20210812Sierra Club 13-27 to IPC.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHOzuTY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER POWER PLANT
CASE NO. IPC-E.21.17
SECOND SET OF PRODUCTION REQUESTS OF SIERRA CLUB TO
IDAHO POWER COMPANY
Sierra Club hereby serves its second 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 September 2. 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, CA94612
ro se. monahan@sierrac lub. org
Ana Boyd
Sierra Club Environmental Law Program
210l Webster Street, Suite 1300
Oakland, CA946l2
[e-mail]
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4.
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 deemed 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, identifu 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.
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6.
7. Please reproduce the production request being responded to before the response
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9.
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 in
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
10.
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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.IPC-E-21-17
Sierra Club's Second Set of Production Requests to ldaho Power Company
August 12,2021
PRODUCTION REQUESTS
SC 13 Please identiff the current undepreciated plant balance for each unit at the Jim
Bridger coal plant. If this information has been provided in Idaho Power's
application, please indicate where in the application this information can be found
SC 14.Please describe the proposed depreciation schedule for each unit of the Jim Bridger
plant by year through 2030 or until the plant balance reaches $0.
sc 15.Please indicate whether any current coal supply agreements for each unit at the Jim
Bridger plant will be in effect beyond 2030.
SC 16.Please indicate whether the Company anticipates that it will enter into a coal supply
agreement for each unit of the Jim Bridger plant before 2030 that extends beyond
2030.
SC 17.Please identiff the date on which Idaho Power decided to move forward with the SCR
emission control systems for Jim Bridger Units 3 and 4 and any associated actions
that committed Idaho Power to the project.
a. Confirm or deny: In May 20l3,Idaho Power and PacifiCorp signed a Limited
Notice to Proceed ("LNTP") with the contractors of the SCR systems. If denied,
please explain.
b. Confirm or deny: In December 2013,Idaho Power and PacifiCorp signed a Final
Notice to Proceed ("FNTP") with the contracts of the SCR systems. If denied,
please explain.
SC I8.Please provide a complete, unredacted copy of the Company's Coal Unit
Environmental Investment Analysis supporting the decision to install SCRs on
Bridger Units 3 and 4
SC 19.Refer to Mr. Adelman's Direct Testimony at 19:8-15. Please provide a complete,
unredacted copy ofthe referenced updated Bridger analysis.
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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-21-17
Sierra Club's Second Set of Production Requests to Idaho Power Company
August 12,2021
SC 20 Please indicate whether Idaho Power completed any other analyses, beyond those
identified in SC 18 and 19, demonstrating that installing SCRs on Jim Bridger Units 3
and 4 would be a net benefit for ldaho Power customers contemporaneous or
subsequent to the Company's Coal Unit Environmental Investment Analysis
submitted as part of its June 28,2013 application for a Certificate of Public
Convenience and Necessity, including any analyses conducted after the start or
completion of construction.
a. If so, please provide such analyses.
b. If so, please identifu the date when such analyses were completed.
SC 2I.Please provide a schedule of capital spending, by month, at each Jim Bridger SCR
project as projected in or around June 2013.
SC 22.Please provide a schedule of capital spending, by month, at each Jim Bridger SCR
project as incurred.
SC 23 Please refer to Mr. Adelman's Direct Testimony at l9:ll-15. Please indicate whether
the Company relied on natural gas Official Forward Price Curves ("OFPC") to
determine that the Jim Bridger SCR installation was least-cost compared to shuttering
Units 3 and 4 and replacing that generation with a combined-cycle combustion
turbine resource.
a. Please indicate whether Idaho Power produced any OFPCs or instead relied upon
OFPCs produced by PacifiCorp.
b. If Idaho Power produced its own OFPCs, please indicate which Idaho Power
employee was responsible for the production of gas price forecasts relied upon
by the Company and whether that employee is still employed by Idaho Power.c. If Idaho Power produced its own OFPCs, please provide each OFPC produced by
Idaho Power between December 201I and December 2016, inclusive.
d. If Idaho Power relied upon OFPCs produced by PacifiCorp, please provide each
OFPC produced by PacifiCorp between December 2011 and December 2016,
inclusive.
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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-21-17
Sierra Club's Second Set of Production Requests to ldaho Power Company
August 12,2021
SC 24
SC 25
SC 26.
SC27
Please describe any Bridger mine assumptions made when evaluating the economics
of installing SCRs on Bridger Units 3 and 4.
a. Confirm or deny: The Company contemplated a four-unit and two-unit fueling
plan for the Bridger mine when determining whether to install SCRs on Bridger
Units 3 and4.
b. If confirmed, provide any underlying workbooks as used supporting the cost of
coal, with formulae intact and unlocked, including the mining plan for Bridger
Coal Company and projected costs of coal from Black Butte.
c. Identiff the date of the end of life for the Bridger Coal Company surface mine in
the analysis underlying the Bridger SCR assessment
d. Identifr the date of the end of life for the Bridger Coal Company underground
mine in the analysis underlying the Bridger SCR assessment.
Confirm or deny: On or around October 2013, the Bridger Coal Company produced a
revised mine plan.
Please provide the Bridger mine October 2013 mine plan from the Bridger Coal
Company. Identiff specific features revised from the mine plan and fueling strategy
informing the Bridger SCR assessment.
Identiff any assumptions made about third party coal costs prior to moving forward
with the Bridger SCR installation.
a. Please provide the basis and any supporting documentation for such assumptions.
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CERTIFICATE OF SERVICE
I hereby certiS that on this l2e day of August202l,I delivered true and correct copies
of the foregoing to the following persons via the method of service indicated below:
Elecffonic mail only (see Order 35058)
Idaho Public Utilities Commission
JanNoriyuki, Secretary
secretarv @puc. idaho. gov
Erick Shaner
erick. [e-mail]. eov
Idaho Power Company
Lisa D. Nordstrom
Matt Larkin
lnordstrom@idahopower. com
mlarkin@ idahopower. com
dockets@idahopower. com
Indus*ial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
dreading@mindspring. com
Idaho Conservation League
Benjamin J. Otto
botto @idahoconservation. org
City of Boise
Ed Jewell
BoiseCitvAttorney@citvofboise. org
ej ewe I I @ c itvofbo i se. or g
Cle an Energt Opportunitie s for ldaho
Michael Heckler
Courtney White
mike@cleanenersyopportunities. com
Kelsey Jae
kelsey@kelse)rj ae.com
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Micron Te chnologt, Inc :
Jim Swier
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
darueschhoff@ hollandhart. com
[e-mail]
awi ensen@hollandhart. com
aclee@hollandhart. com
el earsanoamari@.hollandhart.com
/s/ Ana Bovd
Ana Boyd
Research Analyst
Siena Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA946l2
Phone: [phone]
[e-mail]
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