Draft Sixth Power Plan Comment

11/5/2009 Comments on 6th Power Plan by the Idaho Consumer-Owned Utilities Association: Dear Council Members, The Idaho Consumer-Owned Utilities Association (ICUA) represents 14 rural electric cooperatives and 8 municipalities in Idaho. Combined, ICUA member utilities serve over 120,000 power consumers in our state. On behalf of our 120,000 member consumers we thank the Council for, in our perspective, a generally reasonable and thoughtful plan that fulfills its regional electric power planning purpose by providing guidance and information in meeting the future power needs of the region in a cost-effective and responsible manner. In addition the Plan recognizes the need for flexibility by explicitly allowing resource acquisitions that meet utility needs, even if those acquisitions differ from the general regional Plan. ICUA is very pleased the Council included Chapter 6a, on Transmission in the Plan. Our member utilities across the state are dealing with the challenges you lay out in Chapter 6a. In addition, we believe the Plan should encourage and reinforce joint transmission planning and joint investment in transmission infrastructure. Toward that end, our Association has been engaged in consistent dialogue with the Bonneville Power Administration (BPA) regarding possible opportunities for BPA to “buy-in” to transmission projects in Idaho and across the Northwest. ICUA will keep the Council apprised of our progress with BPA. Of critical importance to ICUA members specifically and to the region generally, the Plan provides an excellent discussion of the Hydro System. The Plan describes how important the hydro system is in keeping our carbon emissions low and notes the significant increase in carbon emissions that would occur should hydro generation be reduced due to dam removal. And the Plan describes how the great flexibility of the hydro system is used to integrate other carbon-free, renewable resources. ICUA believes that the costs associated with fish and wildlife mitigation, the hydrosystem’s ability to integrate renewables and the carbon reduction that the dams provide are critical to include in the Plan, as these elements inform decisions and model assumptions. The plan should further study the benefits of the four Lower Snake dams considering the growing need and desire for carbon free energy resources. We do have some concerns the conservation targets in the Plan are too high. ICUA recognizes that conservation is typically the lowest cost resource and generally believes it is the best way to meet growing loads. We appreciate the Council’s recognition of the inherent uncertainty in the amount of conservation that can be accomplished in the next 5 years by providing a range of conservation savings instead of a specific target. However, we still have concerns over the availability of certain measures, the lead time to develop and implement programs to distribute the measures, and the effect of current economic conditions. ICUA members believe in the consistent professional work of the Council as well as your willingness to accept our input and listen to our concerns. We thank you for the opportunity to comment on the 6th Power Plan. --Idaho Consumer-Owned Utilities Association