20220308_tb1.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER ANDERSON
COMMISSIONER CHATBURN
COMMISSIONER HAMMOND
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL

DATE: MARCH 8, 2022

SUBJECT: 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.

BACKGROUND
The Company and PacifiCorp jointly own the Jim Bridger Power Plant (“Bridger”)
plant located in Wyoming. Application at 2. Bridger is comprised of four coal-fired units built in
the 1970s. Id. PacifiCorp owns two-thirds of Bridger and is the plant operator. Id. The Company
owns one-third. Id. On June 3, 2021, the Company applied to the Commission for authorization to
accelerate the depreciation schedule for Bridger to allow the plant to be fully depreciated and
recovered by December 31, 2030. Id. at 1.
In its Application, the Company asked to establish a balancing account and the
necessary regulatory accounting to track the incremental costs and benefits associated with the
Company’s cessation of participation in coal-fired operations at Bridger. Id. The Company also
asked that customer rates be adjusted to recover the associated incremental annual levelized
revenue requirement of $30,825,729 with an effective date of December 1, 2021, which equates
to an overall increase of 2.53 %. Id. The Company separately proposed rate changes associated
with the Depreciation Application in Case No. IPC-E-21-18 in addition to this Application. Id. at
1-2. The Company is also filing one set of proposed tariff sheets specifying the proposed rates for
providing retail electric service to customers in the state of Idaho for both proposed rate changes.
Id. at 8. The Company requested its Application be processed under Modified Procedure. Id. at 9.
DECISION MEMORANDUM 2
On June 24, 2021, the Commission issued a Notice of Application and set a deadline
for intervention. Order No. 35088. The Commission granted intervention into this matter to the
Industrial Customers of Idaho Power (“ICIP”); ICL; the City of Boise (“Boise City”); Sierra Club;
Clean Energy Opportunities, Inc., d/b/a Clean Energy Opportunities for Idaho (“CEO”); and
Micron Technology, Inc. (“Micron”). Order Nos. 35094, 35102, and 35119. On July 28, 2021, the
Commission issued a Notice of Parties.
On October 1, 2021, the Company and Commission Staff (“Staff”) filed a Joint Motion
to Suspend Procedural Schedule (“Joint Motion”). The Joint Motion asked the Commission to
suspend responses to discovery requests and further processing of this docket to address
PacifiCorp’s proposal to convert Bridger Units 1 and 2 from burning coal to burning gas and the
ongoing negotiation over the Wyoming State Implementation Plan. Joint Motion at 4. On October
1, 2021, intervenors ICL and Sierra Club responded by filing their Idaho Conservation League and
Sierra Club Response To Joint Motion To Suspend Schedule (“Response”). Thereafter, on October
7, 2021, the Company replied to the Response by filing Idaho Power’s Reply To Joint Motion
Response (“Company Reply”).
On November 17, 2021, the Commission suspended the procedural schedule and
discovery until the Company files an update or requests to set the procedural schedule once more
information is known, but no later than December 31, 2021. Order No. 35222. The Commission
also suspended the effective date for 30 days and 5 months, or until May 31, 2022, unless the
Commission issues an earlier order accepting, rejecting, or modifying the Company’s Application.
Id.
On December 30, 2021, the Company filed a letter (“Update”) with the Commission
stating that Idaho Power filed its 2021 Integrated Resource Plan (“IRP”) with a preferred portfolio
that also identifies the cessation of coal-fired generation in Units 1 and 2 in 2023 with a natural
gas conversion of those units in 2024. Update at 1. The Company also stated that the EPA has not
yet formally acted on PacifiCorp’s proposed alternative regional haze compliance plan for Bridger
Units 1 and 2. Id. at 2. The plan would require emission controls by December 31, 2021, for Unit
2 and December 31, 2022, for Unit 1. Id. The Company stated that on December 27, 2021,
Wyoming Governor Mark Gordon issued a temporary emergency suspension extending the
compliance date of Unit 2 through April 30, 2022, to give more time for the EPA to take action on
the Wyoming SIP. The EPA is in discussions with PacifiCorp regarding this issue.
DECISION MEMORANDUM 3
On February 7, 2022, the Company met with parties and discussed filing an amended
application and a proposed schedule to resume processing this case. Amended Application at 3.
On February 16, 2022, the Company filed an amended Application and requested, via modified
procedure, that the Commission set a public comment deadline of April 29, 2022, a simultaneous
reply comment deadline of May 13, 2022, and a Company reply deadline of May 18, 2022.
Amended Application at 11. The Company requested that its proposed rates take effect June 1,
2022. Id.
STAFF RECOMMENDATION
Staff recommends that the Commission accept the Company’s proposed schedule and
issue a Notice of Amended Application and Modified Procedure setting a public comment deadline
of April 29, 2022, a simultaneous reply comment deadline of May 13, 2022, a Company reply
deadline of May 18, 2022, and an effective date of June 1, 2022.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Amended Application and Modified
Procedure setting a public comment deadline of April 29, 2022, a simultaneous reply comment
deadline of May 13, 2022, a Company reply deadline of May 18, 2022, and an effective date of
June 1, 2022?

Taylor R. Brooks
Deputy Attorney General

I:\Legal\ELECTRIC\IPC-E-21-17 Jim Bridger\memos\IPCE2117_dec_amend_tb.docx