20210902IPC to Sierra Club 13-27.pdf

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AnID OonP@mpany
September 2,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-21-17
ln 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
Dear Ms. Noriyuki:
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho
Power Company's Response to the Second Production Request of Sierra CIub to ldaho
Power Company. Due to the voluminous nature of confidential and non-confidential
information provided in response to data requests in this case, the Company is posting
the attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely. Because certain attachments contain confidential
information, the FTP site is divided between confidentialand non-confidential information.
The Iogin information for the non-confidential portion of the FTP site was provided to all
parties on July 21, 2021, and the login information for the confidential portion was
provided to those parties that executed the Protective Agreement in this matter on July
21,2021.
lf you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROU
Lead Couneel
[e-mail]
LDN:sg
Enclosures
X*!.(^1,t,-*,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstrom@ idahopower. com
Aftorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WTH THE JlM
BRIDGER PISNT
CASE NO. !PC-E-21-17
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
SET OF PRODUCTION
REQUESTS OF THE SIERRA
CLUB
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COMES NOW ldaho Power Company ("ldaho Power" or "Company"), and in
response to the Second Set of Production Requests of Sierra Club to ldaho Power
dated August 13,2021, herewith submits the following information:
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB . 1
REQUEST NO. 13: Please identify the current undepreciated plant balance for
each unit at the Jim Bridger coal plant. lf this information has been provided in ldaho
Power's application, please indicate where in the application this information can be
found.
RESPONSE TO REQUEST NO. 13: Please see ConfidentialAttachment 1 to the
Company's Response to the lndustrial Customer's of ldaho Power's ("lClP") First
Production Request No. 1. The undepreciated plant balance, or net book value, can be
found on the Existing Plant NBV tab. Please note, although ldaho Power's property
accounting records have not been maintained at the unit level for the steam production
plants, PacifiCorp's provides asset balances by plant account and unit. Therefore, the
Company estimated the net book value of the Bridger assets by unit based on
PacifiCorp's percentage of Bridger assets by unit as compared to the total Bridger
assets. This calculation is performed on the Existing Plant NBV tab.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 2
REQUEST NO. 14: Please describe the proposed depreciation schedule for each
unit of the Jim Bridger plant by year through 2030 or unti! the plant balance reaches $0.
RESPONSE TO REQUEST NO. 14: ldaho Power's proposed levelized revenue
requirement mechanism includes a depreciable life for all Bridger units and common
facilities of year-end 2030.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 3
REQUEST NO. 15: PIease indicate whether any current coal supply agreements
for each unit at the Jim Bridger plant will be in effect beyond 2030.
RESPONSE TO REQUEST NO. 15: Please see the Company's Response to
Sierra Club's Request No. 3.
The response to this Request is sponsored by Randy Henderson, Principal Joint
Projects Coordinator, ldaho Power Company.
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB .4
REQUEST NO. 16: PIease 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.
RESPONSE TO REQUEST NO. {6: ldaho Power is not currently a party to
any coal supply agreements that extend beyond 2030 and does not anticipate
making fuel commitments that extend beyond the date it exits the plant.
The response to this Request is sponsored by Randy Henderson, Principal Joint
Projects Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB .5
REQUEST NO. 17: Please identiff the date on which ldaho Power decided to
move forward with the SCR emission contro! systems for Jim Bridger Units 3 and 4
and any associated actions that committed ldaho Power to the project.
a. Confirm or deny: !n May 2013,ldaho Power and PacifiCorp signed a
Limited Notice to Proceed ("LNTP") with the contractors of the SCR
systems. lf denied, please explain.
b. Confirm or deny: In December 2013, ldaho Power and PacifiCorp
signed a Fina! Notice to Proceed ("FNTP") with the contracts of the
SCR systems. lf denied, please explain.
:
a. On May 31,2013, PacifiCorp executed the Turnkey Contract for
Engineering, Procurement and Construction Services for Selective
Catalytic Reduction System Project for Jim Bridger Plant Units 3 and 4
with Babcock and \Mlcox Power Generation Group, lnc. ("BWPGG')
and the Perry Group, Ltd. ('EPC Contract"), which included a Limited
Notice to Proceed provision. Idaho Power did not sign the EPC
Contract.
b. ln December 2013, PacifiCorp authorized BWPGG and the Perry
Group, Ltd. a Full Notice to Proceed ("FNTP") with the Selective
Catalytic Reduction ("SCR") installations for Bridger Units 3 and 4.
The Company did not sign the FNTP.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB .6
REQUEST NO. 18: 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
RESPONSE TO REQUEST NO. 18: Please see Attachment 1 for the Coal
Unit Environmental lnvestment Analysls filed with the Commission on February 14,
2013, as part of the 201 1 IRP Update in Case No. IPC-E-11-11. Also attached is
ConfidentialAttachment2, the Coal Environmental Compliance Upgrade lnvestment
Evaluation performed by SAIC ("SAIC study"), which was used in preparation of the
Coal Unit Environmental Investment Analysis. Due to the voluminous nature of
confidential and non-confidential information provided in response to previous data
requests in this case, ldaho Power provided parties access to an FTP site where
copies of all confidential and non-confidential responses can be found. Attachment 1
can be found in the non-confidential portion of that site and Confidentia! Attachment 2
can be found in the confidential portion of that site.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 7
REQUEST NO. 19: Refer to Mr. Adelman's Direct Testimony at 19:8-15. Please
provide a complete, unredacted copy of the referenced updated Bridger analysis.
RESPONSE TO REQUEST NO. 19: Please see Attachment 1, the Appendix C
- Technical Report to the 2015lRP filed in Case No. IPC-E-15-19. The updated
Bridger analysis referenced in Mr. Adelman's testimony begins on page 121. Due to the
voluminous nature of confidential and non-confidential information provided in response
to previous data requests in this case, ldaho Power provided parties access to an FTP
site where copies of all confidential and non-confidential responses can be found.
Attachment 1 can be found in the non-confidentia! portion of that site.
The response to this Request is sponsored by Ryan Adelman, Vice President of
Power Supply, ldaho Power Company.
IDAHO POIA/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB .8
REQUEST NO. 20: Please indicate whether ldaho 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 Coa! Unit Environmental lnvestment
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. lf so, please provide such analyses.
b. lf so, please identiff the date when such analyses were completed.
RESPONSE TO REQUEST NO. 20: ldaho Power did not complete any further
analysis beyond those identified in Request Nos. 18 and 19 regarding the costs and
benefits of installing SCRs on Bridger Units 3 and 4. However, in addition to the 2011
and 2015 comprehensive analyses, the Company continually monitored the actual
project costs as compared to budgeted amounts. Over the course of the project, ldaho
Power reported quarterly to the Commission that the project remained on time and
under budget.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB .9
REQUEST NO. 21: Please provide a schedule of capital spending, by month, at
each Jim Bridger SCR project as projected in or around June 2013.
RESPONSE TO REQUEST NO. 21: A schedule of capital spending, by month,
for the Bridger Unit 3 and 4 SCR project was not prepared in or around June 2013.
However, in support of the Commitment Estimate included as part of the request for a
Certificate of Public Convenience and Necessity in Case No. !PC-E-13-16, the
Company did prepare an annual forecast of expenditures by unit, which is included as
Confidential Attachment 1. Actual expenditures and Allowance for Funds Used During
Construction ("AFUDC") charges, as of May 30, 2013, can be found on the U3 actuals
and U4 actuals tabs. The Summary tab computes an estimate of the monthly AFUDC
charges for the June 1,2013, through March 31,2016, time period based on forecasted
capital spend. Finally, the Commitment Estimate tab presents the total estimated
Bridger Unit 3 and 4 SCR project capital spend, by category, as of June 2013, and as
presented in Case No. IPC-E-13-16. Due to the voluminous nature of confidential and
non-confidential information provided in response to previous data requests in this case,
Idaho Power provided parties access to an FTP site where copies of all confidential and
non-confidential responses can be found. ConfidentialAttachment 1 can be found in
the confidential portion of that site.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 1O
REQUEST NO. 22: Please provide a schedule of capital spending, by month,
at each Jim Bridger SCR project as incurred.
RESPONSE TO REQUEST NO. 22: ldaho Power does not have a schedule
of capital spending, by month, for each Bridger SCR project. However, as directed
by Order No. 32929, the Company submitted to the Commission quarterly reports
that included actual expenditures and remaining forecasted expenditures by Bridger
SCR project and cost category. ln addition, the report included a calculation of the
variance between the then current estimated costs and the original estimated costs.
Please see ConfidentialAttachment 1 for the quarterly expenditure reports filed with
the Commission beginning with the quarter-ending March 31,2014, through
December 31,2016. The expenditure reports are summarized bythe same cost
categories presented in the Response to Request No. 21. Due to the voluminous
nature of confidential and non-confidential information provided in response to
previous data requests in this case, ldaho Power provided parties access to an FTP
site where copies of all confidential and non-confidential responses can be found.
Confidential Attachment 1 can be found in the confidential portion of that site.
The response to this Request is sponsored by Maft Larkin, Revenue
Requirement Senior Manager, ldaho Power Company.
IDAHO POV\IER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB . 11
REQUEST NO. 23: Please refer to Mr. Adelman's Direct Testimony at 19:11-
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. lf ldaho Power produced its own OFPCS, please indicate which ldaho
Power employee was responsible for the production of gas price
forecasts relied upon by the Company and whether that employee is
still employed by ldaho Power.
c. lf ldaho Power produced its own OFPCS, please provide each OFPC
produced by ldaho Power between December 2011 and December
2016, inclusive.
d. !f ldaho Power relied upon OFPCs produced by PacifiCorp, please
provide each OFPC produced by PacifiCorp between December 2011
and December 2016, inclusive.
:
a. ldaho Power did not produce any OFPCs or rely on OFPCs produced
by PacifiCorp. lnstead, the naturalgas price forecast used in the SCR
cost-effectiveness analysis referred to in Mr. Adelman's testimony is an
ldaho Citygate price forecast based on the 2015lRP filed in Case No.
!PC-E-15-19. For the 2015lRP, ldaho Power used the US Energy
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 12
lnformation Administration naturalgas price forecast. Idaho Power
applies a Sumas basis and transportation cost to the Henry Hub price
to derive an ldaho Citygate price. The ldaho Citygate price is
representative of the gas price delivered to ldaho Power's natural gas
plants. The ldaho Citygate price forecast is provided in Appendix F
Technical Appendix of the Company's 2015!RP.
b. See ldaho Power's response to "a" above.
c. See ldaho Power's response to "a" above.
d. See ldaho Power's response to "a" above.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 13
REQUEST NO. 24: 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 and 4.
b. lf confirmed, provide any underlying workbooks as used supporting the
cost of coal, with formulae intact and unlocked, including the mining
plan for Bridger Coa! Company and projected costs of coal from Black
Butte.
c. ldentiff the date of the end of life for the Bridger Coal Company surface
mine in the analysis underlying the Bridger SCR assessment
d. ldentiff the date of the end of life for the Bridger Coal Company
underground mine in the analysis underlying the Bridger SCR
assessment.
RESPONSE TO REQUEST NO. 24: ldaho Power's response below
discusses the Bridger mine and fueling assumptions included in the SCR cost-
effective analysis provided in Appendix *TechnicalAppendix of the Company's
2015 tRP.
a. Yes, ldaho Power contemplated both a four-unit and two-unit fueling
plan for the Bridger mine when determining whether to install SCRs on
Bridger Units 3 and 4. A four-unit Bridger fueling plan was referred to
as Option 1 in the SCR cost-effectiveness analysis completed as part of
the 2015 IRP and a two-unit fueling plan was referred to as Option 2.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 14
The plans considered forecasted volumes and prices tor 2015-2034
from Bridger Coal Company ('BCC') and developed during the annual
budgeting cycle in late 2014. Fueling requirements from Black Butte
were also considered for the forecast. The Black Butte volume and
prices used in the fuel forecast were derived from the Company's
system Operations Plan forecasting process. Volumes and prices from
BCC and Black Butte were combined to develop a comprehensive fuel
cost forecast to the Bridger plant for the 2015-2034 period. For the
four-unit operating option (Option 1), these projected fuel costs for
Bridger Units 3 and 4 were included in the analysis. Coalfuel costs
were excluded from Option 2, which considered Units 3 and 4 being
replaced with an equivalently rated gas-fired combined-cycle
combustion turbine.
b. ConfidentialAttachment 1 details the fuelforecast included in the SCR
cost-effective analysis and the underlying BCC mine plan budget for
BCC that was used.
c. Production from the BCC surface mine was assumed to cease on
December 31,2037, in the mine plan used for the SCR cost-
effectiveness analysis.
d. Production from the BCC underground mine was assumed to cease on
December 31,2023, in the mine plan used for the SCR cost-
effectiveness analysis.
Due to the voluminous nature of confidential and non-confidential information
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 15
provided in response to previous data requests in this case, ldaho Power provided parties
access to an FTP sitewhere copies of allconfidentialand non-confidential responses can
be found. GonfidentialAttachment 1 can be found in the confidentia! portion of that site.
The response to this Request is sponsored by Randy Henderson, Principal Joint
Projects Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRACLUB.16
REQUEST NO. 25: Confirm or deny: On or around October 2013, the Bridger
Coal Company produced a revised mine plan.
RESPONSE TO REQUEST NO. 25: BCC produced a mine plan in the fall of
2013 that was used for budgeting and planning purposes by ldaho Power. At least
annually, the mine produces a life of mine plan.
The response to this Request is sponsored by Randy Henderson, Principa! Joint
Projects Coordinator, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND SETOF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 17
REQUEST NO. 26: Please provide the Bridger mine October 2013 mine plan
from the Bridger Coal Company. ldentiff specific features revised from the mine plan
and fueling strategy informing the Bridger SCR assessment.
RESPONSE TO REQUEST NO. 26: A comparison of the BCC specific fueling
forecasts and mine budgets used in the SAIC Energy, Environment & lnfrastructure,
LLC ('SA|C") Study, provided as ConfidentialAttachment 2 to the Company's
Response to Request No. 18, and the mine plan budgets prepared in the fall of 2013
is provided in Confidentia! Attachment 1. The primary update to the BCC operations
plan made in the Fall of 2013 was the assumption regarding the end of production life
for the underground mine. ln the plan prepared in the fall of 2013, the underground
mine Iife was adjusted from December 31,2037 , to December 31, 2023. Due to the
voluminous nature of confidential and non-confidential information provided in
response to previous data requests in this case, ldaho Power provided parties
access to an FTP site where copies of all confidentia! and non-confidential responses
can be found. ConfidentialAttachment 1 can be found in the confidential portion of
that site.
The response to this Request is sponsored by Randy Henderson, Principal Joint
Projects Coordinator, ldaho Power Company.
IDAHO POIA/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB - 18
REQUEST NO. 27: ldentiff any assumptions made about third party coal
costs prior to moving forward with the Briflger SCR installation.
a. Please provide the basis and any supporting documentation for such
assumptions.
RESPONSE TO REQUEST NO. 27: ldaho Power did not make any different
assumptions regarding third party coal costs prior to moving forward with the Bridger
SCR installations other than the assumptions identified in the Response to Request
Nos. 24 and 26.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB . 19
Respectfrllly submitted this 2nd day of September 2021.
X*!-fl"*t"-*,
LISA D. NORDSTROM
Attorneys for ldaho Power Company
IDAHO POWER COMPAhIY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRACLUB.20
I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2nd day of September 2021, I served a true and
correct copy IDAHO POWER COMPANY'S RESPONSE TO THE SECOND SET OF
PRODUCTION REQUESTS OF THE SIERRA CLUB upon the following named parties
by the method indicated below, and addressed to the following:
Commission Staff
Erick Shaner
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
lndustria! Gustomer of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 N.6th Street
Boise, ldaho 83701
City of Boise
Ed Jewell
Boise City Attorney's Office
150 N. Capitol Blvd.
Boise, ldaho 83701
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IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB .21
Clean Energy Opportunities for Idaho, lnc.
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.,
Boise, ldaho 83703
Michael Heckler
Courtney \Mite
3778 Plantation River Drive, Suite 102
Boise, lD 83703
Sierra Club
Rose Monahan
Ana Boyd
2101 Webster Street, Suite 1300
Oakland, CA 94612
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Jim Swier
8000 S. FederalWay
Boise, lD 83707
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Stacy Gust, Regulatory Administrative
Assistant
IDAHO POVI/ER COMPANY'S RESPONSE TO THE SECOND SET OF PRODUCTION REQUESTS OF
THE SIERRA CLUB -22