20131030Snake River to IPC 1-8.pdf

(208) 343-7s00
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McDevitt & Miller LLP
Lauyers
420 Vest Bannock Stteet
P.O. Box ?"5fu83701
Boiserldaho 83702
October 30,2073
Chas. F. McDcvitt
DeanJ. [oe) Miller
Celeste K. Miller
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Idaho Public Utilities Commission
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SnaLe RiverAlliance
Deat Ms.Jewell.
Enclosed f61 filing ia the above matter, please 6nd thtee (3) copies of Snake Rivet Alliance's
Responses to the First Prcduction Requests of Idaho Powet Company.
Kindty retum a file stamFed copy to me.
VeryTnrlyYouts,
McDevitt & Mllet IIP
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Dean J. Miller (ISB No. 1968)
Chas. F. McDevitt (ISB No. 835)
Celeste K. Miller (ISB No. 2590)
MoDEVTIT & MILLER LLP
420 West Bannock Street
P.O. Box 256/.-83701
Boise, D 83702
Tel: [phone]
Fax: [phone]
joe@mcdevitt-mi1ler. com
chas@mcdevitt-mill er. com
ck@mcdevitt-miller. com
Attomeys for Snake River Alliance
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY FOR
THE INVESTMENT IN SELECTTVE
CATALYTIC REDUCTION CONTROLS
ON JIM BRIDGER UNITS 3 AND 4
Case No.IPC-E-13-16
SNAKE RIVER ALLIANCE'S
RESPONSES TO TIIE FIRST
PRODUCTION REQUESTS OF
IDAHO POWER COMPAI\IY
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In response to the First Production Request of Idaho Power Company ("the
Company'') to the Snake River Alliance ("SR4" or "Alliance") dated October 16,2013,
SRA herewith submits the following:
REOUEST NO. 1: Does Snake Riverbase its position or any opinions expressed
in this case on a study of energy efEciency potential within Idaho Power's service
territor52 If so, please provide a copy of the study and any supporting workpapers.
RESPONSE TO REOUEST NO. 1: The Northwest Power and Conservation
Council's Sixth Power Plan (www.nwcouncil.org), states explicitly the Pacific
Northwest, which includes Idaho Power's service territory, will be able to meet 85
sNArG RMR ALLTANCE'S RESPONSES TO THE FIRST PRODUCTTON REQITESTS OF
IDAHO POWER COMPAI\IY.I
percent of its new load growth over the next two decades with energy efEciency. The
plan states in part, atPg.4:
"The plan shows that a substantial amount of the gpwth in electricity demand
could be met by conservation. Portfolio model analysis shows that over 5,900
average megawatts of conservation are cost effective, double the amount in the
Council's 5ft Power Plan".
The 6e Plan, also states on Pg. 7:
"Significant reductions of carbon emissions from the Northwest's power systern
require reduced reliance on coal, which currently emits more than 85 percent of
the carbon dioxide from the regional power system. A carefully coordinated
retirement and replacement of half the existing coal-fired generation serving the
region with conservation, renewable generation, and lower carbon-emission
resources couldreduce average carbon emissions to 18 percentbelow 1990
levels."
The Alliance also relied on the 2012ldaho State Energy Plan, which identified
energy efficiency as ldaho's priority elechicity resource, regardless of the utility service
area. The 2}lZldaho Energy Plan can be found at:
http://www.energy.idaho.eov/enereyalliance/d/2012_idaho_enereyJlan_final_2.pdf.
The Alliance also relied on the March 15,2013,*2013lntegrated Resource Plan
Appendix B, Demand-Side Management 2012 Annual Report" that outlines Idaho
Power's planning with regard to the Company's "energy efficiency potential."
Specifically, the Alliance took notice for purposes of this testimony on Pg. 135 of Idaho
Power's 2013 Integrated Resource Plan Appendix Demand-Side Managernent20l2
Annual Report ("Energy Efficiency Potential Study) and on Pg. 136 ("Idaho Power's
Internal Energy Efficiency Commitmenf'). The report references "Achievable potential
across the residential, commercial, industrial, and irrigation sectors is projected to be
594,772 MWh, or 67.9 aMW tn20l7 and increasesto 234.4 alvfw by 2032. This
SNAKE RIVER ALLIANCE'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF
IDAEO POWER COMPAIIY.2
represents 4.3 percent of the baseline projection in20l7 and 12.2 percent n2032.8y
2032, achievable potential offsets 12.2 percnrrt of the growth in the baseline projection."
The response to this request was prepared by Ken Miller in consultation with
Dean J. Miller.
SNAKE RTVER ALLIANCE'S RESPONSES TO THE FIRST PRODUCTION REQTIESTS OF
IDAEO POWER COMPANY-3
REOUEST NO.2: Does Snake Riverbase its position or any opinions expressed
in this case on a study or analysis that evaluates dispatchable, baseload alternatives to Jim
Bridger power plant generation? If so, please provide a copy of the study or analysis and
any supporting workpapers.
RESPONSE TO REOUEST NO.2: The Alliance bases its position and
opinions expressed in this case in part on Idaho Power's *20L1IRP Update: Coal Unit
Environmental lnvestment Analysis For the Jim Bridger and North Valmy Coal-Fired
Power Plants" which can be found at:
(http://www.puc.idaho.sov/fileroorn/cases/elec/IPC/IPCEl l I 1/20130214IRP%20UPDA
TES.PDH and also on the Alliance's report and the research that contributed to the
report, "Kicking Idaho's Coal Habit: Charting a Cleaner Energy Fufure" August 2012,
which can be found at : http : //snakeriveralliance. ors/wp-
content/uploadsi20 I 2/084fi ckine-Idahos-Coal-Habit_Aug-22-20 I 2.pdf.
The Alliance's position and opinions expressed in this case are also based on
Redacted Exhibit 5A', which was originally filed as CONFIDENTIAL Exhibit 5 to Tom
Harvey's Direct Testimony on June 28,2013.
The response to this request was prepared by Ken Miller in consultation with
Dean J. Miller.
SNAKE RrvER ALLII\NCE'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF
IDAHO POWER COMPANY-4
REOUEST NO. 3: Does Snake River base its position or any opinions expressed
in this case on a study or analysis of resource altematives to the Jim Bridger power plant
that accounts for carbon? If so, please provide a copy of the study or analysis and any
supporting workpapers.
RESPONSE TO REOUEST NO. 3: Yes, the Alliance bases its position and/or
opinions in this case on Idaho Power's analysis referenced above, specifically Idaho
Power's Redacted Exhibit 5A, which was originally filed as CONFIDENTIAL Exhibit 5
to Tom Harvey's Direct Testimony on June 28,2013; CONFIDENTIAL Attachment 11 -
Resp to SRA's Req No. 2|_Final Draft 1I-5-12 Enviorn Analy 2011 IRP Upd.pdf, and
CONFIDENTIAL Attachment 4 - Response to StafPs Request No. 40_Navigant IPC-
201-20511 final.pdf at Pgs. 3, 6,9, and 10.
The response to this request was prepared by Ken Miller in consultation with
Dean J. Miller.
SNAKE RTyERALLIANCE'S RESPONSES TO THE FIRST PRODUCTTON REQUESTS OF
IDAIIO POWER COMPAI\IY.S
REOUEST NO. 4: In the absence of a carbon regulatory regime, what carbon
assumptions should be used to compare the Jim Bridger power plant to other generation
resources?
RESPONSE TO REOUEST NO.4:
The Alliance objects to this request based on RP 225 (a) which provides that
production requests should not be used to obtain statements of opinion not previously
written.
Without waiving that objection the Alliance states that the issue of carbon
assumptions and pricing is implicated in Case No. IPC-E-13-15, the Company's IRP
proceedings. SRA is a party to that proceeding and will file comments touching on
carbon assumptions according to the schedule established by the Commission.
The response to this request was prepared by Ken Miller in consultation with
Dean J. Miller.
sNArG RrVER ALLTANCE'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF
IDAHO POWER COMPAI{Y.6
REOUEST NO. 5: On page 3 of his testimony, Mr. Miller indicates that he has
prepared multiple reports for the Snake River discussing coal. Please provide a copy of
each report.
RESPONSE TO REOUEST NO. 5: The Alliance's reports and white papers
can be found at www.snakeriveralliance.org.
They include "Idaho's Dangerous Dalliance with King Coal" (September 2011);
"Kickinq Idaho's Coal Habit: Chartine a Cleaner Energv Future" (August 2012); "Puttinq
Down a Coal Plant: Retirine a Utility Assef'(Septe,nrber 2013).
The latter two documents were presented upon invitation to the Westem Energy
Policy Research Conference in Boise (2012) and in Portland (2013).
The response to this request was prepaxed by Ken Miller in consultation with
Dean J. Miller.
SNAKE RTyERALLIANCE'S RESPONSES TO THE FrRST PRODUCTTON REQUESTS OF
IDAEO POWER COMPAIYY.T
REOUEST NO. 6: On page 14 of his testimony, Mr. Miller indicates that the
cost of compliance for additional environmental regulation would be far greater than the
$130 million in costs attibuted to the selective catalytic reduction investment in this case.
Please provide a copy of the analysis that defines the regulations and associated costs that
defines the regulations and the associated costs that are included in his estimate.
RESPONSE TO REOUEST NO.6: The regulations referred to on Pg.14 of the
Alliance's testimony are cited on Pgs. 12-13 of the Alliance's direct testimony, and the
pertinent U.S. EPA fact sheets for the regulations are www.epa.gov/coalashrule;
www.epa. gov/ttn/.naaqs; and www.epa. gov/mats/actions.html.
ln addition, when analyzingthe above-referenced regulatory requirements that
Idaho Power will confront in order to keep the Bridger coal units in compliance with
federal regulations, the Alliance relied on Idaho Power's *20t1IRP Update: Coal Unit
Environmental Investment Analysis For The Jim Bridger and North Valmy Coal-Fired
Power Plants" Pgs. 8-10 ("Recent Environmental Regulations").
The response to this request was prepared by Ken Miller in consultation with
Miller.
SNAKE RTVERALLIANCE'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF
IDAHO POWER COMPA}[Y-8
REOUEST NO. 7: On page 8, lines 16-18 of his testimony, Mr. Miller mentions
CO2 controls that should be considered in the not-too-distant future. Please describe the
CO2 controls that should be considered in the not-too-distant future.
RESPONSE TO REOUEST NO. 7: On June 25,2013, one week before Idaho
Power filed its CPCN application to initiate this case, the federal executive branch
announced its "Climate Action Plan," which among other things presented a schedule
that directs the U.S. Environmental Protection Agency (EPA) to promulgate a regulation
to reduce greenhouse gas emissions from existing coal-fired power plants by June 2014
with a goal of completing approval of the rule by mid-2015.
The June 25 announcernent states:
"Power plants are the largest concentrated source of emissions in the United
States, together accounting for roughly one-third of all domestic greenhouse gas
emissions. We have already set limits for arsenic, mercury, and lead, but there is
no federal rule to prevent power plants from releasing as much carbon pollution
as they want. Many states, local govemments, and companies have taken steps to
move to cleaner electricity sources. More than 35 states have renewable energy
targets in place, and more than25 have set energy efficiency targets...
Despite this progress at the state level, there are no federal standards in place to
reduce carbon pollution from power plants. In April 2012, as part of a continued
effort to modernize our electric power sector, the Obama Administration proposed
a carbon pollution standards for new power plants. The Environmental Protection
Agency's proposal reflects and reinforces the ongoing trend towards cleaner
technologies, with natural gas increasing its share of electricity generation in
recent years, principally through market forces and renewables deployment
growing rapidly to account for roughly half of new generation capacity installed
in2012...
With abundant clean energy solutions available, and building on the leadership of
states and local governments, we can make continued progress in reducing power
plant pollution to improve public health and the environment while supplying the
reliable, affordable power needed for economic growth. By doing so we will
continue to drive American leadership in clean energy technologies, such as
efficient natural gas, nuclear, renewables, and clean coal technologies...
SNAKE RIVER ALLIANCE',S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF
IDAHO POWER COMPAI\IY.9
To accomplish these goals, President Obama is issuing a Presidential
Memorandum directing the Environmental Protection Agency to work
expeditiously to complete carbon pollution standards for both new and existing
powerplants. This work will build on the successful first-term effort to develop
greenhouse gas and fuel economy standards for cars and trucks. In developing the
standards, the President has asked the Environmental Protection Agency to build
on state leadership, provide flexibility, and take advantage of a wide range of
energy sources and technologies including many actions in this plan."
The Climate Action Plan can be found at:
http ://www.whitehouse. gov/energv/climate- chanse
The response to this request was prepared by Ken Miller in consultation with
Dean J. Miller.
SNAKE RrVER ALLIANCE'S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF
IDAEO POWER COMPANY-Io
REOUEST NO. 8: On page 15, lines l6-18 of his testimony, Mr. Miller states
that a new carbon regulatory regime would dramatically alter ldaho Power's resource
stack. Please provide the analysis for this statement.
RESPONSE TO REOUEST NO. 8: According to Idaho Power's 2013 IRP at
Pg. 105:
"Figure 9.7 shows that at a carbon adder of approximately $45 per ton in 2018,
the preferred resource portfolio would change from resource portfolio 2 to
resource portfolio 6. (In 2018, the IRP high-carbon scenario has a value of $35
per ton.) The supplemental carbon analysis shows that sufficiently high carbon
prices can affect Idaho Power resource acquisition decisions. Much lower carbon-
adder values can affect the daily resource dispatch decisions under certain
conditions as described previously in the Carbon Adder section."
This analysis by Idaho Power appears to indicate that an adjustment to the carbon
adder of a much smaller magnitude than suggested by the Alliance can impact Idaho
Power's resource stack in terms of resource dispatch. tn addition, if a new carbon
regulatory regime included emission constraints such as caps, it is logical to assume the
IRP resource stack would be altered to reflect new emission controls because there are
currently no means to reduce coal plant CO2 emissions.
The response to this request was prepared by Ken Miller in consultation with
Dean J. Miller.
DATED this 320 day of October,2}l3.
MCDEVITT & MILLER, LLP
Attorneys for Snake River Alliance
SNAKE RryER ALLIANCE'S RESPONSES TO TIrE FIRST PRODUCTION REQUESTS OF
IDAHO POWER COMPANY-II
CERTIFICATE OF SERVICE
I hereby certify that on,n. $fiu, of October ,2OI3,I caused to be served, via
the method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
P.O. Box 83720
Boise,ID 83720-0074
jjewell@puc. state.id.us
Kris Sasser
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W, Washingto n (837 02)
P0 Box 83720
Boise,ID 83 720-0074
[e-mail]
Lisa D. Nordstrom
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
lnordstrom@idahopower. com
Jennifer Reinhardt-Tessmer
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
j reinhardt@idahopower. com
Benjamin J. Otto
Idaho Conservation League
710 N. Sixth Street (83702)
PO Box 844
Boise,ID 83701
botto @idahoconservation.org
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SNAKE RrVER ALLIANCE',S RESPONSES TO THE FIRST PRODUCTION REQUESTS OF
IDAHO POWER COMPAIIY-I2
Peter J. Richardson
Gregory M. Adams
Richardson & Adams, PLLC
PO Box 7218
Boise,lD 83702
peter@richardsonandol ear-y. com
gre g@richardsonadams. com
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
dreadine@mindsprine, com
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SNAKE RTVERALLTANCE'S RESPONSES TO Tm FIRST PRODUCTTON REQTTESTS OF
IDAEO POWER COMPAI\TY-B