CUB’s Comments on Idaho Power’s Integrated Resource Plan
Posted on November 7, 2013 by Nadine Hanhan
Tags, Utility Regulation
Last month, CUB submitted comments on Idaho Power’s Integrated Resource Plan (IRP). IRPs are 20-year planning documents that outline how a utility intends to meet its resource needs in a least-cost/least-risk manner. In the IRP, the utility compares the results of various combinations of potential resources to determine which one is the least cost/least risk path to meeting customer demand. The Commission “acknowledges” IRPs if they satisfy various conditions, but acknowledgment does not mean that the investments discussed in the IRP are approved. Acknowledgment simply means the plan seems reasonable at a given point in time.
In its comments, CUB discussed several key points pertaining to Idaho Power’s IRP. CUB had concerns about pollution control investments at Idaho Power’s Jim Bridger power plant. CUB believes that Idaho Power did not properly analyze potential phase-outs of coal units 3 and 4 at Jim Bridger. A phase-out is when a utility considers closing a coal plant early instead of extending the usage of the plant by adding expensive environmental compliance investments. CUB believes that the Company should have done more rigorous analysis to determine whether a phase-out was a viable option, as PGE did in the case of Boardman.
CUB also felt that Idaho Power overforecasted certain investments (i.e., planned too far ahead into the future). Idaho Power made projections for acknowledgment that stretch from 2024-2032. These are demand response capacity projections, and while they should be discussed in an IRP CUB does not believe that this kind of prediction is appropriate to include for acknowledgment.
Additionally, CUB is concerned by Idaho Power’s seeming request for acknowledgment of a transmission investment called Gateway West. This is a joint project with another utility, PacifiCorp. There are still many details that need to be worked out before the impacts of the entire Gateway project can be understood, and CUB feels that the whole project should not be included in the acknowledgment section of the IRP report.
Idaho Power also makes overly conservative assumptions about water and weather in the IRP. The IRP states that Idaho Power used worse-than-usual conditions in order to model its hydroelectric generation forecasts. While these should be included in an IRP report, CUB believes that Idaho Power relied too heavily on these conservative estimates in its report.
Finally, CUB had concerns about a jointly-owned power plant—North Valmy. North Valmy is co-owned between Idaho Power and another company called NV Energy. Earlier in 2013, NV Energy announced a plan to close North Valmy early. This was discussed in the IRP, but the final resource portfolio Idaho Power chose did not reflect the possibility of the North Valmy coal plant closure. Idaho Power’s 50% (284 MW) ownership of two coal units at North Valmy represents a significant resource. North Valmy Unit 1 is scheduled to close at the same time as PGE’s Boardman plant, in which Idaho Power also has a stake. Combined, these two closures represent a potentially large change to Idaho Power’s resource portfolio. CUB feels that such a large change should have been more substantially considered in Idaho Power’s IRP.
We are currently awaiting Idaho Power’s reply comments and will keep our readers informed as this IRP process progresses. Stay tuned to the CUB blog for updates!
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04/04/17 | 0 Comments | CUB’s Comments on Idaho Power’s Integrated Resource Plan