CUB Advocates for You in Integrated Resource Plans
Posted on April 21, 2016 by Nadine Hanhan
Tags, Energy
As you know, CUB has the responsibility of intervening in integrated resource plan (IRP) proceedings on behalf of customers. In case you don’t remember, an IRP is a document that outlines how a utility intends to meet its resource needs in the best combination of cost and risk over the long term (usually around 20 years). In its IRP, the utility compares the results of various “resource portfolios” of potential resources (wind, coal, gas, energy efficiency, etc.) to determine which resource portfolio is the least-cost/least-risk path to meeting the demand of a utility’s customers. Utilities are required to submit one, and after they do, the Public Utility Commission “acknowledges” IRPs if they satisfy various conditions. But it is important to remember that acknowledgment does not equal pre-approval of a utility’s investments.
More recently, Oregon wrapped up a couple of IRPs—LC 59 for Cascade Natural Gas and LC 63 for Idaho Power Company. These dockets proved to be quite interesting for a number of reasons.
LC 59 – Cascade Natural Gas
CUB had a lot to say about this IRP! The main takeaway, though, is that CUB did not feel that Cascade demonstrated a solid analysis of how it was going to meet its load. The first reason for this is that Cascade asked for several extensions to even file its IRP and ended up filing its IRP well after the original due date. When it was finally filed, CUB felt that large portions of the analysis were “forecasting” events that had already happened or that were very soon about to take place (e.g., within a few months!). In addition, Cascade was very unclear about how it was planning on meeting its peak load demand (peak loads are times during the day that are high-usage times—so for example, at 7:00 in the morning when thousands of people wake up and turn on their heat). This adds up. Both gas and electric utilities have peak load demand. Because Cascade filed late, it was using older numbers, so CUB never got a clear picture of what the current peak load numbers were even going to be. To top it all off, when CUB asked for these numbers, we never got them! We submitted some information requests, but unfortunately, they were never answered.
These were just some of the issues CUB had to navigate throughout this IRP. Ultimately, the IRP was not acknowledged by the Commission. As we explained above, the Commission usually acknowledges these documents—sometimes with caveats. But in general, if a Company turns in a quality IRP with reasonable demonstration of how its resources will meet demand, CUB has observed that it is more common for the Commission to acknowledge plans than not. And even if the Commission acknowledges them, it can still “not acknowledge” certain elements of a plan. Thus, it says a lot that the Commission did not acknowledge Cascade’s IRP at all.
Thankfully, Cascade has committed to improving its analysis in the future. Cascade is expected to file a substantive IRP update by early next year, and you can expect CUB to be involved and keep you updated.
LC 63 – Idaho Power Company
CUB also had a lot to say about this IRP! The main takeaways in this docket are that CUB felt that 1) Idaho Power did not select the lowest-cost portfolio, and 2) Idaho Power could have invested in more energy efficiency.
Idaho Power has consistently met its energy efficiency targets over the years. This means that when it plans to execute a certain amount of energy efficiency (e.g. efficient lighting), it has consistently overshot its targets and is actually being more efficient than originally planned. While CUB thinks this is fantastic, we also think its “overshooting” is so high that it could stand to increase its targets and save customers more money! Not only does this contribute to a lower-cost portfolio, but it saves resources. It is CUB’s belief that the cheapest power plant is the one you don’t have to build, so when Idaho Power consistently goes beyond its goals, it can probably adjust its analysis a little more to have higher targets.
CUB’s second issue with this IRP is that Idaho Power did not select the lowest-cost portfolio. In short, the portfolio it selected was the eighth lowest cost—over $74 million more expensive than one of the lowest-cost portfolios. Other portfolios Idaho Power modeled were a bit more expensive (but still cheaper than the portfolio it chose) but could have retired coal plants early. As a result, we expressed our thoughts both in comments and in front of the Commission on March 24th.
We have yet to see the final order on this docket as it has not been filed yet, but CUB will be advocating for you in future IRPs—in Idaho Power cases and others!
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12/27/16 | 0 Comments | CUB Advocates for You in Integrated Resource Plans