20200805Sierra Club Comments.pdf

August 5,2020
To: Idaho Public Utilities Commission via email, [e-mail]
From: Lisa Young, on behalf of the Idaho Sierra Club, 503 W. Franklin St., Boise, ID 83702
Re: PAC-E-19-16
As the Director of the Idaho Sierra Club, I respectfully submit these comments on behalf of our
chapter. We maintain contact with over 300 supporters in the PacifiCorp service territory. Based on
customer interests expressed through those interactions and given our knowledge of energy matters,
we submit these comments regarding PacifiCorp's IRP.
First, we acknowledge and appreciate the resources PacifrCorp employed to conduct its coal unit
assessments, which identified several near-term economic coal retirements.
The following four sections describe our concerns and recommendations, which are re-capped at the
end:
l. Idaho customers should not subsidize the continuation of uneconomic coal units.
Idaho Power demonstrates earlier exits from Jim Bridger units are economically beneficial.
Jim Bridger Coal Unit Retirement Dates
PacifiCorp IRP 2023 2028 2037 2037
Idaho Power IRP 2022 2026 2028 2030
Idaho Power is a 40 percent co-owner of Jim Bridger. The Idaho Power 20l9IRP specifically
assessed the early retirement of all four Jim Bridger units in timeframes similar to that of
PacifiCorp, and a few that were faster. Idaho Power found that the fastest exit scenario, with the full
closure of Jim Bridger prior to 2030, saved Idaho consumers over $80 million relative to a scenario
most similar to PacifiC orp's (2022,2026, and2034,respectively). I
Idaho Power explains that while "the 2017 IRP preferred portfolio included early exits from two
units at Jim Bridger in2028 and2032... the 2019 IRP analysis has determined it is economical to
exit all four coal units early at Jim Bridger."2
Idaho Power's amended IRP found that coal plants did not serve customers' best interests. As noted
by the utility:
The Amended 2019 IRP also indicates favorable economics associated with Idaho Power's
exit from five of seven coal-fired generating units by the end of 2026 and exit from the
remaining two units at the Jim Bridger facility by the end of the 2020s.3
t Idaho po*e.20l9 IRP, Amended January 31,2020. Pages t09-l I l. Assessment of Bridger Scenario 4 (55,996A78,000 NPV)
against Scenario 3 ($6,076,723,000 NPV) in Portfolio 16 under base planning assumptions.
2 Idaho Power 2019 IRP, Amended January 3l,2020.Page 12
3 Idaho Po*er 201 9 IRP, Amended January 3l,2020,Page 5
PacifiCorp's assessment of coal resources should be informed by Idaho Power's analysis. We are
concerned that PacifiCorp has potentially missed details critical to the long-term risks faced at Jim
Bridger; risks that have been recognized by Idaho Power.
all future IRPs.
Commission to ensure that PacifiCorp does not impede other utilities serving Idaho from
exiting coal to best serve their ldaho customers.
2. Securitization of non-economic should be investisated. not excluded.
PacifiCorp has excluded opportunities to refinance the remaining plant balance of its existing coal
fleet. PacifiCorp's neighboring states in New Mexico and Colorado have recently enacted
securitization legislation, allowing the remaining balance at existing coal plants to be refinanced
upon retirement. Utah could enact similar legislation. If PacifiCorp were to harness such legislation,
it would improve the ratepayer basis for retiring non-economic plants while minimizing impacts to
PacifiCorp's bottom line. Instead, PacifiCorp elected to assume, across the board, that the utility is
entitled to full recovery of and on remaining plant balance at otherwise non-economic coal plants.
costs when non-economic coal plants retire, and to include that potential in its evaluation of
coal retirements.
3. There is a disconnect between transmission and seneration resource Action Plan items
Although the generation resource section of PacifiCorp's Action Plan section does not commit to
any particular resource builds, the transmission section is much more specific. The most significant
transmission action item in PacifiCorp's IRP is a plan to construct and place in service the 400-mile,
500-kilovolt Gateway South transmission line by December 2023. The problem with PacifiCorp's
transmission action items is that they are tied to notional generation resources that the Company is
not committed to developing and for which the Company has not established a tangible need.
PacifiCorp's Action Plan unless they are contingent on the Company's all-source RFP
process identifying those expenditures as part of a least-cost resource plan.
4. PacifiCorp should remove coal-favoring biases
The forces favoring clean energy are gtowing, not waning. The risks associated with coal
generation are growing, not declining. As utilities update their analyses to more accurately reflect
costs and risks, the economics of coal units decline. It is difficult for customers in the Rocky
Mountain Power territory to watchdog the Company's complex analyses, yet the people who dig
deep uncover nuanced biases that favor coal, such as overly optimistic assumptions on future coal
prices or under-stated assessments of risk factors.
Company be more diligent in removing coal-favoring biases from its analyses and to be
resourceful and perseverant in pursuing options to accelerate its exit of coal.
Recap of Recommendations
Idaho ratepayers should not be burdened with subsidizing the uneconomic continuation of coal
resources.
future IRPs.
Commission to ensure that PacifiCorp does not impede other utilities serving Idaho from exiting
coal to best serve their Idaho customers.
Action Plan unless they are contingent on the Company's all-source RFP process identifying
those expenditures as part of a least-cost resource plan.
costs when non-economic coal plants retire, and to include that potential in its assessment of
coal retirements.
and to be resourceful and perseverant in pursuing options to accelerate its exit of coal.
Thank you for considering our comments,
Lisa Young
Director, Idaho Sierra Club
I aclvtowledge that submitting a comment in on open case constitutes a public record under ldaho Code 74-
101(l 3) and that all information I provide in this comment is available for public and media inspection. My
comment may be reviewed by the utility. Our headquarters in ldaho are in the ldaho Power senice area.