Comment on Idaho Power’s 20-Year Plan — Ken Miller

The Idaho Public Utilities Commission, which regulates Idaho Power and other investor-owned utilities, has received Idaho Power’s “Integrated Resource Plan” and related documents. Idaho electric utilities are required to prepare these “IRPs” every other year, and while the plans aren’t binding on the utilities, they provide a good picture of where your power might be coming from in the future. Idaho Power will hold open houses around its sprawling service territory in the coming weeks to answer questions and explain its plan to anyone who’s interested. The meetings will be announced shortly, after the PUC sets its schedule to review Idaho Power’s plan, and we’ll let you know when they are as soon as the schedules are set. In the meantime, the Commission will accept comments any time between now and the deadline it will announce shortly.

So what’s in this IRP and why should you care? For starters, you might want to let the company, the PUC and others know whether you’re satisfied with where your electricity comes from. For instance, is it OK with you that nearly half of your electricity comes from dirty out-of-state coal-fired generation plants, or would you like Idaho Power to more aggressively plan to dial down its reliance on those coal plants and the pollutants they emit in other states? Do you think your utility is doing enough to promote energy efficiency and conservation? Do you think it’s doing enough to put wind, solar, geothermal and other renewable energy resources on its system? How do you feel about the construction of big new transmission lines leading to generation resources and markets in other states? These big transmission lines can help bring wind and other clean energy from afar to where we live, but they’re also super-expensive and have environmental consequences.

The PUC doesn’t actually “approve” utility IRPs like this one. Instead, in regulatory parlance, the Commission decides whether to “accept” the plan. That’s because these plans serve mostly as a roadmap so the PUC knows how utilities plan to meet their future energy needs. In the case of Idaho Power, the new 2011 IRP was created with the advice of the company’s IRP Advisory Council, which includes a number of stakeholder groups, including the Snake River Alliance. However, the utility is free to select its own “preferred portfolio” to meet future energy needs, so the Alliance’s participation on the Council shouldn’t be viewed as an endorsement of Idaho Power’s plan. In fact, we have raised a number of concerns, including our concern that some Idaho utilities rely way too much on coal-fired power generation to provide your electricity when cleaner alternatives exist.

Reading the IRP is a great way to get a better feel for your utility’s planning and future electricity needs. It can get a little technical at times, but for the most part Idaho Power tries to couch its IRP in terms we can understand.

In this IRP, Idaho Power says it plans to meet its projected increase in electricity demand (its “load”) between 2011 and 2020 not only through efficiency and conservation measures, but also through construction of the so-called Boardman-Hemingway transmission line from Canyon County in Idaho up to the Columbia River Gorge.  That new transmission line, which has yet to be approved by a number of state and federal agencies, is designed to help Idaho Power and utilities in the Pacific Northwest move power back and forth to meet their respective needs. Idaho Power has selected new transmission over the next 10 years instead of building new generation plants. If the Boardman-Hemingway project is delayed or isn’t built, Idaho Power would probably rely instead on building additional natural gas generation plants.  The company’s plan for the 2021-2030 timeframe includes gas plants and some renewables such as solar, but given that’s a decade away and given how dramatically things can change, most of our attention with this plan is focused on the first 10 years.

The Snake River Alliance provided extensive comments to Idaho Power when the IRP was still in draft form and before it was submitted to the PUC. Some of those comments were incorporated in the final version. While we support much in this plan, we have concerns about a number of issues. Here are some of the key points in our comments to Idaho Power:

On the issue of greenhouse gas reductions and the operation of Idaho Power’s coal fleet, we told Idaho Power:

The Alliance appreciates that Idaho Power is tracking possible federal carbon cost and penalty trends. The draft acknowledges the September 2009 “guidelines to establish a goal to reduce the CO2 emissions intensity of the company’s utility operations” as a result of the May 2009 IDACORP shareholders vote. It appears, however, that the emissions have been partially stabilized rather than significantly reduced, although even that characterization is difficult given the short time-frame since Idaho Power announced its efforts to contain greenhouse gas emission intensities. Carbon reduction efforts to date may be due to a number of factors, including how various hydro conditions affect the operations of Idaho Power’s hydro generation and in turn how that affects the operations of the coal plants.  It is disappointing that the IRP does not better position the company for more ambitious carbon reduction plans. In fact, the carbon strategy seems predicated largely on changing hydropower operations, increased cloud seeding, water leases and the like. The draft acknowledges as much on P. 6:

This reduction in (CO2) intensity relative to the 2010 level reflects an increase in hydro generation as a result of the current water conditions, and reduced coal-fired generation.

That would seem to indicate that trends in emissions intensity are episodic and dependent in part on hydro conditions over which the company has little control. The numbers during low-water years would likely be far different if Idaho Power was forced to rely more on its company-owned thermal generation and market purchases.

There seems to be insufficient evidence that Idaho Power is interested in pursuing reduced operations of the coal fleet with a goal of reducing greenhouse gas emissions (as opposed to reducing coal operations coincident with times of high hydro production)…

…The Alliance continues to be concerned whether Idaho Power’s IRP reflects the risks we believe are associated with what seems to be a business-as-usual approach to the operations of the 1,100MW of coal-fired generation in which the company has an interest. Idaho Power in 2009 took a hands-off approach to whether the Boardman coal plant should be decommissioned early, even though it and its customers had a direct financial interest in the plant’s future. The same approach seems to have been taken with regard to Bridger and Valmy. We acknowledge that Idaho Power does not control whether its Wyoming and Nevada coal assets are decommissioned or retrofitted and in what time-frame. But that does not mean Idaho Power cannot exhibit more of a leadership role in what is now a region-wide drift away from coal-fired power plants in favor of efficiency, renewables, and even gas.

It took until this IRP to acknowledge – and plan for – what was viewed regionally as the inevitable early decommissioning of Boardman. We see no signs that Idaho Power (or PacifiCorp or Nevada Power) is preparing for or even contemplating an early retirement of Bridger or Valmy. We are particularly troubled with the observation that “even though coal-fired power plants require significant capital commitments to develop, coal resources take advantage of a low-cost fuel and provide reliable and dispatchable energy. Coal supplies are abundant in the Intermountain Region and are sufficient to fuel Idaho Power’s existing plants for many years to come.” (P. 49).

We note that plant modifications required to meet air-quality standards for Boardman are scheduled for 2011, 2014, and 2018, while modifications at Bridger are scheduled for 2015, 2016, 2021 and 2022 (P.68). These modifications are enormously expensive, and customers will be saddled with a continuing investment in an unsustainable resource…”

And on the question of how the IRP treats renewable energy:

“It is noteworthy that Portfolio 1-3 for the first 10 years of the planning period contemplates no acquisition of new renewable energy resources beyond contractual obligations to enter into agreements with Qualifying Facilities. However, recent events at the PUC would seem to significantly reduce the chances of that occurring during this planning period. While there is geothermal, solar and small hydro in Portfolio 2-6, we consider those mostly placeholders that signal the company’s willingness to acquire new renewables of undetermined nature. Still, the draft IRP contains only 162MW of planned renewables acquisition. We are concerned that the proposed 2030 fuel mix (P. 7) contains only 7 percent wind, 3 percent geothermal, and 1 percent solar…”

We’re happy to provide the full text of the Alliance’s comments to Idaho Power to those interested in receiving them. Simply e-mail Energy Program Director Ken Miller.

There’s enough in this plan that almost any reader will find something to support – or oppose. We encourage you to dive in and give it a look, and then come up with your own conclusions as to whether your utility is reflecting your priorities when it comes to where your energy comes from. So jump in, give it a look, and give them a piece of your mind.

Idaho Power’s IRP and supporting documents can be found at the PUC website and then going to “File Room” and then “Electric Cases” and then scrolling down to IPC-E-11-11. You can submit comments to the PUC by clicking the “Comments and Questions about a Case” icon and typing or pasting in your comments there.You can also visit Idaho Power’s IRP page to learn more about the company’s IRP process.