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BEFORE THE IDAHO PUBLIC UTILIT]ES COMM]SS]ON
IN THE MATTER OE TDAHO POWER
COMPANY'S APPLICATION FOR A
DETERMTNATION VALIDAT]NG A NORTH
VALMY POWER PLANT UNIT 2 CLOSURE
rN 2025.
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
TOM HARVEY
CASE NO. IPC-E-19_18
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present position
"Company").
A. My
is 7227 West Idaho
employed by fdaho
Supply, Plannlng
Department.
O. Pl-ease describe your
A. I have a Bachelor of
in busj-ness management from Boise
attended the University of Idaho's
Please state your name, business address, and
with Idaho Power Company ("Idaho Power" or
name is Tom Harvey and my business address
Street, Boise, Idaho 83'102. I am
Power as the Genera1 Manager of Power
and Operatj-ons in the Power Supply
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educational background.
Business Administration
State University. I also
Utility Executive Course
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13 in 2011.
L4 O. Please describe your work experience with
15 fdaho Power.
L6 A. I was hired by Idaho Power in July 1980 to
Ll work in the Plant Accounting Department. From 1985 through
18 2009, I was the Fuels Management Coordinator and then was
79 promoted to the Joint Projects Manager. In April 2015, I
20 was promoted to Resource Planning and Operations Director.
2I In January 20L8, I was promoted to my current position,
22 General Manager of Power Supply, Planning and Operations in
23 the Power Supply Department. My current responsibilities
24 include supervision over Idaho Power's jointly-owned coal-
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HARVEY, DI 1
Idaho Power Company
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assets, integrated resource planning, load serving
operations, and merchant activities.
O. What is the purpose of your testimony in this
case ?
A. The purpose of my testimony is to present the
results of the North Valmy power plant ("Valmy") Unit 2
cl-osure analyses supporting a December 31, 2025, end-of-
l-if e date.
a What specific action is the Company requesting
("Commission") in10 of the Idaho Pub1ic Utilities Commission
11 this case?
72 Idaho Power is requesting the Commission
sufflciently validated the
Unit 2 as December 31, 2025, ds
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15 in Order No. 34349.
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acknowledge the Company has
economic retirement date of
directed by the Commission
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I. AGREEMENTS A}ID REGI'I,ATORY APPROVAIS
TMPACTING VAIMT OPERJATIONS
. Pl-ease describe the Val-my plant.
. Valmy is a coal--fired power plant that
of two units and 1s located near Winnemucca,
Unit 1 went into service in 1981 and Unit 2
consists
foll-owed in 1985. Idaho Power owns 50 percentr or 284
megawattsl (*MW") (generator nameplate rating), of Valmy.
NV Energy is the co-owner of the plant with the remaining
1 For planning purposes, Idaho Power uses the net dependable
capability of 262 MW.
HARVEY, Df 2
Idaho Power Company
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50 percent ownership and operates the Valmy facility. NV
Energy and Idaho Power (co11ective1y, the "co-owners") work
jointly to make decisions regarding Valmy. The plant is
connected via a single 345 kilovolt transmission 1j-ne to
the Idaho Power control area at the Midpoint substation.
Idaho Power owns the northbound capacity and NV Energy owns
line.this
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the southbound capacity of
O. What are the
Energy and Idaho Power own
A. The ownership
current agreements under which NV
and operate Valmy?
and operation of Valmy 1s
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dictated by three agreements: (1) the Agreement for the
Ownership of the North Valmy Power Plant Project; (2) the
Agreement for the Operation of the North Valmy Power Pl-ant
Project, both of which are dated December 72, 7918,' and (3)
the North Valmy Station Operating Procedures Criteria,
dated as of February Lt, 1993, between Idaho Power Company
and Sierra Pacific Power Company, as amended by Amendment
No. I to the Operating Procedure Criteria for Valmy Coal
Diversion Procedures and Usage, dated as of January 7,
20L2. Additionally, as presented in Case No. IPC-E-19-08,
the co-owners entered into the North Valmy Project
Framework Agreement between NV Energy and Idaho Power,
dated as of Eebruary 22, 2079 ("Framework Agreement"),
memorializing the terms and conditions under which either
partner may elect exit of participation in Va1my. The
HARVEY, Df
Idaho Power
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1 Framework Agreement is effective upon both co-owner's
2 determination of satisfactory regulatory approvals.
3 Q. Have the co-owners received satisfactory
4 regulatory approval of the Framework Agreement?
5 A. Commission Order No. 34349 deemed the
6 Framework Agreement with NV Energy as prudent and
7 commercially reasonable; however, approval of the Eramework
B Agreement from the Nevada Public Utilitles Commission
9 ("Nevada PIJC"lz and the Public UtiJ-ity Commission of Oregon
10 has not yet been received.
11 O. What are the current end-of-life assumpti-ons
72 used by the co-owners for each Valmy unit?
13 A. In its 2018 Update to the Life Span Analysis
74 Process of Valmy Units 1 and 2, NV Energy recommended
15 retirement dates of both unj-ts at year-end 2025.3 However,
16 on December 2L, 2078, in Docket No. 18-05003, the Nevada
2 Joint Application of Nevada Power Company d/b/a NV Enerqy andSierra Pacific Power Company d/b/a NV Energy for approvaf of the second
amendment to its 2018 Joint Integrated Resource Pl-an to update andmodify the foad forecast, the Demand-Side Manaqement Action Pfan, theqeneration portion of the Supply-Side Action Plan, and the Transmission
Action Pfan- Docket No. 19-05003, fifed on May 1, 2079.
3 Application of Sierra Pacific Power Company d/b/a NV Enerqy and
l,/errada Power Company d/b/a NV Energy for approvaf of its 2077-2A36Trienniaf Inteqrated Resource Pfan and 2017-2079 Energy Supply P)an,
2016 Annuaf Demand Side Manaqement Update Report as it refates to the
Action Pfan of its 2075-2035 Integrated Resource PLan, and the second
amendment to its 2016-2035 Integrated Resource PLan and 2016-2018Action PLan to incLude the acquisition of the South Point Energy
Center, Docket No. 16-07001. Updated Life Span Analysis Process in
compliance with order dated February 16, 207'7, filed on Eebruary 16,
2018.
HARVEY, DI 4
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PUC issued an order adopting NV Energy's 20L9-2038
Triennial fntegrated Resource Plan, 2079-2021 Action P1an,
and 2079-202t Energy Supply P1an, all of which included an
early retirement of Unit 1 on
stated conditions.4
December 31, 202L, under NV
NV Energy's stated conditionsEnergy's
include:
northern
achieve
(1) demonstrative evidence that the three new
PV projects and associated
commercial operation by June
storage projects will
2022, (2) NV Energy
customer 1oad, (3)must have adequate capacity to serve
10 there must be sufficient access to capacity and energy in
11 western markets to mitigate cost pressure and allevj-ate a
t2 reduction in flexibility associated with not having power
13 available from Valmy t, (4) a transmission area load of
14 2,800 MW will trigger a reevaluation of retirement of Valmy
15 L, (5) accounting treatment regarding decommissioning Va1my
16 1 must be consistent with other retirement NV Energy
Ll qeneration assets, and (6) the accounting treatment
18 regardlng undepreciated book value must be consistent with
t9 the tracking accounting treatment authorized in prior
20 dockets. The end-of-life date for Unit 2 remained at year-
2L end 2025.5
a Joint Application of Nevada Power Company d/b/a NV Energy and
Sierra Pacific Power Company d/b/a NV Energy for approvaL of their
2019-2038 Trienniaf Integrated Resource Pfan and 2079-2021 Energy
Supply P7an, Docket No. 18-06003 (December 21, 2018).
5 Nevada PUC Order dated December 21, 2078, Document ID 34961
HARVEY, DI 5
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Idaho Power, in the
( "Settlement Stipulation")approved by
stipulation
the Commission with
Order No.33117, agreed to use prudent and commercially
efforts to end its participation in the
of Unit 1 by December 3L, 2079, and Unit 2 by
reasonable
operation
December 37, 2025 .6
O. Does Commisslon Order No. 343491 address the
Company's proposed cessation of Unit 2 operations by
December 3L, 2025?
A. During review of Idaho Power's Application in
settlement
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13 did
No. IPC-E-19-08, Commission Staff ("Staff") indlcated
it reviewed the Company's Unit 2 closure analysis but
not have adequate information from Idaho Power at the
74 time to determine whether completed a
of December 31,
adopted Staff's
efforts to file
15 of a unit
the Company had
withdrawaf datethorough review
2025. In Order
recommendation
L6 No. 34349, the Commisslon
71 that the Company use best
18 within 27 days of the service date of the order: (1) an
2025, economic79 analysis valldating the December 3L,
6In the lulatter of the Application of Idaho Power Company for
Authority to Increase fts Rates for ELectric Service to Recover Costs
Associated with the North VaTmy P7ant, Case No. IPC-E-16-24, Order No.
331'71 (May 31, 2071) .
1 In the Matter of the Applicatlon of Idaho Power Company forAuthority to Increase Its Rates for ELectric Service to Recover Costs
Associated with the North Valny Plant, Case No. lPC-E-19-08 (May 31,
2019) .
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retirement date of Unit 2 or (2) an analysls
different economic retirement date of Unit 2
supporting a
II. T'NIT 2 RETIREMENT ECONOMIC AI{AIYSIS
O. Has Idaho Power completed the analysJ-s
supporting an economic retirement date of Unit 2?
A. Yes. The Company's analyses can be grouped
into three general categories: (1) a Long-Term Capacity
Expansion ("LTCE") analysis performed during the
development of the 2019 Integrated Resource Plan ("IRP");
(2) a portfolio cost comparison between a 2019 Unit 2
shutdown and a 2025 Unit 2 shutdown under the planning
assumptj-ons from the 20L9 IRP; and (3) a comprehensive
Valmy verification for all 24 portfolios modeled in the
IRP, including alI costs and benefits associated with the
Framework Agreement.
O. Please describe the analysis performed
of the 2019 IRP.concurrently with
A. The
the deveJ-opment
Settlement Stipulation
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L9 Commission with Order No. 33111 in Case
approved by the
No. IPC-E-76-24
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2L analyses as part of the Company's 20L9 IRP and perform a
Unit 2 closure validation study to evaluate a least
cost/least risk cl-osure date. Because the 20L9 IRP was in
the development phase at the time the Company filed 1ts
request in Case No. IPC-E-19-08, Idaho Power relied on the
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Idaho Power
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newly executed
schedules as an
Eramework Agreement and
indication that there
associated fee
1ike1y no economic
2 prior to
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benefit associated with the exit of Unit
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December 37, 2025.8 However, concurrent with the processing
of Case No. IPC-E-19-08 and 1n conjunctj-on with the
development of the 20t9 IRP, Idaho Power developed 24
resource portfolios using the LTCE capability of the AURORA
model to analyze whether exiting Unit 2 prior to 2025 would
benefit customers.
What is the goal of the IRP?
the IRP are to ensure: (1) IdahoThe goals of
Power's system has sufficient
customer demand and ffexibl-e
resources to reliably serve
capacity needs
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planning perlod; (2)
bal-ances cost, risk,
over a 2)-year
portfolio
and environmental concernsi (3)
balanced treatment is given to both supply-side resources
and demand-side measures; and (4) the public is invol-ved in
the planning process in a meaningful way.e Historically,
the Company developed portfol-los to el-iminate resource
deficiencj-es identified in a 20-year load and resource
balance. Under this process, Idaho Power developed
portfolios
eliminate
which were quantiflably demonstrated to
the identified resource deficienci-es, and
the sel-ected resource
8 Case No. IPC-E-19-08, Harvey,
e 2079 Integrated Resource PJ-an,
DI, pages 2l-23.
Case No. IPC-E-19-t9, page 1.
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qualitatively varied by resource type,
resource types reflected the Company's
the financial performance of a resource
on future conditions in energy markets
However, beqinning with the 20L9 IRP,
using the AURORA model's LTCE modeling
develop portfolios. lo
where the varied
understanding that
class is dependent
and energy policy.
the Company began
capability to
scenarios are formulated
used to develop portfol-ios
alternative future
portfolios for the
AURORA model- selects from
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a. Please describe the LTCE modeJ-ing capability
of AURORA.
A. The LTCE capabllity of AURORA produces a
Western El-ectricity Coordinating Council- (*WECC")
optimized portfolio under various future conditj-ons, such
as varying assumptions for natural gas prices and carbon
costs. The V[ECC-optimized portfolio includes the addition
of supply- and demand-side resources for Idaho Power's
system while simultaneously evaluating the economics of
exiting from current generation units.
the AURORA LTCE modeling
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process, the
first, then
specifically, under
afternative future
the AURORA model is
that are optimal to the selected
scenarios. To develop optimized
alternative future scenarios, the
2079.
10 The 2019 IRP will be fil-ed i-n Case No. IPC-E-19-19 on June 28,
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a variety of
available to
those given
are optimal for
O. What are the existing supply- and demand-side
resource options available to AURORA?
A. Existing supply-side resources include
generation resources and transmlssion import capacity from
Existing demand-sideregional wholesale el-ectric markets.
resources incl-ude current levels of demand response as wel-I
as savings from current energy efficiency programs and
measures, which are reflected as a decrement to the load
forecast.
O. How does the AURORA modeling meet the planning
margin and regulating reserve requirements objectives?
A. First the AURORA model will account for the
capability of the existing system and then, when the
existi-ng system comes short of meeting the objectives, will
select from a pool of new suppJ-y- and demand-side
resources. The general iterative methodology for the LTCE
logic is that for each LTCE iteration, the entire set of
candidate new resource options and retirements are
avail-able to the system and the model- performs the standard
chronol-ogical commitment and dispatch logic under each
future scenario. The model tracks the performance of all-
new resource options and resources available for
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supply- and demand-side resource options
it, developing portfolios that
alternative future scenarios.
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retirement,
the market
of each iteration, the LTCE logic decides how
current set of new builds and retirements, or
that the model has converged on a solution.
behind the LTCE model seeks to create a mix
tracking the resource costs and value based on
prices developed in the iteration.At the end
to adjust the
it determines
The logic
of resources
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that are most economic while adhering to future capacity
needs and meeting
O- How
reliability constraints .
does Idaho Power define the new supply-
10 and demand-side resources in AURORA?
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1s set by Idaho
new suppJ-y- and demand-side
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Advisory
2079 IRP
biomass,
turbines,
engines,
response,
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Counci1 process. The new resources used in the
AURORA modeling include solar, geothermal-, wind,
combined-cycle combustion turbines, simple cycle
reciprocating internal- combustion turbine
nuclear, battery storage, pumped storage, demand
and energy efficiency.
O. What happens once AURORA forms the portfol-ios?
A. Once formed, the portfol-ios are evaluated for
operational, environmental, and qualltative considerations,
and cul-minate into an action plan that sets the stage for
the Company to economically and effectively prepare for the
system needs of the future. The resulting combination of
resources provides a reliable portfolio to supply cost-
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effective power to Idaho Power's customers over the 2}-year
planning period.
A. LTCE Analysis.
O Pl-ease describe the
scenarios performed for
A. The AURORA
AURORA LTCE modeling
]RP.
LTCE modeling was performed using
three natural gas and four carbon emissj-ons adders to
develop optimized resource portfolios for a range of
possible future conditions, with the Boardman-to-Hemingway
transmission line project and without. Twenty-four
separate portfolios were developed which included varied
amounts of nameplate generation additions, creating a
di-versity of resource mixes, including wind, solar, natural
gas reciprocating engines, natural gas combined-cycIe
combustion turbines, demand-side management, battery
storage, pumped storage, biomass, and additional
accel-eration of the Jim Brldger power plant unit
retirements. The diversity of resource mj-xes in the 24
portfolios illustrates the many combinations of resources
that resul-t in a rel-iable system for customers at varying
costs.
O. How did Idaho Power use the 24 AURORA LTCE
modeling resource portfolios to validate a Valmy Uni-t 2
cl-osure of 2025?
HARVEY, DI 72
fdaho Power Company
the 2079
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Idaho Power modeled the 24 portfolios to
validate a Unit 2 shutdown date of 2025. It is lmportant
to note that the logic of the capacity expansion model
allowed Unit 2 Lo retire in 2025 or earlier in these AURORA
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LTCE model
down prior
the final
runs. In a1l- 24 scenarios, Unit 2 did not shut
to 2025. However, these runs did not include
costs and benefits associated with the newly
executed Eramework Agreement.
Based upon these initial results, to reduce model-
10 runtime during final capacity expansion runs, Idaho Power
11 l-eft the Unit 2 shutdown date static at 2025. Although the
72 preliminary runs did not include the flxed costs required
13 to keep the plant in operation or the exlt fees associated
L4 with the Framework Agreement, fdaho Power did not believe
15 the inclusion of the Framework Agreement costs and savings
L6 would result 1n any materj-af impact to the modeling
11 results.
18 B. PortfoJ.io Cost Comparison.
L9 O Dld the Company compare the costs of the 2025
scenarios ?
To compare the net cost and benefits of
20 and 2019 shutdown
2T A Yes.
22 Unit 2 shutdown, Idaho Power did an
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an early
planning
costs and
this time
natural gas and
savings of the
forced Unit 2
carbon assumptions
Framework Agreement
analysis using
with the fu1l
incl-uded, but
to shut down in 2079. The Company
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compared this portfolio cost to that of its 2019 IRP
preferred portfolio, which includes a 20L9 and 2025
shutdown for Units 1 and 2, respectively. The result,
which is summarized in Exhibit No. 7, was a portfolio cost
of approxlmately $95 million more than the preferred
portfollo/ supporting the concl-usion that the net cost
savings associated with an
not support a shutdown of
early retlrement of Unit 2 would
Unit 2 prior to 2025.
Did the Company run a slmilar cost
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by modeling
etc. ?
A.
a forced Unit 2 retirement for 2020,
comparison
2021,
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No.
13 2019 exit provide
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$95 million more costly than a 2025 shutdown, a forced
shutdown in any year between 2019 and 2025 would not result
in a l-ower cost than the 2025 shutdown date. The 20L9
shutdown date allows for the maximum amount of potential
cost avoidance with respect to required capJ-taI and
operations and maintenance ("O&M") expendj-tures; therefore,
1f t.his scenario is higher cost than the year-end 2025
shutdown scenario, a shutdown date durlng any of the
interim years between 2020 and 2024 would not result in any
additional cost savings that woul-d support a shutdown date
prior to year-end 2025.
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The modeling
bookends that
of a 2025 exlt and a forced
render the modeling of the
a Unit 2 shutdown in 2019 is
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1 C. Comprehensive Val.my Verification.
O. Please describe the comprehensive Valmy
analysls the Company performed to val-idate the Unit 2 2025
shutdown date.
A. In addition to the IRP analysis detailed
earlier in my testimony, and the portfolio cost comparison
between a 201-9 shutdown and a 2025 shutdown, Idaho Power
ran the capacity expansi-on model for all 24 portfollo
scenarios with the full- costs and savings of the Framework
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approach,
any year
beneflts
prlor to 2025,
assoclated with
included as inputs
the LTCE model was
to the model. Under thls
allowed to shut down Unit 2 in11
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resulti-ng from
expenditures,
inputs to this
taklng into account al-l- costs and
an early exiti L.e.r exit fees
the Eramework Agreement, avoided capital
and avoided O&M expense. The Va1my-speciflc
model are included in Exhibit No. 2.
71 O What were the results of the comprehensive
18 Valmy model runs?
I9 A11 24 portfolios validated a Unit 2 closure
20 of 2025 as the Ieast cost option because each of the
27 modeled scenarios shut down Unit 2 Ln 2025. It is
22 important to note that thls analysis included a model run
23 that reflected the least favorable coal scenario that is
24 most likely to result in early coal closure-the high
scenario. Even under this "least
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Idaho Power Company
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favorable" coal scenario, Unit 2 was shown to be needed and
cost-effective until the end of 2025.
0. What concfusions can be drawn from these
results?
A These results indicate that, under the broad
range of modeled scenarios, in no case is it economically
Given the factbeneficial to exit Unit 2 pr|or to 2025.
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that these models included al1
associated with an early exit
val-idates year-end 2025 as the
both depreci-ation purposes and
from the Valmy plant.
33'71t, Idaho Power performed
part of the 2079 IRP process.
AURORA modeling affords Idaho
an optimized portfolio under
such as varying assumptions
carbon costs, i-ncluding the
Unit 2 closure analyses as
The LTCE capabllity of the
Power the ability to produce
various future conditions,
for natural gas prices and
addltion of
costs and benefits
supply- and demand-
while
expected
from Unit 2,this analysis
exit date forappropriate
the Company's planned exit
III. CONCLUSION
Please summarize your testimony.
As directed by the Commission in Order No.
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22 side resources for Idaho Power's system,
23 simul-taneously evaluating the economics of exiting from
24 current generation unj-ts. The AURORA LTCE modeling
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HARVEY, DT
Idaho Power
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1 nameplate generation additions, creating a dj-versity of
2 resource mixes. To validate a Valmy Unit 2 shutdown date
3 of 2025, Idaho Power performed a LTCE analysis of the 24
4 portfol-ios. In all 24 scenarios, Unit 2 did not shut down
5 prior to 2025, validating a December 37, 2025, end-of-life
6 date. Further, when forcing the model to shutdown Unit 2
7 in 20L9 (the year with the greatest potential for cost
8 avoidance), total portfolio costs exceeded the 2025
9 shutdown scenario by approximately $95 million. For these
10 reasons, 2025
Unit 2.
o.
A.
is the appropriate end-of-life date for Valmy
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72 Does thls complete your testimony?
13 Yes, it does.
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ATTESTATION OF TESTIMONY
STATE OE IDAHO
County of Ada
l, Tom Harvey, having been duly sworn to testify
truthfully, and based upon my personal knowledge, state the
following:
I am employed by Idaho Power Company as the General
Manager of Power Supply, Planning and Operations in the
Power Supply Department and am competent to be a witness j-n
this proceeding.
I declare under penalty of perjury of the laws of
the state of fdaho that the foregoing pre-fil-ed testimony
and exhibits are true and correct to the best of my
information and belief.
DATED this 27th day of June 201,9.
0>\
Tom Harvey
SUBSCRIBED AND SWORN to before me this 2'7th day of
24 June 20L9.
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Notary Publ-ic for Idaho
Residing at:Meridian Idaho
My commission expires:02/04/2027
HARVEY, DI 18
Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-19-18
IDAHO POWER COMPANY
HARVEY, DI
TESTIMONY
EXHIBIT NO. 1
PORTFOLIO COST COMPARISON
($ x 1000)
Portfolio 14
(Planning NG, Planning
Carbon, 82H)
Portfolio 14
Valmy Both Units
Retired YE 2019
(Planning NG, Planning
Carbon, B2H)
Val YE 2019 B2H Difference
20L9 s
S
s
s
s
s
s
S
S
s
S
s
s
s
s
s
s
s
s
S
480,505.05
476,277.97
504,767.O3
490,381.55
525,915.06
544,763.60
569,804.06
556,520.50
580,672.44
596,907.25
634,593.70
559,529.30
683,8L7.44
708,074.20
772,555.06
733,707.50
732,997.40
737,929.60
749,797.60
795,897.44
s
s
s
S
S
s
s
s
s
S
s
s
S
S
s
s
s
s
s
s
480,611.80
476,424.78
504,7Lt.66
516,039.80
546,309.44
568,150.00
595,069.44
561,381.05
584,785.00
595,480.56
554,191.50
658,314.00
690,325.44
772,757.40
7L4,802.94
738,584.50
769,270.25
770,152.44
773,573.20
799,095.50
S
s
S
S
S
s
S
s
s
s
s
s
S
S
s
s
s
s
S
5
s
s
s
s
6.74
212.8L
(ss.38)
25,658.14
20,394.38
23,386.40
25,265.38
4,860.56
4,772.56
(426.6st.
19,597.80
8,784.70
6,508.00
4,077.20
2,247.88
4,877.00
36,278.85
32,222.84
23,775.60
3,198.06
2020
202L
2022
2023
2024
2025
2026
2027
2028
2029
2030
203t
2032
2033
2034
2035
2035
2037
2038
NPV S 5,028,3L0.40 s 5,123,368.80 95,058.40
82H S112,488.63 S112,488.G3
Bridger Fixed Cost NPV So.oo So.oo
TOTAI NPV s 5,1N,799.O3 s 5,235,857.43 95,058.40
Exhibit No. 1
Case No. IPC-E-19-18
T. Harvey, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-I9-18
IDAHO POWER COMPANY
HARVEY, DI
TESTIMONY
EXHIBIT NO.2
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Case No. IPC-E-19-18
T. Harvey, IPC
Page 1 of 1
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