it contains a complete analysis of the relevant issues.
Respectfully submitted this 27'h day of February 2019,
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ICL COMMENT I
Benjamin J. Otto
Idaho Conservation League
February 27,2019
[[i1 l] $,li l*: 59
CERTIFICATE OF SERVICE
I certifr that on the 27th day of February,2019,I delivered true and correct copies of the
foregoing COMMENTS to the following via the service method noted:
Diane Hanian
Commission Secretary (Original and 7
copies)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail only:
Rocky Mountain Power
Yvonne R. Hogle
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
lvonne.hogle@pacifi corp. com
ted.weston@pacifi corp. com
Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE February 27,2019
Hand delivery: