Draft Sixth Power Plan Comment

Comments to the Northwest Power and Conservation Council on Draft Sixth Power Plan by Snake River Alliance November 6, 2009 On behalf of the Snake River Alliance, its membership and its Board of Directors, please accept the following comments on the Northwest Power and Conservation Council’s Draft 6th Power Plan. My name is Ken Miller, and I am the Clean Energy Program Director for the Snake River Alliance. I also currently serve as Chair of the NW Energy Coalition, although these comments are submitted on behalf of the Alliance. The Snake River Alliance is an Idaho-based non-profit organization established in 1979 to address Idahoans’ concerns about nuclear safety issues. In early 2007, the Alliance expanded the scope of its mission by launching its Clean Energy Program. The Alliance’s energy initiative includes advocacy for renewable energy resources in Idaho; expanded conservation and demand-side management programs offered by Idaho utilities and the Bonneville Power Administration; and local, state, regional, and national policies and initiatives that promote sustainable energy policies. The Alliance is pursuing these programs on behalf of its members, many of whom are customers of Idaho’s regulated utilities and also Idaho’s many municipal and cooperative utilities. We congratulate the members and staff of the Power Council for your extraordinary work on this Power Plan. We were strong supporters of the 5th Plan as well, as it took significant steps to propel our region toward a sustainable and affordable energy future. We were particularly pleased with the ambitious energy efficiency goals set forth in 5th Plan – goals the region embraced and exceeded well ahead of schedule. We believe the draft 6th Plan’s efficiency goals are equally ambitious, but also equally attainable. The fact that our region can meet most of our new load through energy savings is remarkable and a testament to our collective commitment to a clean energy future. That commitment was underscored in the Council’s recent report on the region’s amazing efficiency accomplishments during 2008. In addition, the promise of meeting the balance of our new load through renewable energy is equally welcome as we continue to transition to a new clean energy economy. While we believe the targets set forth in the Draft 6th Plan will likely be exceeded given our region’s history with conservation programs, and also that the targets could reasonably be raised, at a minimum we urge the Council to stand firm against any attempt to reduce the proposed targets. We also note that if the Council were to adopt a scenario in which the proposed targets were to be met at an accelerated rate, the region would realize significant energy cost savings. Energy efficiency is the cornerstone of the Alliance’s energy program, but climate issues such as greenhouse gas emissions are thoroughly intertwined in our region’s energy resource decisions. While Idaho has not established carbon reduction targets and is not a full member of the Western Climate Initiative, the other three states in our region have committed themselves to reaching their targets. It is imperative that we act not just to stabilize carbon emissions from our electricity generation, but to actually reduce those emissions. This is where we believe there is still room for improvement in the Draft 6th Plan. We believe the Council should factor the true environmental costs of resources in its resource recommendations. In so doing, the Council can send unmistakable signals to our utilities that continued reliance on coal fired generation at today’s levels is not sustainable from an environmental standpoint, or from a risk and economic standpoint. Most of us believe that some form of carbon regulation, whether through a tax or trading mechanism, is inevitable either through regional or federal action or both. It is therefore critical that we as a region prepare for carbon constraints. The sooner we begin planning for that eventuality, the better off we’ll be by embracing even more affordable energy efficiency and clean resources. It is a moral imperative as well as an economic one. As with setting bold efficiency goals, setting equally ambitious carbon reduction goals is critical to our region. Many of our utilities – and certainly those here in Idaho – pay very close attention to the Council’s Power Plans and look to those plans for guidance as they construct their conservation programs and develop their respective integrated resource plans. Among many other things, that means setting a realistic placeholder for the inevitable federal carbon cost and factoring that cost into resource decisions. Idaho Power, for instance, is considering calculating a $43 per ton carbon adder (with an annual escalator) into its risk analysis. While that amount may not immediately affect decisions on which resources to dispatch and in what sequence, a significant carbon price will begin to do so. There is simply no way to obtain meaningful greenhouse gas emission reductions while keeping the region’s existing coal fleet intact. Here in Idaho, our state’s largest electric utility says it will respond to its shareholders’ demands by beginning to reduce its carbon emissions. Even though Idaho has no greenhouse gas reduction targets, Idaho Power has announced plans to reduce its CO2 emissions intensity to 2005 levels by 2010-2013. If a utility like Idaho Power, which relies on coal for 40 percent or more of its generation, can make this commitment, then surely the Council, with its impressive record of environmental stewardship, can plot a course to do the same. We were heartened to note that the Council is heeding the sentiment, expressed in overwhelming numbers at its public hearings across the region, and has asked staff to propose an approach to analyzing the least cost strategy to meet a specific carbon emission goal. The memorandum prepared by staff in advance of the Council’s coming Portland meeting is a good beginning toward filling what we view is a big hole in the Draft Plan. We’re encouraged that the Council now recognizes the need to more thoroughly address this issue, but we remain only cautiously optimistic that the final Plan will include concrete measures to reduce emissions. Importantly, we believe the Plan must more thoroughly analyze the issue of retiring coal plants. We understand the Council has no authority to decommission generation resources, but we also understand that the region’s existing coal fleet is the elephant in the Draft Plan. As the Council is aware, the fate of the Boardman plant is an issue of much discussion, and utilities are considering their options as they weigh whether to invest more than $600 million on emissions upgrades (but not for CO2 reductions) or to plan for other options to replace power from that plant. More information from the Council via the Power Plan could very well help inform decisions by these utilities. We agree with and support two recent studies – Bright Future and The Power of Efficiency – conducted by the NW Energy Coalition that illustrate how our region can wean itself from its dirty coal plants, restore our endangered salmon runs, electrify our future vehicle fleets, and develop our rich renewable energy resources while still maintaining our affordable and reliable electric power system. While not all of these measures will be easily attainable, they are nonetheless still attainable. Our region is the national leader in advancing clean energy policies that are affordable and sustainable. Adopting a Power Plan that addresses not only energy efficiency but also the region’s unnecessary generation-related carbon emissions is essential. Respectfully submitted, Ken Miller Snake River Alliance Box 1731 Boise, ID 83701 (208) 344-9161 kmiller@snakeriveralliance.org