20241003Compliance Filing 2023.pdf

—�IQAHO Ro
RECEIVED
MATTHEW T. LARKIN Thursday, October 03, 2024
Revenue Requirement Senior Manager IDAHO PUBLIC
[e-mail] UTILITIES COMMISSION
October 3, 2024
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-12-09
Compliance Filing — Boardman Power Plant Annual Review (2023)
Dear Commission Secretary:
Pursuant to Idaho Public Utilities Commission ("Commission") Order Nos. 32457
(Case No. IPC-E-11-18) and 32549 (Case No. IPC-E-12-09), attached for electronic filing
is Idaho Power Company's Boardman Power Plant Annual Review report for the year
ending 2023.
If you have any questions regarding this filing, please contact Regulatory
Consultant Courtney Waites at [phone] or [e-mail].
Sincerely,
Matthew T. Larkin
MTL:sg
cc: Dayn Hardie

a_10AW POWER.
BOARDMAN POWER PLANT ANNUAL REVIEW
FOR THE YEAR ENDING 2023
October 3, 2024
Pursuant to Idaho Public Utilities Commission ("Commission") Order Nos. 32457 (Case No. IPC-
E-11-18)and 32549 (Case No. IPC-E-12-09), Idaho Power Company("Idaho Power"or"Company") has
completed its review of the Boardman power plant ("Boardman") balancing account for 2023. The
purpose of this report is to provide the Commission with(1)an update of the Boardman balancing account
levelized revenue requirement and (2) a summary of activities that occurred at Boardman in 2023. The
Company is not recommending a rate change as part of this report.
L BACKGROUND
In February 2012, the Commission issued Order No. 32457 in Case No. IPC-E-11-18: (1)
accepting the Company's accounting and cost recovery plan for the early shutdown of Boardman and (2)
allowing the Company to establish a balancing account to track shutdown-related costs and benefits.
Following the Commission's order, on February 15, 2012, Idaho Power requested authority to increase
rates to begin recovery of the levelized revenue requirement associated with Boardman beginning June
1, 2012 (Case No. IPC-E-12-09). The Company proposed to replace the then current non-levelized base
rate revenue recovery associated with Idaho Power's existing investment in Boardman with a levelized
revenue requirement that was tracked in the Boardman balancing account, smoothing the revenue
requirement impacts of the early Boardman retirement over the remaining years of the plant's life and
providing for full recovery of Boardman-related costs by Boardman life end.
The levelized revenue requirement calculation included three components: (1) the revenue
requirement on existing investments as of May 31, 2012, prior to when the Boardman balancing account
was established; (2) the revenue requirement on incremental investments after May 31, 2012, after the
Boardman balancing account was established; and (3) the revenue requirement associated with future
decommissioning and offsetting salvage costs. The Commission issued Order No. 32549 on May 17,
2012, authorizing implementation of the cost recovery approach approved in Order No. 32457 and
increasing the Company's annual revenue requirement by $1,525,501 effective June 1, 2012, to reflect
in customer rates the new levelized Boardman revenue requirement of$5,174,794.
In accordance with Order Nos. 32457 and 32549, Idaho Power filed its Boardman Power Plant
Annual Review each year from 2012 through year-end 2018 without requesting to adjust rates. Then, on
October 17, 2019, Idaho Power filed an application in Case No. IPC-E-19-32 requesting to decrease
customer rates$1,058,225 effective January 1, 2020, to reflect the updated Boardman levelized revenue
requirement amount of$5,135,872. On December 26, 2019, the Commission issued Order No. 34519 in
Case No. IPC-E-19-32 approving the requested rate change. Because full depreciation of all Boardman
investments was to occur December 31, 2020, Idaho Power filed a request with the Commission to
remove the $5,135,872 in Boardman levelized revenue requirement amounts, less an adjustment of
$213,918 to reflect benefits of the U.S. Tax Cuts and Jobs Act of 2017 associated with Boardman that
will no longer exist, effective January 1, 2021. The Commission approved the Company's request with
Order No. 34885.
Boardman Power Plant 2023 Annual Review 1
Case No. IPC-E-12-09

II. SUMMARY OF ACTIVITIES IN 2023
Boardman produced its last megawatt of energy on October 15, 2020, at 12:56 PM. In the
Company's Boardman Power Plant Annual Review for the Year Ending 2020, Idaho Power provided the
updated quantification of the levelized revenue requirement based on actuals through the plant's end-of-
life. Therefore, no update to the levelized revenue requirement is necessary. The following summarizes
the activities related to cessation of coal-fired operations at Boardman that occurred in the year 2023:
Decommissioning and Salvage Costs
Idaho Power's initial estimate of the decommissioning and salvage costs was determined by
applying the Company's 10 percent ownership percentage to the decommissioning study performed by
Black & Veatch for Portland General Electric ("PGE") and completed in 2011. In 2018, PGE issued a
request for proposal seeking an Owner's Engineer to complete design and permitting work in preparation
for decommissioning activities, including capping the ash disposal area, demolishing structures at
Boardman (i.e., coal handling systems), remediating the coal yard, and other selective demolition work
across the site (i.e., support buildings, features supporting coal, coal handling, and coal ash handling).
The cost study prepared by AECOM Technical Services, the Updated Boardman Coal Plant
Decommissioning and Demolition Plan dated October 16, 2019, indicates a slightly higher
decommissioning cost forecast than the estimate prepared in 2011, however no changes were made to
the$5.4 million of decommissioning and salvage costs included in the levelized revenue requirement and
collected from customers.
Decommissioning and Demolition Activities
Decommissioning of the Boardman plant and separating of the facilities shared with PGE's Carty
generating station began on October 16, 2020. At this time the plant was taken to a cold, dark and dry
state in preparation for demolition until the first quarter of 2021 when decommissioning activities began.
In 2023, all remaining demolition across the site was completed,which included demolition of the crusher
building, turbine hall, ash handling systems, and peripheral warehouse buildings, as well as removal of
materials from the imploded boiler and stack.
Coal accumulations in the coal yard that had been inaccessible during coal reclamation were
removed for disposal; 11,550 tons of coal were removed from the coal yard.All the remaining fly ash that
was still in the storage dome, 8,030 tons, was removed from the dome for disposal. A total of 46,460 tons
of scrap was recycled, 21,100 tons of that scrap material having been removed in 2023. In addition, the
sewage lagoons were removed, graded and reseeded. A total of 2,106 tons of sediment from the settling
ponds was excavated for disposal, and the ponds were backfilled and surfaced with crushed concrete.
Disposal of coal, settling pond sediment, and fly ash exceeded initial estimates.
Site restoration was completed in December 2023. Demolition disturbance areas in the coal yard
and at the backfill source were graded and reseeded. All unpainted concrete from site structures, an
estimated total of 24,350 tons, was crushed on site and used to fill and surface the plant site. In all, the
total project recycling and reuse rate was 72.7 percent.
Boardman Power Plant 2023 Annual Review 2
Case No. IPC-E-12-09

Asset Purchase Agreement
Under the terms of the 1976 Agreement for Construction, Ownership and Operation of the
Number One Boardman Station on Carty Reservoir ("Ownership Agreement"), Boardman's end-of-life
requires the parties to enter into good faith negotiations on a decommissioning agreement and requires
the real property(e.g., land and water rights)to revert to PGE while crediting Idaho Power for its share of
the value associated with the real property. Consistent with these requirements, PGE and Idaho Power
have undertaken good faith negotiations and reached an agreement for the remaining Boardman assets
to be conveyed and assigned between PGE and Idaho Power, and as a result, on April 29, 2022, entered
into an Asset Purchase Agreement ("APA").
Under the APA, the following will occur: (1) Idaho Power agrees to convey and assign to PGE
100 percent of Idaho Power's ownership interests in and obligations of the Shared Facilities, the
Boardman real property (inclusive of water rights), and transmission lines in accordance with the Bill of
Sale, (2) PGE agrees to convey and assign to Idaho Power 100 percent of PGE's ownership interest in
and obligations under the Idaho Power tangible property, and (3) Idaho Power agrees to convey and
assign to PGE 100 percent of Idaho Power's ownership interest in and obligations under the PGE tangible
and intangible property. Payment to be made by PGE to Idaho Power for the conveyance and assignment
of these assets is summarized in Table 1 below. Note,the final total payment will be determined at closing
to reflect the then-current net book value of the transmission lines.
Table 1. PGE Payment to Idaho Power for the Conveyance and Assignment of Certain
Boardman Project Assets Between the Owners
Asset Description Agreed Purchase Price
Shared Facilities:
Carty Reservoir $0
Cohunbia River Intake $0
Existing Water Intake Structure $0
Potable Water System $0
Tower Road Rights $0
Wastewater Ponds $0
Coiunninications Equipment and
Housing $0
Boardman Real Property: $70,000
Boardman Project site
Ash landfill site
Intangible Property -Water Rights $2,300,000
Transmission Lines:
Boardman-Slatt Line Facilities * Prices will be adjusted to the $247,280.36
Dalreed Line Facilities then current net book value at time $55,135.10
Tangible Property
IPC Tangible Pro ei $0
PGE Tangible Property $0
Total TBD1
Boardman Power Plant 2023 Annual Review 3
Case No. IPC-E-12-09

Under Oregon statute,' PGE and Idaho Power must obtain approval from the Public Utility Commission
of Oregon for the conveyance of assets defined in the APA. Therefore, on June 30, 2022, the parties filed
a Joint Application for the sale and purchase of certain Boardman assets.2 The case is currently pending.
Boardman Balancing Account
The following summarizes Idaho Power's share of the decommissioning expenditures recorded
to the balancing account on a system basis as of December 31, 2023:
Decommissioning Costs $4,226,719
Materials and Supplies Write-off $ 967,717
Actual Decommissioning Expenditures $5,194,436
Remaining Forecast $ 156,892
Current Decommissioning Estimate $5,351,328
Decommissioning Costs Collected ($5,381,547)
Estimated Under(Over) Collection $ (30,219)
Collection of estimated levelized revenue requirement amounts ceased in 2020 and decommissioning
activities were nearly complete as of December 31, 2023. If the Joint Application is approved, Idaho
Power will record the gain associated with the disposition of the Boardman assets under the APA in the
Boardman balancing account.
III. CONCLUSION
The levelized revenue requirement following the 2020 annual review, when full collection of
Boardman levelized revenue requirement amounts occurred, demonstrated that there was a difference
in the annual revenue requirement which, along with the sum of the associated true ups, was negative
$40,669--a benefit to customers. Decommissioning activities have been completed and nearly all of the
decommissioning expenses have been paid. However, the anticipated gain associated with the APA is
yet to be recorded, therefore the revenue requirement true-up has remained in the balancing account.
Variations between actual and forecasted decommissioning expenses are being tracked in the Boardman
Balancing Account, which will be combined with the true-up and the gain associated with the APA, to
determine the final balancing account value once complete. The Company will continue to report the
balancing account activities to the Commission annually until all expenses have been paid and the
disposition of the Boardman assets has been completed, and will adjust customer rates in a future
proceeding, if necessary, ensuring customers pay no more or no less than actual Boardman-related
costs.
' Oregon Revised Statute ("ORS") 757.480 and ORS 757.485.
2 Docket UP 419 (filed June 30, 2022, and supplemented October 15, 2023).
Boardman Power Plant 2023 Annual Review 4
Case No. IPC-E-12-09