Loading...
HomeMy WebLinkAbout20130701Michael Youngblood DI.pdfnfn:--i11.-rqF. ; l-, l- , ,i i-. '".1 2$t3 JU:i 2"q pil L: 0L llit,iri';::i :'-. l_lTiLl i: ::= i--ii.,, .,',:. ;,iii BEFORE THE IDAHO PUBLTC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY' S APPLICATION EOR A CERTIFTCATE OF PUBLIC CONVEN]ENCE AND NECESSITY FOR THE INVESTMENT IN SELECTIVE CATALYTIC REDUCTION CONTROLS ON JIM BRIDGER UNITS 3 AND 4. CASE NO. IPC-E-13-16 IDAHO POWER COMPANY DIRECT TESTIMONY OF MICHAEL J. YOUNGBLOOD I 2 3 4 5 6 1 I 9 10 11 L2 13 L4 15 15 71 18 19 20 2t 22 23 24 25 a. A. O. Please state your name and business address A. My name is Michael J. Youngblood and my business address is 722L West Idaho Street, Boise, rdaho. 0. By whom are you employed and in what capacity? A. I am employed by Idaho Power Company ("Idaho Power" or "Company") as the Manager of Regulatory Projects in the Regulatory Affairs Department. Please descrj-be your educational background. In May of L911, T received a Bachelor of Science Degree in Mathematics and Computer Sclence from the University of Idaho. Erom L994 through 1,996, I was a graduate student in the Executive MBA program of Colorado State University. Over the years, I have attended numerous industry conferences and training sessions, including Edison Electric fnstitute's "Electric Rates Advanced Course. " o.Pl-ease describe your work experience with Idaho Power Company. A.I began my employment with ldaho Power j-n L91'7. During my career, I have worked in several departments of the Company and subsidiaries of IDACORP, incJ-uding Systems Development, Demand Planning, Strategic Plannj-ng and IDACORP Solutions. From 1981 to 1988, I worked as a Rate Analyst in the Rates and Planning YOUNGBLOOD, Dr 1 Idaho Power Company 1 2 3 4 5 6 1 8 9 10 11 t2 13 L4 15 t6 71 18 19 20 27 22 23 24 25 Department where I was responsible for the preparation of electric rate design studies and bil-l- frequency analyses. I was also responsible for the valj-dation and anal-ysis of the l-oad research data used for cost of service allocations. From 1988 through 1,997, T worked in Demand Planning and was responsible for the load research and load forecasting functions of the Compdoy, including sample design, impJ-ementation, data retrieval, analysis, and reporting. I was responsible for the preparation of the five-year and twenty-year load forecasts used j-n revenue projections and resource plans as wel-l as the presentation of these forecasts to the public and regulatory commissions. From t99L through 1998, I worked in Strategic Planning. As a Strategic Planning Associate, I coordinated the complex efforts of acquiring Prairie Power Cooperative, the first acquisition of its kind for the Company in forty years. I was the team leader on combined departmental efforts responsi-ble for evaluating performance based regulatJ-on and reviewing potential tel-ecommunicatj-ons business opportunities as a direct resul-t of changes in tel-ecommunication legislation. From 1996 to 1998r dS a part of a Strategic Plannj-ng initiative, I helped develop and provide two-way communication between customers and YOUNGBLOOD, Dr 2 Idaho Power Company 1 2 3 4 5 6 1 I 9 10 11 72 13 74 15 1"6 71 1B 79 20 27 22 23 24 25 energy providers using advanced computer technologies and te l-ecommuni- cat ions . Erom 1998 to 2000, I was a General Manager of IDACORP SoJ-utions, a subsidiary of IDACORP, reporting to the VP of Marketing. f was dlrectly responsible for the direction and management of the Commercial & Industrial (*C&I") Business Solutions dj-vision. r had the overal.l- responsibility for the research, development and implementation of new products and services for C&I customers. These new products and services included energy informatlon services, bill payment and management products, facility monitoring, telecommunication and internet services, onsite qeneration and power quality analysis. I was directly involved in the direction and product development of the Allied Utilities Network, an al-l-iance of utilities with the conimon goal of providing products and services for their respective customers as well as the growth of those services into new territories, including national- and regional accounts. In 2001-, T returned to the Regulatory Affairs Department and worked on special projects related to deregulation, the Company's Integrated Resource Plan, and filings with both the Idaho Public Utilities Commission ("Commission" or "IPUC") and the Public Utility Commission of Oregon (*OPUC"). YOUNGBLOOD, Dr 3 Idaho Power Company 1 2 3 4 5 6 7 8 9 10 11 1,2 13 t4 15 16 7"1 18 19 20 21 22 23 24 25 In 2008, T was promoted to the position of Manager of Rate Design for Idaho Power. fn that position I was responsible for the management of the rate design strategies of the Company as well- as the oversight of all tari-f f administrati-on. fn January of 20!2, T became the Manager of Regulatory Projects for Idaho Power, which is my current position. In this position, I provide the regulatory support for many of the large individual projects and i-ssues currently facing the Company. Most recently that has included providing regulatory support for the inclusion of the Langley Gulch power pJ-ant investment in rate base and supporting the Company's efforts to address numerous issues lnvolving Qualifying Facilities (*QF") as defined under the Public Utility Regulatory Policies Act of 1-978 ("PURPA"), including the Company's efforts in Case No. GNR- E-11-03, the review of PURPA QE contract provisj-ons. I. O\IERVIETT O. What it the purpose of your testimony in this matter? A. The Company is requesting the IPUC issue a Certificate of Public Convenience and Necessity (*CPCN") rel-ated to the Selective Catalytic Reductj-on ("SCR") investments planned for Jim Bridger Unit 3 and Jim Bridger Unit 4 ("the Project"). In my testimony, I wiII briefly YOUNGBLOOD, Dr 4 Idaho Power Company 1 2 3 4 5 6 7 I 9 10 11 72 13 L4 15 16 L1 1B 79 20 2! 22 23 24 25 describe the portfol-io analysis of coal-fired generation alternatives developed for the Company's 2073 Integrated Resource Pl-an (*201-3 IRP"). The 20L3 IRP is being filed concurrently with this filing in Case No. IPC-E-13-15 and is Attachment 4 to the Application 1n this case. In addition, I will present the cost estimates for the Jim Bridger SCR systems and the estimated revenue requirement impact of including that j-nvestment in the Company's rate base. Finally, I will- discuss the Company's request for the Commj-ssion to provide authorization and blnding ratemaking treatment for the Company's SCR investments in Jim Bridger Units 3 and 4 pursuant to Idaho Code S 61-541. O. The Company has filed a number of CPCNs for peaklng facilities over the last decade, and most recently, for the Company's combined-cyc1e combustion turblne project at the Langley Gulch power plant. Is this request for a CPCN different from those requests? A.Yes it is. Most of the Company's previous requests for a CPCN were for new generating plants. This request is different in that it is for the addition of emission equipment required for the Company to remain compliant with environmental regulations at an existing generation resource. The Jim Bridger Plant is already a valued part of the Company's generation fleet, and in fact, YOUNGBLOOD, Dr 5 Idaho Power Company 1 2 3 4 5 6 7 I 9 10 11 L2 13 74 15 L6 L1 18 19 20 2L 22 23 24 25 as noted in Ms. Lisa Grow's testimony, is the Company's Iowest cost thermal p1ant. The Jim Bridger Plant is currentl-y included as production plant in the Company's rate base. Ongoing operatj-on and maintenance of the plant, including the investment in emission controls mandated by state or federal environmental regulations, would not typically be an investment for which the Company would request a CPCN. o. this time? A.As described in Ms. Grow's testimooy, the Company is requesting a CPCN for the SCR investment because of the magnitude of the investment and the uncertainty surrounding coal-fired generation in today's political and social- environment, as well as the amount of interest expressed by stakehol-ders. o.Please generally descrj-be the Project for which the Company is requesting a CPCN. A. The Project refers to the Company's investment in SCR systems to reduce the emissions of ni-trogen oxide for Jim Bridger Units 3 and 4. A complete discussion of the specific emission controls and equipment required for the Project can be found in Mr. Tom Harvey's testimony. YOUNGBLOOD, Dr 6 Idaho Power Company Why then is the Company requesting a CPCN at 1 2 3 4 5 6 1 8 9 10 11 72 13 L4 15 t6 L7 18 1,9 20 27 22 23 24 25 O. Why are the investments in SCR systems at Jim Bridger Unj-ts 3 and 4 necessary? A.The Best Availabl-e Retrofit Technology Appeal Settlement Agreement and the Wyoming Regional Haze State Implementation Pl-an ("Wyoming Regional Haze SIP") require the instal-l-ation of SCR systems on Jim Bridger Unit 3 by the end of 2075 and on Jim Bridger Unit 4 by the end of 20L6. On May 23, 20!3, the Envj-ronmental Protection Agency ("EPA") proposed to approve the Wyoming Regional Haze SIP for installation of SCR systems on Jim Bridger Units 3 and 4 j-n 2OL5 and 2016, respectively, as outlined in the SIP. The EPA has indicated it wi-ll sign a notice of f i-nal rulemaki-ng on November 21, 2073. This would make these emission reduction requirements at Jim Bridger Units 3 and 4 federally enforceable as well-. This is dj-scussed more fu11y in Mr. Harvey's testimony. In order for the continued operation of the plant to be compliant with environmental regulation, it wil-l- be mandatory for the SCR systems to be lnstall-ed at Jim Bridger Unlts 3 and 4. O. When do the SCR emission control systems for Jim Bridger Uni-ts 3 and 4 need to be installed and operational- ? A. In order to be compliant with these current state and anticipated future environmental regulations, and YOUNGBLOOD, Dr 7 Idaho Power Company 1 2 3 4 5 6 7 I 9 10 11 L2 13 L4 15 76 L't 18 L9 20 2t 22 23 24 25 enable continued operation of the Jim Bridger Plant, the SCR emission control systems for Jim Bridger Units 3 and 4 must be installed and operatj-onal by December 31, 2015, and December 31, 20L6, respectively. O.Is fdaho Power solely responsible for the SCR investments for the Project? A. No. Idaho Power is not the sol-e owner of the Jim Bridger P1ant. The Company is a one-thj-rd partial owner of the p1ant, the remaining two-thirds being owned by PacifiCorp. PacifiCorp is also the operating partner of the plant. Nevertheless, while the decj-sion to add SCR systems to Jim Bridger Units 3 and 4 does not so1ely reside with Idaho Power, the Company did conduct its own lndependent analysis to determi-ne if the addition of SCR systems was economically prudent. This analysis is discussed in greater detail in Mr. Harvey's testimony. O. What did the Company conclude from the resul-ts of the economic analysis discussed by Mr. Harvey? A.Based upon the economic analysis discussed in Mr. Harvey's testimony regarding both the Science Applications International Corporatlon (*SAIC") and Idaho Power evaluations analyzing the install-ation of SCR systems at Jim Bridger Units 3 and 4, the Company's concl-usion is that compared to alternatj-ve compliance options, the install-ation of the SCR systems is the l-owest incrementaf YOUNGBLOOD, Dr I Idaho Power Company 1_ 2 3 4 5 6 7 I 9 10 11 12 13 L4 15 76 L7 18 79 20 27 22 23 24 25 cost and least risk option, and therefore, a prudent economic decision for the ongoing operation of the Jim Bridger P1ant. II. 2OL3 IRP AT{AI,YSIS o.Subsequent to the Company's conclusion that the instal-l-ation of SCR systems is the prudent economic decision for the ongoing operation of the Jim Bridger P1ant, did the Company nonetheless eval-uate any potentj-al reduction or early retirement of its existing coal-fired resources ? A.Yes. As part of the development of the Company's 201,3 IRP, the Company included four resource pJ-anning portfolj-os that explored options for reducing the amount of coal-fired generatj-on in Idaho Power's generation portfolio. The options to reduce the reliance on coal included replacement with natural gas-fired generation, increased demand-side measures including demand response, changing the fuel at the North Valmy plant to natural 9ds, and the Boardman to Hemingway transmission line. Two of the portfolios specifically ceased coal-fired operations at the Company's Jim Bridger and North Valmy coal plants (the Boardman coal plant ceases coal--fired operations at year- end 2020 in aII resource portfolios). YOUNGBLOOD, Dr 9 Idaho Power Company I 2 3 4 5 6 7 I 9 10 11 L2 13 t4 15 16 77 18 19 20 2L 22 23 24 25 0.What were the results of the 2073 IRP analysis with regard to the portfolios that eliminated a coal-fired resource at the Jim Bridger Pl-ant? A.As described on pages 93-94 of Attachment 4 to the Application, Portfolios 6 and 7 ceased coal-fired operati-ons at the Company's Jim Bridger and North Valmy coal plants. These two portfolios ranked as the two highest cost resource portfolios of the nine portfolios analyzed. As shown on Tabl-e 9.2 on page 98 of Attachment 4, Portfol-io 6 had a net present val-ue for the 20-year planning period (20L3-2032) that was $1,5L2,173,000 more costly than the Company's preferred portfolio, and Portfolio 7 was $1,785r578r000 more costly. o.Based upon the analysis conducted in the 2073 IRP, is the continued operation of the coal-fired resource at the Jim Bridger Plant cost-effective? A Yes. As noted on page 113 of Attachment 4, the Company's preferred resource portfolio in the 2013 fRP is Portf ol-io 2. Resource Portfolio 2 incl-udes continued operations at the Jim Bridger and North Valmy coal plants. Idaho Power intends to operate its facilities, including the coal-fired generation plants, in ful-l compliance with environmental regulations. YOUNGBLOOD, Dr 10 Idaho Power Company 1 2 3 4 5 6 7 I 9 10 11 t2 13 L4 15 L6 77 18 79 20 2T 22 23 24 25 O. Do you believe the 2073 IRP was sufficient in analyzing the complexities surrounding coal-fired generation? A. Yes. f believe the 2073 IRP, in addition to the previously filed Coal Study, adequately analyzes the Company's options for compliance whj-le supporting its obligation to reliably serve the electrj-city needs of its customers. The Idaho Power resource planning process has four primary goals: (1) Identify sufficient resources to reliably serve the growing demand for energy within the Idaho Power service area throughout the 20-year planning period. (2) Ensure the sel-ected resource portfolio balances cost, risk, and environmental- concerns. (3) Give equal and balanced treatment to supply-side resources, demand-sj-de measures, and transmission resources . (4) Involve the public in the planning process in a meaningful way. IRP anal-yses are conducted by the Company on an ongoing basis with the formal IRP document being filed for acceptance with the IPUC and acknowledgement with the OPUC every two years. YOUNGBLOOD, Dr 11 fdaho Power Company 1 2 3 4 5 6 7 8 9 10 11 t2 13 t4 15 16 L7 1B 19 20 27 22 23 24 25 o. A. IIT. PROi'ECT COST ESTIMATE O. Has the Company determined a total project cost estimate for Idaho Power's share of the Proiect ("Project Cost") ? A.Yes. The total cost of the Project, before Allowance for Eunds Used During Construction (*AEUDC") is $353,8431886. Idaho Power's share of that amount, the Project Cost, is one-third, or $117,947,962, comprised of a $57,649,1L3 investment in Jim Bridger Unit 3 and a $60,298,849 investment in Jim Bridger Unit 4, before AEUDC. What is included in the Project Cost? Confidential- Exhibit 7 shows the budget projections for each cost description by year for Jim Bridger Units 3 and 4. The largest portions of the total- Project Cost estimate are the costs incl-uded under the engineer, procure and construct contract (*EPC Contract"). o. Contractor? Has a contract been signed with an EPC A.Yes. As discussed in Mr. Harvey's testimony, because of the extent of the Project and the extended period of time it takes to p1an, permit, engineer, procure, and construct SCR systems, and the uncertainty of the final ruling from the EPA on approval of the porti-on of the WyomJ-ng Regional Haze SIP that addresses the SCR systems at Jim Bridger Uni-ts 3 and 4, a YOUNGBLOOD, Dr 1-2 Idaho Power Company 1 2 3 4 5 6 7 I 9 10 11 72 13 74 15 16 11 18 19 20 2L 22 23 24 25 26 21 28 29 30 Limited Notice to Proceed ("LNTP") contract was with the successful- bj-dder on May 31, 2073. O. Has PacifiCorp, the majority owner operator, made regulatory filings simil-ar to this Idaho Power? signed and plant filing by A. Yes. As indicated by Mr. Harvey, in August 2012, PaciflCorp, d/b/a Rocky Mountaln Power, filed a CPCN with the Wyoming Public Service Commission ("Wyoming Commisslon") to construct two SCR systems on units 3 and 4 of the Jim Bridger Plant, ds well as a "voluntary request for approval of resource decision to construct SCR systems on Jim Bridger units 3 and 4" with the Public Service Commissj-on of Utah ("Utah Commission") . o. A. Vrlhat were the results of those filings? On May 10, 201,3, the Utah Commj-ssion issued a final- Report and Order approving the resource decision to construct the SCR systems, which is incl-uded as Attachment 2 to the Application. The Utah Commission's conclusions are provided below: Based on the f oregoing discuss j-on and the evidence presented in this caser w€ approve the Company's resource decision to construct SCR systems to achj-eve0.07 Ibs/MMBtu limits at Bridger Unit 3 by 20L5, and Unit 4 by 2076, ds described in the AppJ-ication. We find the Company has demonstrated the Bridger SCR Project is the least-cost means, adjusted for risk, to meet the emissions limits for Bridger Units 3 YOUNGBLOOD, Dr 13 Idaho Power Company 1 2 3 4 tr 6 1 I 9 10 11 L2 13 74 15 76 71 18 L9 20 2t 22 23 24 25 ZO 21 2B 29 30 31 5Z 33 34 35 36 31 3B 39 40 47 42 A-)AJ 44 and 4 established by the Wyoming emission standards. We also find the Company's proposed timing for completing the Pro j ect w1l-I benef it ratepayers by avoiding increased Project cost due to the requj-rements of a compressed construction schedule and possible additional outages. Coordinating the timlng of the Projectwith the four-year maintenance schedules of the Bridger Pl-ant also will manage costs and risks associated with potential replacement power cost while the Project is implemented. Importantly, this timing wil-l- also ensure the Project is completed j-n time to meet the Wyoming SIP deadlines. Docket No. 72-035-92, Commi-ssion Report and Order, issued May 10, 20t3, page 32). On NIay 29, 20L3, the Wyoming Commission issued a final order approving the CPCN for the SCR upgrades, which is included as Attachment 3 to the Application. A sunrmary of the Wyoming Commission's conclusions is provided below: We conclude there is need for additional- servi-ce which warrants construction of the proposed SCR upgrades to Bridger Units 3 and 4 based upon our findings, which are supported by the testimony of the intervenors as well as the Application and testimony and exhibits of RMP. We conclude that: Ii] the proposed expendi-tures are reasonable and in thepublic interest, Iii] the present and future public convenience and necessity require the construction and operation of SCR upgrades to Bridger Units 3 and 4, and tfiil a CPCN shoul-d be issued in this case. RMP has carried its burdensof proof and persuasion. It is in the public interest that the certificate be YOUNGBLOOD, Dr L4 Idaho Power Company 1 2 3 4 5 6 7 I 9 10 11 72 13 14 15 L6 L1 18 L9 20 2T 22 23 24 25 issued.(Docket No. 20000-4L8-EA-72, Record No. 13314 paragraphs 84-86). O. Illhat amount has the Company determi-ned to be the Project Cost includj-ng AFUDC ("Total- Commitment Estimate") ? A.The Total Commitment Estimate for the Project is the Project Cost of $117,947,962 plus $11,889,437 in AFUDC. The Total- Commitment Estlmate for the Project, including AFUDC, is $729,837,393. Of this amount, $62,923,527 is the Commitment Estimate for Jim Bridger Unit 3 and $66,913 ,866 is the Commitment Estimate for Jim Bridger Unit 4. o.Please clarify what you mean by the term Commitment Estimate. A.Based on the EPC Contract, actual costs incurred in the development phase and the forecast estimates of the work to be completed, Idaho Power is able to make a reliable estimate of the total capital cost of the Project. As it has done in prior CPCN applications, Idaho Power has termed this estimate a "Commitment Estimate." The Commitment Estimate is a good faith estimate of Idaho Power's total- capital cost incJ-uding AFUDC, and additional costs the Company anticipates it wil-l- incur but cannot quantify with precision at this time. YOUNGBLOOD, Dr 15 Idaho Power Company 1 2 3 4 5 6 1 I 9 10 11 72 13 t4 15 L6 L1 18 79 20 2t 22 23 24 25 Idaho Power's Total Commitment Estimate for the Project is $129 ,83'7 ,393 . O. What is the estimated revenue requirement impact of these proposed additions to the Company's rate base? A.Based upon the system investment stated above, the Company performed a high-level jurisdictional revenue requirement analysis. Based upon the current jurisdictional split between Idaho and Oregon, the Idaho jurj-sdictional addition to production plant would be $60,196,124 for i-nvestments at Jim Bridger Unit 3 and $64,074,741 for investment at Jim Bridger Unit 4. At the Company's current rate of return, the additional- annual- revenue requirement for Jim Bridger Units 3 and 4 would be approximately $9.1 million and $9.7 million, respectively. rv. REQITESTED REGUT,ATORY TREIATLTENT O. What reguJ-atory treatment is the Company requesting as part of this CPCN request? A.The Company is requesting that the Commission issue a CPCN order by November 29, 2013. Pursuant to ldaho Code S 6L-54Lt the Company is requesting that the Commission provide Idaho Power with authorization and a binding commitment to provide rate base treatment for the Company's capital investment in the SCR systems at Jim Bridger Units 3 and 4 in the amount of the Total Commitment YOUNGBLOOD, Dr 16 Idaho Power Company 1 2 3 4 5 6 7 I 9 10 1t_ 72 13 t4 15 t6 L1 18 L9 20 2t 22 23 24 25 Estimate of $L29,837,393. Of that amount, the Commitment Esti-mate of i62,923,527 for the investment in Jim Bridger Unit 3 would be cl-osed-to-p1ant and authorj-zed for cost recovery on or after January l, 2016, and the Commitment Estimate of $66,91-3,866 for the j-nvestment in Jim Bridger Unit 4 would be cl-osed-to-p1ant and authorized for cost recovery on or after January 1, 20L1. If binding ratemaklng is approved for the Total Commitment Estimate of $129,83'7 r393, the Company coul-d be assured that amounts incurred up to the Commitment Estimate amount would be determined to be prudent. Should the cost of the Project be less than the Commitment Estimate, the savings would directly benefit the customer through a l-ower amount in rate base. On the other hand, shou1d the Project come in over the Commitment Estimate, Idaho Power would have to demonstrate to the Commissi-on that amounts above the Commitment Estimate were prudently incurred and should be recovered in rates. The return on equity the Company expects to earn on the Project investment is the authorized rate in effect at the time the Project is placed in service. Idaho Power wil-l- depreciate the investments over the remaining Iife of the Jim Brldger Pl-ant in accordance with the IPUC-approved depreciation rates in effect at the time the investment is YOUNGBLOOD, Dr 71 Idaho Power Company 1 closed-to-plant. The Company's current depreciatj-on rates 2 were approved in Case No. IPC-E-12-08, Order No. 32559. 3 Q. Why is the Company requesting a CPCN order 4 by November 29, 20!3? 5 A. The LNTP concept described above was used 6 to reduce the risk and upfront costs of a EulI Notice to 7 Proceed ("FNTP") until the final- ruling from the EPA j-s I released, and to ensure the EPC Contractor can meet the 9 deadl-ines for inst.allation as per the Wyoming Regional 10 Haze SIP. A provision in the LNTP states that December L, 11 2073, whj-ch is defined as the FNTP Date, is the deadline by !2 which the FNTP must be issued in order for the EPC l-3 Contractor to attain the Project completlon guarantee dates L4 wj-thout requiri-ng a contract change. Idaho Power and 15 PacifiCorp have agreed thatr dS long as the FNTP is issued 76 on or before December L, 2073, neither the EPC Contract t7 price nor the Project guarantee dates wil-l- be adjusted. 18 The Company is requesting a CPCN order by November 29, 19 2013r so that 1n the event that a favorable CPCN order is 20 issued, the Company will be able to approve PacifiCorp's 21 execution of the FNTP by December L, 2073. 22 O. Why is the Company requesting the Commission 23 provide authorization and binding ratemaking treatment for 24 the Company's SCR investments j-n Jim Bridger Units 3 and 4 25 pursuant to ldaho Code S 6L-541? YOUNGBLOOD, Dr 18 Idaho Power Company A. Because of the uncertainty and political 2 realities surrounding the topic of coal-fired generation 3 descri-bed in the testimony of Ms. Grow, the Company is 4 concerned that decisj-ons made today may be second guessed 5 in the future. Even with a favorable determination 6 provided with a certificate, the risk of disallowance at a 7 future date is a concern for the Company. Eor that reason, I the Company is requesting that the Commission provide 9 binding ratemaking treatment under Idaho Code S 67-54L. 10 O. Does ldaho Code S 6L-541 require the 11 Commission to make certaj-n determinations regarding Idaho L2 Power's activities as a regulated utility? 13 A. The law provides that the Commission will 1,4 determine whether: (1) the utility has a Commission- 15 accepted integrated resource plan in effect, (2) the 1,6 Project is in the public interest, (3) the utility has \7 considered other resources, (4) the Project is reasonable 18 compared to other resource options such as energy L9 efficiency, demand-side management, and other alternative 20 sources of supply or transmission, and (5) the utility 2L participates in regional transmission planning. 22 O. Based upon the information the Company has 23 presented in this case, will the Commission be abfe to make 24 these determinations with regard to Idaho Power? 25 YOUNGBLOOD, DI L9 Idaho Power Company 1 2 3 4 5 6 7 I 9 10 11 72 13 L4 15 16 1-7 18 19 20 27 22 23 24 25 A. the Company's that are filed Yes. This information has been testj-mony, and in the CoaI Study with this case. addressed in and 2013 IRP V. SI'MI{ARY o.In sunrmary, what specifically is the Company requesting the Commission to incl-ude in its CPCN order? A.Idaho Power believes that the results of the CoaI Study conducted by the Company (SAIC analysis and Idaho Power's Aurora simulation) and the portfolio costs identified j-n the 2013 IRP clearly demonstrate that the investment in SCR systems at Jim Bridger Units 3 and 4 represent the most cost-effective means of assuring continued operation of the Jim Bridger Plant to provide sufficient resources to reliably serve the growing demand for energy within Idaho Power's service area. Even sor the Company beli-eves that the current political and environmental- climate provides additional risk of future recovery of Company investments and necessitates a transparent public process to review the resul-ts that support the Company's conclusion. Therefore, the Company requests the Commission evaluate the meri-ts of providing a favorable CPCN order. Specifically, Idaho Power requests that the Commission issue an order approving a Certificate of Public Convenience and Necessity by November 29, 20L3, which finds that: YOUNGBLOOD, Dr 20 Idaho Power Company 1 2 3 4 5 6 1 I 9 10 11 L2 13 74 15 1,6 77 18 19 20 27 22 23 24 25 (1) The installation of Selective Catalytic Reduction systems planned for Jim Bridger Units 3 and 4 is consistent with Idaho Power's resource plans and j-s an appropriate investment to assure the ongoing compliant operation of the Jim Bridger Plant to reliably serve its customers. (2) Existing Wyoming and anticipated federal regulations require the instal-l-ation of Sel-ective Catalytic Reduction systems for Jim Bridger Units 3 and 4 by December 37, 2015, and December 31, 2076, respectively. (3) The approved Total Commitment Estimate for the Project, including $11,889,437 in AEUDC is $L29,837,393, which includes a Commitment Estimate for Jim Bridger Unit 3 of $62,923,527 and a Commitment Estimate for Jim Bridger Unit 4 of $66,913,866. (4) Pursuant to Idaho Code S 6]--54L, the Commission provides Idaho Power with authorization and a binding commitment to provide rate base treatment, as described previously in my testimony, for the Company's capital investment in SCR controls at Jim Bridger Units 3 and 4 and related facil-ities up to the amount of the Total Commitment Estimate of $L29,83'7,393 at such time the plant is placed into operation. RetaiI customers wil-1 receive the full benefit of the Project being completed under the Total Commitment Estimate, while the Company will have the YOUNGBLOOD, Dr 27 Idaho Power Company 1 2 3 4 5 6 1 I 9 t-0 11 72 13 1-4 15 16 77 18 t9 20 2t 22 23 24 25 opportunity Estimate as o. A. to justify any costs above the Total Commitment prudently incurred for recovery. Does this conclude your testimony? Yes, it does. YOUNGBLOOD, Dr 22 fdaho Power Company I 2 3 4 5 6 7 I 9 10 11 L2 13 74 15 t6 l7 18 L9 20 2L 22 23 24 25 26 21 28 29 30 31 STATE OF IDAHO County of Ada ATTESTATION OF TESTIIONY SS. l, Michael J. Youngblood, having been duly sworn to testify truthfully, and based upon my personal knowledge, state the following: I am employed by Idaho Power Company as the Manager of Regulatory Projects in the Regulatory Affairs Department and am competent to be a witness in this proceeding. I declare under penalty of perjury of the laws of the state of Idaho that the foregoing pre-filed testimony and exhibits are true and correct to the best of my information and belief. DATED this 28th day of June 2073. SUBSCRIBED AND June 201,3. YOUNGBLOOD, Dr 23 Idaho Power Company before ary Pu Residing at: My commission or Idaho {$f '1'(}" olO )t.r $ Jat&.,,ff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION GASE NO. IPC-E-13-16 IDAHO POWER COMPANY YOUNGBLOOD, DI ,TESTIMONY EXHIBIT NO.7 EXHIBIT NO.7 IS CONFIDENTIAL AND WI LL BE PROVI DED TO THE APPROPRIATE PARTIES UPON REAUEST AND EXECUTION OF THE PROTECTIVE AGREEMENT