20210726Sierra Club 1-12 to IPC.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER POWER PLANT
CASE NO. IPC.E.2I.I7
FrRST SET OF PRODUCTION REQUESTS OF SIERRA CLUB TO
IDAHO POWER COMPANY
Sierra Club hereby serves its first set of production requests regarding the above-mentioned
docket. Sierra Club requests that Idaho Power Company provide responses as expeditiously as
possible, but not later than the deadline of 2l days, which is Ausust 13. 2021.
INSTRUCTIONS
Please provide copies of responses to the following contacts:
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Rose Monahan
Sierra Club Environmental Law Program
2101 Webster Street, Suite 1300
Oakland, CA946l2
[e-mail]
Ana Boyd
Sierra Club Environmental Law Program
2101 Webster Street, Suite 1300
Oakland, CA946l2
ana.b oy d@sierraclub. org
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Whenever possible, Sierra Club prefers to receive electronic copies of production
responses either by email or on CD.
Responses to any and all of Sierra Club's production requests should be supplied to
Sierra Club as soon as they become available to Idaho Power Company.
The requests herein shall be deerned to be continuing in nature and Idaho Power
Company is requested to supplement its responses as necessary and as additional
information becomes available.
In responding to each production request, please consult every document source which is
in your possession, custody, or control, including all documents in the possession of
experts or consultants.
For each response, identify the person who prepared the answer to the production request
as well as their position with Idaho Power Company or any Idaho Power Company
affiliate or parent.
Please reproduce the production request being responded to before the response.
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If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
If the responses include spreadsheet files, please provide those spreadsheet files rn
useable electronic Excel readable format.
In responses providing computer files, list the file names with cross-reference to the data
request, and if necessary to the understanding of the data" provide a record layout of the
computer files. Computer files provided with a response must be in or compatible with
the current version, or the immediately prior version, of Microsoft Office.
For each dollar amount provided in response to a discovery request please state if the
amount is in nominal or constant dollars and what years dollar
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In the Matter of ldaho Power Company's Application for Authority to Increase its Rates
for Electric Service to Recover Costs Associated with the Jim Bridger Power Plant
Case No.[PC-E.21-17
Sierra Club's First Set of Production Requests to Idaho Power Company
Jrily 23,2021
SC 1.
PRODUCTION REQUESTS
Provide electronic copies of all data requests and responses received from or sent to
other parties in this proceeding. If electronic copies are not available, please contact
counsel for Sierra Club to coordinate response. This is an ongoing request.
SC 2.Please refer to the Direct Testimony of Mr. Adelman at414-5:2. Please provide
complete, unredacted copies of the agreements referred to, specifically the Agreement
for Ownership of the Jim Bridger Project, the Agreement for the Construction of the
Jim Bridger Project, and the Agreonent for the Operation of the Jim Bridger Project,
as well as Amendments I through 9.
SC 3.Please provide complete, unredacted copies of the current fuel supply agreements for
the Jim Bridger power plant. If the Company does not have a fuel supply agreement
for the Bridger mine, please provide the most recent fueling plan for the Bridger
mine.
sc 4.Has Idaho Power evaluated whether securitizing its remaining debt on the Jim
Bridger plant would result in savings for the Company's customers when compared to
accelerated depreciation as proposed in this proceeding?
a. If so, please provide such analysis.b. If not, explain why not.
SC 5.Please provide any analysis conducted by or for Idaho Power, other than ldaho
Power's most recent IRP, evaluating whether exiting Jim Bridger earlier than the
dates currently proposed in the Company's Second Amended 20l9IRP would be
economically beneficial for Idaho Power's customers.
sc 6.Please refer to Mr. Adelman's Direct Testimony on pages 6 and7.a. Has Idaho Power evaluated the costs of installing SCRs on Bridger Units I
and2 if SCRs are required by the federal govemment? If so, please
provide such analysis.b. Did Idaho Power's modeling for its most recent IRP assume that SCRs
would or would not be required on Bridger Units I and2?c. If the answer to subpart (b) is that Idaho Power assumed that SCRs would
not be required, has Idaho Power completed any modeling assuming that
SCRs will be required? If so, please provide such analysis.
Please confirm whether Idaho Power has reached any partial, tentative, preliminary,
or final agreement with PacifiCorp that would permit the Company to exit from the
Jim Bridger plant in 2022 ltnit l),2026 (unit 2), 2028 (unit 3) and 2030 (unit 4).a. If any agreement has been reached, please provide a copy of the written
agreement or describe the agreement if such agreernent is not written;
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SC 7.
In the Matter of ldaho Power Company's Application for Authority to Increase its Rates
for Electric Service to Recover Costs Associated with the Jim Bridger Power Plant
Case No.LPC-E-21-17
Sierra Club's First Set of Production Requests to Idaho Power Company
Jnly 23,2021
If no agreement has been reached, please describe the current status of
ongoing negotiations with PacifiCorp.
SC 8.Please indicate whether Idaho Power and PacifiCorp have come to an agreanent on
an expected closure date for the Bridger coal mine.
SC9 If no agreement has been reached, please indicate when Idaho Power expects the
Bridger coal mine to close and whether that differs from when PacifiCorp expects the
mine to close.
SC 10.Please refer to the Direct Testimony of Mr. Larkin at ll:7-9 indicating that "Bridger
will require incremental investments to maintain operations prior to the
decommissioning of the plant."
a. Please explain whether these incremental investments are intended to
continue operations at Jim Bridger through 2030 or some later date.b. If incremental investments are intended to continue operations at Jim
Bridger beyond 2030, please explain why Idaho Power customers should
contribute to maintaining operations at the plant beyond 2030.
SC 11 Please refer to the Direct Testimony of Mr. Larkin at26:12-21, indicating that ldaho
Power assumes that it will be responsible for fixed O&M costs as long as PacifiCorp
continues operating Jim Bridger units, but that all O&M costs responsibilities will
cease in 2030.a. Please explain why Idaho Power has made this assumption;b. Please explain why Idaho Power customers should be responsible for fixed
O&M costs at Jim Bridger units even after Idaho Power exits from these
units?
SC 12.Please refer to the Direct Testimony Mr. Adelman at 15:18-16:8. Did Idaho Power
evaluate Regional Haze compliance options for Jim Bridger that did not include the
continued burning of coal, including conversion to natural gas or retirement?
b.
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CERTIFICATE OF SERVICE
I hereby certiff that on this 23rd day of July 2021,I delivered true and correct copies of
the foregoing to the following persons via the method of service indicated below:
Electronic mail only (see Order 35058)
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
[e-mail]. eov
Karl Klein
[e-mail]. eov
Idaho Power Company
Lisa D. Nordstrom
Matt Larkin
lnordstrom@i dahopower. com
mlarkin@i dahopower. com
dockets@i dahopower. com
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
dreading@mindsprine. com
Idaho Conservation League
Benjamin J. Otto
botto@idahoconservation. org
City of Boise
Ed Jewell
BoiseCitvAttorney@citvofboise. ore
ej [e-mail]
/s/ Miriam Ratrel-Smith
Miriam Raffel-Smith
Legal Assistant
Sierra Club Environmental Law Program
2l0l Webster St., Suite 1300
Oakland, CA946l2
Phone: [phone]
miriam.raffel-smith@sierraclub. org
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