20210922Sierra Club 28-32 to IPC.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION :il: j :lt iZ pH 3: E9
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCTATED WITH THE JIM
BRIDGER POWER PLANT
CASE NO. IPC.E-21-17
THIRD SET OF PRODUCTION REQUESTS OF SIERRA CLUB TO
IDAHO POWER COMPAIIY
Sierra Club hereby serves its third 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 October 13. 2021.
INSTRUCTIONS
Please provide copies of responses to the following contacts:
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Rose Monahan
Sierra Club Environmental Law Program
2l0l Webster Street, Suite 1300
Oakland, CA946l2
rose.monah [e-mail]
Ana Boyd
Sierra Club Environmental Law Program
2l0l Webster Street, Suite 1300
Oakland, CA94612
ana.b oy d@s i errac lub. 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 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, identiff 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.
7. Please reproduce the production request being responded to before the response.
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lf 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 ifnecessary to the understanding ofthe data, provide a record layout ofthe
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 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-B-21-17
Sierra Club's Third Set of Production Requests to Idaho Power Company
September 22,2021
PRODUCTION REQUESTS
SC 28.Refer to Confi dential Attachm ent 2, " Coal Environmental Compliance Upgrade
lnvestment Evaluation," provided in response to Sierra Club 2-18.
a. Provide the workpapers that support the calculation of the cumulative present
value power costs shown in the report, in machine readable format with cells
unlocked and formulas intact.
b. Provide the source offorecasts ofcoal prices, natural gas prices, and carbon
compliance costs used in the analysis (if something other than IPC) and the date
each forecast was created.
c. Confirm that the analysis of the Jim Bridger units was done only for [PC's share
ofthe plant, and that costs and generation are for the 33 percent share only.
d. Provide the capacity factors that correspond to the generation amounts shown in
Table A-26.
SC 29.Describe how PacifiCorp and IPC, as co-owners of the Jim Bridger plant, make
decisions about investments and future operations of the plant.
SC 30.Describe how PacifiCorp and IPC, as co-owners of the Jim Bridger plant, made the
decision to install the SCRs at units 3 and 4.
a. Provide the dates of any meetings that were held to discuss whether or not to
proceed with the SCR investments.
i Provide any presentations, meeting minutes, or other documents that were
referred to during any such meetings.
b. Provide the date at which a decision was made by PacifiCorp and IPC to proceed
with the SCR investments at units 3 and 4.
i After this date, did IPC do any additional analysis of the economics of the
SCR investments at Jim Bridger units 3 and 4?
l. If yes, provide any analysis done, the date(s) at which this analysis was
done, and all supporting workpapers in machine-readable format with cells
unlocked and formulas intact.
2. If no, why not?
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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 Third Set of Production Requests to Idaho Power Company
September 22,2021
SC 3I Between 201I and 2016, was IPC aware of any analysis done by PacifiCorp on the
economics of the SCR investments at Jim Bridger units 3 and 4?
a. If yes, how was IPC made aware of such analysis?
i Did PacifiCorp inform IPC of its intent to perform such analysis?
ii Did PacifiCorp share the results of any such analysis with IPC?
l. If yes, provide the results of any such analysis done by PacifiCorp and
shared with IPC.
a. Provide both the date of any analysis and the date that it was shared
with IPC.
2. If yes, provide any correspondence between IPC and PacifiCorp that
discusses the analysis of the SCR investments at Jim Bridger units 3 and 4.
b. If no, why not?
SC 32 In its evaluation of the SCR investments at Jim Bridger units 3 and 4, did IPC
calculate a "break even" price for natural gas, meaning the price for natural gas at
which it becomes more economic to convert the units to gas rather than install the
SCRs?
a. If yes, what was that price?
i Provide any supporting workpapers (in machine readable format with cells
unlocked and formulas intact) that calculate a price for natural gas at which
point it becomes more economic to forego the SCR investments.
b. If no, why did IPC not do such a calculation?
c. Is IPC aware if PacifiCorp did such a calculation?
i If yes, when did IPC become aware of this calculation?
l. What was the break even price of gas calculated by PacifiCorp?
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CERTIFICATE OF SERVICE
I hereby certifu that on this 22nd day of September 202I,I delivered true and correct
copies of the foregoing Third Set of Production Requests of Sierra Club to
Idaho Power Company to the following persons via the method of service indicated below:
Electronic mail only (see Order 35058)
Idoho Public Utilities Commission
Jan Noriyuki, Secretary
[e-mail]
Erick Shaner
[e-mail]. eov
Idaho Power Company
Lisa D. Nordstrom
Matt Larkin
lnordstrom@ idahooower. com
[e-mail]
dockets@.idahooower.com
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
[e-mail]
Dr. Don Reading
dreading@mindsprin g.com
Idaho Conservation League
Benjamin J. Otto
botto@ idahoconservation. org
City of Boise
Ed Jewell
BoiseCiwAttorney@cityofboi se.ors
ej [e-mail]
Clean Energt Opportunities for Idaho
MichaelHeckler
Courtney White
[e-mail]
courtne)[e-mail]
Kelsey Jae
[e-mail]
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Micron Technologt, Inc :
Jim Swier
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
[e-mail]
[e-mail]
awj [e-mail]
[e-mail]
ql garsanoamari@hol landhart.com
/s/ Ana Bovd
Ana Boyd
Research Analyst
Sierra Club Environmental Law Program
2l0l Webster St., Suite 1300
Oakland, CA946l2
Phone: [phone]
[e-mail]
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