20130701Lisa Grow DI.pdf

i1 '- n r.-.,t".:.1i...:._i' ',
tUlS JUit 2S plt rl: SZ
ll-t;- li,'-: ''
ur[i'r; s i"cc,,,,. ; j.:. ,: ; +;,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY' S APPLICATION FOR A
CERTIEICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE INVESTMENTIN SELECTIVE CATALYTIC REDUCTION
CONTROLS ON JIM BRIDGER UN]TS 3
AND 4.
CASE NO. IPC-E_13-16
rDAHO POWER COMPANY
DTRECT TESTIMONY
1
2
3
4
5
6
1
I
9
10
11
L2
13
t4
15
76
71
18
L9
20
2L
22
23
24
25
0. Please state your name and business address.
A. My name is Lisa A. Grow and my business
address j-s 1227 West Idaho Street, Boj-se, Idaho 83102.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company") as the Senior Vice President of Power
Supply.
o.Please describe your educational background
and work experience with fdaho Power.
A.I graduated from the University of Idaho in
L9B7 with a Bachelor of Science degree in Electrical
Engineering. I received an Executive Masters of Business
Admj-nistration from Boise State Universlty in 2008. I
began my career at Idaho Power after graduating from the
University of Idaho in L987, and have hel-d several
engineering positions before moving into management in
2005. In 2005, I was named Vice President of Delivery
Engineeri-ng and Operations. In 2009, T was appointed to my
current position as Senlor Vice President of Power Supply.
My current responsibilities include overseeing the
operation and mai-ntenance of Idaho Power's generation
fleet, power plant engJ-neering and construction,
environmental affairs, water management, power supply
planning, and whol-esale electricity and gas operations. I
also oversee Idaho Power's load serving operations, which
GROW, Dr 1
Idaho Power Company
t_
2
3
4
5
6
7
I
9
10
11
72
13
1,4
15
1,6
t1
18
79
20
2L
22
23
24
25
is responsible for deli-vering reliable energy to customers
through the Company's grid using its generation portfol-io
and system purchases.
o.
proceeding?
What is the Company's request in this
A.The Company is requesting that the Idaho
Public Utilities Commission ("Commission") issue a
Certificate of Public Convenience and Necessity (*CPCN")
and provide binding ratemaking treatment under ldaho Code S
6l-541 rel-ated to the Selective Catalytic Reduction (*SCR")
investments planned for Jim Bridger Units 3 and 4 ("Bridger
SCRs") .
O. What is the purpose of your testimony in this
proceeding?
A.The purpose of my testimony is to: (1)
provide an overview of the Company's case, (2) describe the
important rol-e that the Jim Bridger power plant ("JJ-m
Bridger Plant") serves in maintainj-ng the diversity and low
cost structure of the Company's generation resource
portfolio, (3) provide the Commission with an understanding
of the regulations and analyses that led to the Company's
plans to commit to the investment in the Brldger SCRs, and
(4) explain the Company's rationale for requesting a CPCN
and binding ratemaki-ng treatment in this proceeding.
GROW, Dr 2
Idaho Power Company
1
2
3
4
5
6
1
I
9
10
11
L2
13
t4
15
l6
L7
18
19
20
2t
22
23
24
25
O1TERVIEW
O. Please provide an overview of the Company's
case.
A. In this case, the Company will support its
request for a CPCN and associated ratemakj-ng treatment
rel-ated to the investment in the Bridger SCRs by
demonstrating that the SCR investment is prudent,
necessary, and in the best interests of the Company and its
customers.
Mr. Tom Harvey, Joint Projects Manager, will present
testimony that describes in detail the federal and state
emj-ssions reguJ-ations that require the Bridger SCRs. Mr.
Harvey will also describe the analyses that were performed
to determine that the Bridger SCRs represent the most cost-
effective retrofit technofogy that will all-ow the Jim
Bridger Plant to operate in compliance with those emissi-ons
regulations. Lastly, Mr. Harvey wil-l- provlde a description
of the Company's economic analysis that determj-ned that the
investment in the Bridger SCRs represents the l-owest cost
and least risk option of serving future customer demands.
Mr. Mi-chae1 J. Youngblood, Manager of Regulatory
Projects, wilI present testimony that discusses the
portfolio analyses performed in the 20L3 Integrated
Resource Plan ("IRP") which supports the continued
operation of the Jim Bridger Pl-ant. Mr. Youngblood will-
GROW, Dr 3
Idaho Power Company
I.
1
2
3
4
5
6
1
I
9
10
11
L2
13
74
15
16
L1
18
t9
20
2t
22
23
24
25
also present the cost estimates for the Bridger SCRs and
the estimated revenue requirement impact of including that
investment in the Company's rate base. Finally, Mr.
Youngblood will discuss how binding ratemaking treatment is
requested to operate in this case.
O. What is your rol-e in the Company's decision-
making process regarding the investment in the Bridger
SCRs ?
A.As the Senior Vice President of Power Supply,
I oversee the Joint Projects and Water and Resource
Planning groups. These groups were responsible for
prepari-ng the economic analyses related to the Bridger SCRs
as well as the 20L3 IRP. Under my leadership, the Joint
Projects group manages the Company's ownershi-p interest in
the Jim Bridger Plant; therefore, I am the officer
responsj-ble for the Jim Bridger Pl-ant and the SCR project.
Also, I am the officer that oversees the reliable operation
of Idaho Power's system and electric generation portfol-io.
Over the past several years, I have had regular
discussions with Mr. Harvey regarding the regulations,
financial-/economic analyses, and engineering studj-es
related to the need and viability of the Bridger SCRs.
GROW, Dr 4
Idaho Power Company
1
2
3
4
q
6
7
8
9
10
11
72
13
74
15
76
71
18
19
20
2L
22
23
24
25
26
II. IHE ROLE OF THE iIIM BRIDGER PI,ATiIT IN THE COMPATiIY' S
GEIIERATION RESOI'RCE PORTFOLIO
O. Please describe Idaho Power's current
portfolio of generation resources.
A. Idaho Power's current resource portfolio
consists of a dj-verse mix of l-ow-cost generation types
totaling nearly 3r 600 megawatts ("MW") of nameplate
capacity. Idaho Power's resource portfolio is anchored by
the Company's hydroelectric system consisti-ng of t1
projects located on the Snake River and its tributaries.
These L7 projects provide t,'709 MW of nameplate capacity
and approximately 8.4 million megawatt-hours (*MWh")
annually under median water conditions. Idaho Power is the
non-operating partner in three coal--fired power plants that
provide the Company with 1,719 MW of namepl-ate capacity.
Idaho Power's share of these resources i-ncl-udes the Jim
Bridger Plant at 77L MW, the North Valmy power plant
1"Va1my") at 284 MW, and the Boardman power plant
("Boardman") at 64 MW Idaho Power's resource portfol-io
also includes three natural- gas-fired combustion turbj-ne
plants. Langley Gu1ch, a combined-cyc1e p1ant, provides
318 MW of nameplate capacity. The Company's two simple-
cycle "peaker" plants, the Danskin power plant and Bennett
Mountain pIant, provide a combined 444 MW of nameplate
capacity. Idaho Power also owns a small diesel-fired
GROW, Dr 5
Idaho Power Company
I generator located in Salmon, Idaho, that provj-des
2 approximately 5 MW of nameplate capacity.
3 Q. In addition to energy from its own resources,
4 does Idaho Power serve its customer energy demands from
5 other generation resource types?
6 A. Yes. The Company currently has power purchase
7 agreements with one wind project and two geothermal
8 projects. Elkhorn Val1ey wind project, Iocated in
9 northeastern Oregon, provides 101 MW of nameplate wind
10 qeneration. The Raft River geothermal power pIant, Iocated
11 j-n southern Idaho, provJ-des 13 MW of nameplate capacity.
L2 The Neal- Hot Springs geothermal project, Iocated in eastern
13 Oregon, provides 22 MW of nameplate capacity.
14 Idaho Power also contracts with Qualifying
15 Facili-ties for energy purchases under the Public Utility
76 Regulatory Policies Act of L978 (*PURPA"). As of May 31,
t1 2073, Idaho Power had 103 PURPA contracts with independent
18 developers for approximately '184 MW of nameplate capacity.
19 The PURPA generation facilities consist of low-head
20 hydroelectric projects on various irrigation canals,
2l cogeneration projects at industrial facilities, wind
22 projects, anaerobic digesters, l-andfill 9ds, wood-burning
23 facilities, and various other small, renewable-power
24 projects. There is one additional- PURPA project under
25
GROW, Dr 6
Idaho Power Company
1
2
3
4
5
6
7
8
9
10
11
L2
13
L4
15
L6
L1
t-8
L9
20
27
22
23
24
25
contract schedul-ed to come on-l-ine by December 2013 with a
nameplate capacity of 4.1 MW.
o.How does a diverse generation portfolio
benefit Idaho Power and its customers?
A.Idaho Power has l-earned from nearly a century
of operations that energy diversity means energy security.
The Company's resource portfolio is among the most diverse
and therefore secure in the nation. The Company leverages
its hydro, coal, and natural gas resources to provide
dependable "baseload" energy to customers, along with
purchased renewable resources and a robust set of energy
efficiency programs. It is the same principle as
maj-ntaining a diversified investment portfolio to manage
risk; a variety of resources, minimj-zes the risk that comes
with having all your eggs in one basket.
O. What val-ue do coal plants like the Jim Brldger
Plant add to the Company's resource portfolio?
A. C1ean, renewable hydropower remains the lowest
cost foundation of Idaho Power's resource portfolio,
providing for more than half of its customers' energy needs
j-n most years. However, in low water years like the one
southern Idaho is experiencing in 201,3, water can be scarce
during summer months when demand reaches its peak. Wind
and sol-ar cannot always satisfy the resulting generation
shortfall. Eor example, last JuIy, Idaho Power customers
GROW, Dr 7
fdaho Power Company
1
2
3
4
5
6
1
8
9
10
11
L2
13
L4
15
L6
L1
18
19
20
2L
22
23
24
25
set a record for electricity demand. At that time, Idaho
Power had 600 MW of wind capacity connected to its system.
Unfortunately, on that hot, cal-m day the wind turbines were
only able to generate about 14 MW when customer demand was
peaking in the late afternoon. It is at those times that
the Company's reliab1e, low-cost coal resources, l-ike the
Jim Bridger Pl-ant, can be dispatched to help meet customer
demands. The Jim Bridger Plant not only provides highly
val-uable capacity during periods of peak demand, but also
Iow cost and dependable baseload energy.
O.
Pl-ant.
Please describe the Company's Jim Bridger
A.Idaho Power owns one-third of the Jim Bridger
coal-fj-red power plant located near Rock Springs, Vrlyoming.
The plant consists of four generating units. After
adjustment for scheduled maintenance periods and estimated
forced outages, the annual energy generating capability of
Idaho Power's share of the plant is approximately 625
average megawatts. PacifiCorp (formerly known as Pacific
Power & Light Company) has two-thirds ownership and is the
operator of the Jim Bridger Pl-ant.
O.How does the variabl-e cost of operating the
s other resourceJim Bridger Pl-ant compare to the Company'
al-ternatives ?
GROW, Dr 8
Idaho Power Company
1
2
3
4
5
6
7
8
9
10
11
L2
13
74
15
L6
l1
1B
79
20
27
22
23
24
25
26
A.The Jim Bridger Plant has the lowest dispatch
cost of Idaho Power's entire thermal generation fleet.
Based on the Company's May 2073 Operating Pl-an, the Jim
Bridger Plant's average dispatch cost is expected to be
IZuwr, over the period of June 2oL3 through ltay 20L4.
For comparison purposes, the average dispatch cost for the
remaining baseload thermal fl-eet is expected to be
IZuwh over the same perlod.
O.When fixed plant investment is al-so
considered, does the Jim Bridger Plant continue to rank
among the Company's l-owest cost resources?
A.Yes. The Jim Bridger Pl-ant is also the
Company's lowest cost thermal resource from an instal-Ied
cost of nameplate capacity perspective. Based on actual
2072 financial information, the total- cost of nameplate
capacity (excluding fuel- and per-unit energy taxes) for the
Jim Bridger Plant was $8.24lkilowatt (*kW")/month. For
comparison purposes, the average 20L2 instal-l-ed cost of
nameplate capacity for the remaining baseload thermal- fl-eet
was $13.39lkW/month.
rrr. REQUTREDTENTS AIID ECONOMTC AIIATYSES DEMONSTRATTNG
THE IIEED FOR THE BRIDGER SCRS
0. Please describe the emissions control
investments planned at Jim Bridger Units 3 and 4 for which
the Company i-s seeking a CPCN.
GROW, DT 9
fdaho Power Company
1
2
3
4
5
6
7
I
9
10
11
L2
13
L4
15
L6
L7
18
T9
20
2L
22
23
24
25
A. The emissions control investments proposed
in this CPCN are SCR systems and associated ancillary
equipment for Jim Bridger Units 3 and 4. These emissions
control equi-pment investments wil-l result in the
reduction of ni-trogen oxide (NOx) emissions from Jj-m
Bridger Units 3 and 4 in compliance with already binding
state and proposed federal emissions requirements
O.Which federal and state emissions
requirements are the Bridger SCRs intended to satisfy?
A.The Bridger SCRs are required to comply
with exi-sting Regional Haze Rules and are also required
to comply with stand-a1one requirements in the Wyoming
State Implementation Pl-an ("SIP"). Mr. Harvey describes
these emissions requirements in greater detail- in his
testimony.
o.When must the SCRs be instal-led at Jim
Bridger Units 3 and 4 in order to successfully comply
with the federal and state emissions regulations?
A.The BART Appea1 Settlement Agreement and the
Wyoming Regional Haze SIP require the instal-lation of SCR
on Unit 3 by the end of 2075 and on Unit 4 by the end of
2OL6. On May 23, 2013, the United States Environmental
Protection Agency ("EPA") proposed to approve the Wyoming
SIP for instal-l-ation of SCR on Jim Bridger Units 3 and 4
in 2Ot5 and 20L6, respectively, as outlined in the SIP.
GROW, Dr 10
Idaho Power Company
1
2
3
4
5
6
1
8
9
10
11
72
l_3
74
15
76
L7
18
19
20
21,
22
23
24
25
26
The EPA has indicated it wil-l- sj-gn a notj-ce of final
rul-emaking on November 27, 2013, making these emission
reduction requirements at Jj-m Bridger Units 3 and 4
federal-l-y enforceable as well-.
O. What woul-d resul-t if the Company did not make
these investments within the complj-ance time frame?
A.If the environmental upgrades are not
installed within the time frame given by the EPA, Idaho
Power would be forced to stop generating from these units.
Unl-awful-1y operating the units in viol-ation of federal and
state regulations is not an option for Idaho Power.
O.As a minority partner in the Jj-m Bridger
P1ant, what is the Company's decision authority regarding
projects like the Bridger SCRs?
A.Several provi-sions in the aqreement for the
operation of the Jim Bridger Project Between Idaho Power
Company and Pacific Power & Light Company ("Operation
Agreement") address Idaho Power's payment obligations
rel-ated to operating expenses, capital additions, and
maintenance costs at the Jim Bridger Plant. Some of those
provisions set forth below.
Article L4 of the Operation Agreement, Capital
Additions, states:
At any time that either party shal-l-
determine a capital addltion,
improvement or betterment is required
GROW, Dr l_1
Idaho Power Company
l
1
2
3
4
5
6
1
8
9
10
11
12
13
L4
15
t6
71
18
19
20
2L
22
23
24
25
26
)'7
2B
29
30
31
32
33
34
35
36
31
3B
or useful- (other than replacements
budgeted under the ma j-ntenance and
repair provisions of this Agreement),
the Operator shall have prepared a cost
estimate of such capital addition and,
if the part.ies agree, proceed with
construction and installation, the
costs thereof to be paid one-third by
Idaho and two-thirds by Paclfic unless
otherwise agreed to at the time.
Articles 5 and 6 of the Operation Agreement,
Expense of Operation, Maintenance, Repairs, and
RepTacements and Payment of Operating Expenses, also
contain sections re.l-ated to the payment of costs at the
Jim Bridger Pl-ant. Section 5.1, for example, outlines
certain operating expenses attributable to the Jim Bridger
Plant ("Operating Expenses"). Section 5.4 then
establishes a process for the review and approval of the
budget as follows:
On or before October 1 of each year,
Pacific shall submit to Idaho a budget
of its estimate of Operating Expenses
by ca1endar months f or the calendar
year beginning January 1 next
following.Such budget shall be
subj ect to approval by Idaho, whi-ch
approval shal1 not unreasonably be
withheld.If such approval is not
given by November 1 in any such year,
the parties shall- agree upon a revised
budget not later than December 1 of
such year. Each budget shalI include
such items of expenditures for
replacement and repair of Project
facilities as are normal to projects of
a similar character and shal-l- provide
an adequate contingency item for
GROW, Dr 12
Idaho Power Company
1
2
3
4
5
6
1
I
9
10
11
72
13
74
15
t6
71
18
t9
20
27
22
23
24
25
26
27
28
emergency repairs and replacements.Pacific w11l-submit any budgetrevj-sions which changes the budget by
10% or more during any cal-endar year
which Idaho shal-l promptly consider andwhich shall similarly be subject to
approval by Idaho.
Idaho Power representatives have been, and contj-nue to be,
fu11y engaged with the operating partner, Pacj-fiCorp, to
provide a thorough review of the costs and benefits
associated with the installation of the Bridger SCRs
according to the provlsions of the Operatj-ng Agreement.
O.Pl-ease describe the interactions that have
been taking place between the Company and the operating
partner, PacifiCorp, in regard to the SCR project.
A.The Company and PacifiCorp have been
discusslng the Regional Haze regulations and thej-r impact
on the Jim Bridger Plant since the EPA promulgated the
Regional Haze Ru1es (40 CFR Part 51) in 1999. Most
recently, senior officers of Idaho Power and PacifiCorp met
at the Jim Bridger Pl-ant, di-scussed the SCR approval
process and contemplated the provisions to be incl-uded in a
"Limited Notice to Proceed" for the Engineering,
Procurement, and Construction ("EPC") contract. A
subsequent meeting between Company representatives and
PacifiCorp occurred to review the SCR procurement process,
bidders, drawings, evaluations and recommendations on the
GRO!{, Dr 13
Idaho Power Company
1
2
3
4
5
6
1
U
9
10
11
72
13
L4
15
t5
t7
18
T9
20
2t
22
23
24
25
EPC contract. PacifiCorp and the Company continue to have
communi-cations on the SCR proj ect.
O.How will the investment in the SCRs impact the
Plant as compared toeconomic viability of the Jim Bridger
other resource alternatives?
A.To determine the economic viability of
installing the Bridger SCRs, Idaho Power prepared the CoaI
Unit Environmental- Investment Analysis ("CoaI Study") which
is incl-uded as Exhibit Nos. 5 and 6 to Mr. Harvey's
testlmony. The Coal Study analyzed the SCR investment at
Jim Bridger Units 3 and 4 as part of a larger analysis
conducted for all four units at the Jim Bridger Plant and
the two unj-ts at the Valmy p1ant.
The methodology used in the Coal- Study examined
future investments required or reasonably anticipated for
environmental- compliance for the existing coal- units.
Those investments were then compared to the costs of two
al-ternatives: (1) replace such units with combined-cycle
combustion turbj-nes or (2) convert the existing coal-fired
unj-ts to natural- gas. For the complete evaluation, fdaho
Power used a combination of third-party analysis, input
from the operating partners of each coal- pIant, and a final
economic dispatch analysis conducted by the Company to
assure a compJ-ete and fair assessment of the alternatives.
GROW, Dr 74
Idaho Power Company
1
2
3
4
q,
6
7
I
9
10
11
t2
13
t4
15
1,6
t1
18
t9
20
2L
22
23
24
25
a.Do you believe the CoaI Study results support
retrofitting Jim Bridger Units 3 and 4 wlth SCRs?
A.Yes. As outl-ined in greater detail in Mr.
Harvey's testlmofly, the Coal Study supports retrofitting
Jim Bridger Units 3 and 4 with emissions control equipment
to aIlow ongoing coal--fueled energy production from this
facllity through the study period as the least-cost,
adjusted for risk, outcome for customers.
IV. CPCN AIiID RATE!,IAICING TREJAI!'ENT
o.Why is the Company requesting a CPCN and
binding ratemaking treatment under ldaho Code S 67-541 at
this time?
A.The Company is requesting a CPCN and binding
ratemaking treatment under ldaho Code S 6l-541 for the SCR
investment because of the magnitude of the investment, the
uncertainty surrounding coal--f ired generatj-on in today's
political and social environment, and the amount of
interest expressed by stakeholders. With the magnitude of
the investment and the changing climate for investments in
coal-fired generation, the Company has chosen to request a
CPCN even though it does not believe it is required to do
so by Idaho Code S 6l-526. In this wdy, a public process
is initiated to provide the Company, Commission, and
interested parties a regulatory forum to fu1Iy vet these
contested issues.
GROW, DI 15
Idaho Power Company
I
2
3
4
5
6
7
I
9
10
1l_
72
13
t4
15
1,6
t1
18
79
20
2L
22
23
24
25
O. Please explain further what you mean by
"today's political and social environment."
A.The political uncertainty surrounding the
ongoing operation of coal-fired resources has been a
reality for many years now, complete with discussion about
cap and trade legislation, addition of a carbon tax, etc.
The Company has experienced a number of events in recent
years that attest to the heightened sensitivity to the
issues surrounding coal-fired generation. Eor example, in
the Company's last general rate case in Oregon, the
Citizens' Utility Board of Oregon objected to the Company's
proposal to recover a prior j-nvestment in Jim Bridger Plant
pollution control equipment. Over a year later, even
though the Public Utility Commissj-on of Oregon ("OPUC")
found that the Company's $400,000 investment in
envlronmental control-s was not imprudent nor caused harm to
Oregon customers, the OPUC stated on page 7 of Order No.
L3-L32 that the Company "fail-ed to exercise the reasonable
standard of care" they expected utilities to exercise as
co-owners of a generatj-on facility. Thus, to ensure future
compliance with that standard, the OPUC found that a one-
time disall-owance to management expense equivalent to 10
percent of the Oregon portion of the investment was
appropriate.
GROW, Dr 76
Idaho Power Company
1 Q. What are other experiences the Company has had
2 that indicate a changing political and social- environment
3 regarding coal-fired generation?
4 A. In its review of the Company's 2011 IRP filing
5 in Oregon, the OPUC would not acknowledge any IRP provision
6 relating to new investments in coal plants until the
7 Company completed a study of its coal investment complJ-ance
8 costs and other parties had the opportunity to comment on
9 the study. In Order No. L2-L77, the OPUC directed Idaho
10 Power to complete an eval-uation of environmental- compliance
11 costs for existing coal-fired plants. Action Item 11 in
L2 Appendix A of Order No. l2-L77 stated:
13 In its next fRP Update, Idaho Power
74 will include an Eval-uation of15 Environmental- Compliance Costs for
76 Existing Coal-fired Plants. The71 Eval-uation will investigate whether
18 there is flexibi-Iity in the emerging1,9 environmental regulations that would
20 all-ow the Company to avoid early27 compliance costs by offering to shut22 down individual units prior to the end
23 of their useful- lives. The Company24 will also conduct further plant
25 specific analysis to determine whether26 this tradeof f woul-d be i-n the
21 ratepayers' interest.
28
29 Recently, when the Company filed an informational
30 copy of its 20lL IRP Update with the Commission under
31 Docket No. IPC-E-11-11, environmental groups expressed
32 concern regarding the use of coal--fj-red power generation by
33 Idaho's regulated el-ectric utilities and plans by those
GROW, Dr 11
Idaho Power Company
1 utilities to make signifj-cant investments in the coal
2 plants to keep them in complj-ance with state and federal-
3 regulations. These groups believed a rigorous review and
4 public evaluatj-on of additional coal plant investment
5 should occur, and even suggested a CPCN proceeding.
6 Q. During the Company's development of the 2013
7 IRP, were there other indications of the changing social-
8 and political concerns with regard to coal-fired
9 generation?
10 A. Yes. Over the course of a year, the Company
11 invol-ved representatives of the public in the resource
!2 planning process. On a monthl-y basis, the Company met with
13 members of the Integrated Resource PIan Advisory Council
14 (*IRPAC"), which included representatives from the
15 political-, environmental, and customer sectorsr ds well as
16 representatives of other public-interest groups. The IRPAC
Ll actively participated throughout the resource planning
18 process. Members of the IRPAC representing the Idaho
79 Conservation League and Boise State University suggested an
20 additional resource portfolio which eliminated the
2l Company's involvement in all of its coal-fired generation
22 plants be included and analyzed as part of the 2073 IRP.
23 In addition to the resource portfoJ-io suggested by
24 the IRPAC members representing the Idaho Conservation
25 League and Boise State University, Idaho Power developed a
GROW, DI 18
Idaho Power Company
1
2
3
4
5
6
7
8
9
10
11
12
13
l4
15
L6
L1
18
79
20
2L
22
23
24
25
resource portfolio that was derived from the study of the
Idaho Power coal investment compliance costs. The resource
portfolio was al-so analyzed as part of the 2073 IRP.
During the development of the 2013 IRP, NV Energy
announced its intention to remove coal from its portfol-io
Idaho Power is a one-half owner of Valmy and NV Energy is
the operating partner. As a resul-t of that announcement,
Idaho Power included two additional resource portfolios
designed to estimate the effects of closing Valmy. The
20L3 IRP is included as Attachment 4 to the Application
filed contemporaneously with this direct testimony.
o.What were the resul-ts of the IRP's analysis of
the four coal-replacement scenarios?
A. The IRP's analysis supported the Coal- Study in
that the coal--retirement portfolios are not the least cost
al-ternatlves. The cost to replace the coaf resources is
simply too high.
0.Are emission control investments at Valmy part
of the Company's current CPCN request?
A. No. While the Valmy plant is not a part of
the Company's request for a CPCN for the SCR j-nvestments at
Jim Bridger Units 3 and 4, the Nevada legislation
associated with NV Energy's announcement is yet another
indication of the changing climate with regard to coal--
fired generatJ-on.
GROW, Dr L9
Idaho Power Company
1
2
3
4
5
6
7
I
9
10
11
L2
13
t4
15
1,6
!7
18
t9
20
2L
22
23
24
25
O. Do you believe that the installation of the
Bridger SCRs represents a prudent investment that is j-n the
best interests of the Company and its customers?
A.Yes, I do. As supported by the comprehensive
analyses presented in this case, the investment in the
Bridger SCRs represents the lowest cost and least risk
option of serving future customer demands. The SCR
investment will allow the Jim Bridger Pl-ant, the Company's
l-owest cost thermal generatJ-on resource, to continue
providing customers with rellable energy and will maintain
the Company's diverse portfolio of generation resources.
O. Does this conclude your direct testimony in
this case?
A.Yes, it does.
GROW, Dr 20
Idaho Power Company