20230525Comments.pdf

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 1
CASE NO. PAC-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: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR A
CERTIFICATE OF CONVENIENCE AND
NECESSITY AUTHORIZING
CONSTRUCTION OF THE BOARDMAN-
TO-HEMMINGWAY 500-KV
TRANSMISSION LINE PROJECT
CASE NO. PAC-E-23-01

IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.’S COMMENTS

COMES NOW Idaho Irrigation Pumpers Association, Inc. (“IIPA”) and pursuant to Order
No. 35726, herein provide its comments in support of Rocky Mountain Power’s (“RMP”)
Application, as follows:
Background
Nearly one-third of IIPA’s members are RMP customers. As customers, IIPA’s primary
interest in this docket is to ensure that RMP provides safe, reliable, and low-cost energy. A
portion of IIPA’s members also provide valuable demand response service to RMP. IIPA’s
secondary interest in this proceeding assesses the impact of B2H on RMP’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 RMP’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 25, 4:59PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 2
CASE NO. PAC-E-23-01

RMP’s filing asserts that B2H provides a benefit for service of Oregon load. The extent to which
these benefits are experienced by Idaho customers are largely dependent on multi state
jurisdictional treatment and are not addressed by IIPA in these comments. Beyond the need to
serve Oregon load, IIPA believes that B2H could provide value generally to Idaho customers.
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

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 3
CASE NO. PAC-E-23-01

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
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.
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 of
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.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 4
CASE NO. PAC-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.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 5
CASE NO. PAC-E-23-01

RMP 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 or
wind capacity, and purchasing low cost emitting capacity. RMP can accomplish this while
simultaneously reducing its own carbon footprint.
To see this, suppose that RMP 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 RMP and lowers RMP’s total power costs.
Suppose that RMP further sells 100 MW of clean capacity (i.e. hydro or geographically diverse
wind and solar)2 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 RMP’s carbon
footprint.3
Increased System Reliability
RMP is facing a capacity shortage as peak demand grows and coal fired generation
reaches end of life. B2H will support RMP’s system reliability. RMP’s solution to its energy
shortage includes new solar generation. However, RMP is already experiencing the
consequences of non-geographically diverse solar generation. RMP’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.

2 PGE’s action item 4 includes pursuing capacity contracts in bilateral markets.
3 Assuming 100 hours of capacity service and 0.5 MTCO2E per MWh, this is approximately 50 MTCO2E.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 6
CASE NO. PAC-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
RMP. RMP 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 RMP’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 RMP’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 RMP.
Market access reduces the number of times per year the irrigation demand response
program is called on. IIPA expects that increased market access will reduce the need to regularly
curtail irrigation customers. Many current participants in the irrigation demand response program
face substantial crop damage if curtailment occurs too regularly. A preferred outcome for IIPA is

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 7
CASE NO. PAC-E-23-01

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. 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 RMP
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.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 8
CASE NO. PAC-E-23-01

DATED this 25 day of May, 2023.
ECHO HAWK & OLSEN
_____________________________________
ERIC L. OLSEN

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 9
CASE NO. PAC-E-23-01

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 25th 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:

Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Chris Burdin, Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
[e-mail]

U.S. Mail
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Overnight Mail
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Electronic Mail (Email)

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

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Electronic Mail (Email)

Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
[e-mail]

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Mark Alder
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
[e-mail]

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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S COMMENTS – Page 10
CASE NO. PAC-E-23-01

John Hutchings
Carla Scarsella
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
[e-mail]
[e-mail]

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Katherine McDowell
Adam Lowney (ID #10456)
McDowell Rackner & Gibson PC
419 SW 11th Avenue, Suite 400
Portland, Oregon 97205
[e-mail]
[e-mail]

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Thomas J. Budge
Racine, Olson PLLP
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
[e-mail]

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Brian C. Collins
Greg Meyer
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]
[e-mail]

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_____________________________________
ERIC L. OLSEN