20220216Amended Application and Motion to Set Schedule.pdf

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An loAcoRPcompimY
LISA D. NORDSTROM
Lead Counsel
[e-mail]
r.r . ,, r r.!t 'i. I ?,:..'iil lli U'rL
February 16,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. )PC-E-21-17
ln the Matter of the Application of ldaho Power Company for Authority to
lncrease lts Rates for Electric Service to Recover Costs Associated with the
Jim Bridger Power Plant
Dear Ms. Noriyuki
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho Power
Company's Amended Application and Motion to Set Schedule in the above matter.
ln addition, attached is the Supplemental Direct Testimony of Matthew T. Larkin filed
in support of the Amended Application and Motion to Set Schedule. Word versions are also
attached for the Reporter.
!f you have any questions regarding the attached documents, please do not hesitate
to contact me.
Very truly yours,
- - ,.-* r .''ia
,:.,:.Lt-*'
X*!-fl"1.t"-*,
Lisa D. Nordstrom
LDN:sg
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF IDAHO POWER
COM PANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO
RECOVER COSTS ASSOCIATED WTH
THE JIM BRIDGER POWER PLANT.
CASE NO. IPC-E-21-17
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE
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ldaho Power Company (ldaho Power or Company), in accordance with ldaho Code
S 61-502, 61-503, 61-524,61-525, as well as RP 052, 056, 121, and 125, hereby
respectfully makes application to the ldaho Public Utilities Commission (Commission) for
an order authorizing ldaho Power to (1) accelerate the depreciation schedule for all coal-
related Jim Bridger Power Plant (Bridger) investments to allow for full depreciation and
recovery by December 31, 2030, (2) establish a balancing account, and the necessary
regulatory accounting, to track the incremental costs and benefits associated with ldaho
Power's cessation of participation in coal-fired operations at Bridger, and (3) adjust
customer rates to recover the associated incremental annual levelized revenue
requirement of $27.13 million with an effective date of June 1 , 2022, which equates to an
overall increase of 2.12 percent.
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 1
ln support of this Amended Application, ldaho Power asserts as follows:
I. INTRODUCTION
1. ldaho Power appreciates the Commission and other parties' understanding
of the need for the suspension of the procedural schedule in this case until more
information was known concerning Bridger emissions limits and possible coal-to-gas unit
conversions. ldaho Power and Commission Staff filed a Joint Motion to Suspend
Procedural Schedule on October 1,2021, because, at the time, the U.S. Environmental
Protection Agency (EPA) had not taken formalaction responding to \Afroming's proposed
State lmplementation Plan (SlP) Revision, which would ensure Regional Haze
compliance of Bridger Units 1 and 2 effective January 1,2022. ln addition, in September
2021, PacifiCorp submitted to the Commission their 2021 IRP in Case No. IPC-E-21-'19
which included an Action Plan envisioning the cessation of coal-fired generation at Units
1 and 2 in 2023 with a natural gas conversion of those units in 2024. On November 17,
2021, the Commission issued Order No.35222, suspending the procedural schedule in
this case.
2. On December 30, 2021, the Company filed an update with the Commission,
notifoing the parties that the EPA had not yet formally acted on Vlffoming's SIP Revision
which othenuise would require emission controls to be in place for Unit 2 by December
31, 2021, and for Unit 1 by December 3'1, 2022. In the status update, ldaho Power
expfained that on December 27, 2021, \Afoming Governor Mark Gordon issued a
temporary emergency suspension, extending the compliance date of Unit 2 through Apri!
30,2022, while PacifiCorp awaited approvalof the hfioming SIP Revision. ldaho Power
requested the Commission continue the current schedule suspension and committed to
convene a conference with parties to discuss the reopening of the procedural schedule
no later than April 30,2022.
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 2
3. On February 7,2022, the Company met with parties, providing an update
on EPA actions regarding Bridger Regional Haze compliance and the results of Idaho
Power's 2021 IRP regarding the potential conversion of Units 1 and 2 to natural gas
generation. The Company discussed filing an amended application to resume processing
of this case.
4. ldaho Power's amended quantification of the Bridger levelized revenue
requirement includes onlv coal-related assets and removes from the original request all
investments that will remain in service for natura! gas operations and associated natural-
gas related costs in accordance with the planned natural gas conversion of Bridger Units
1 and 2 as presented in the Company's 2021 lntegrated Resource Plan (lRP). While
ldaho Power initially requested a rate base increase of $30.83 million, the Company's
proposed amended base rate revenue increase is $27.13 million, or 2.12 percent, to
become effective June 1 ,2022.
!I. THE BRIDGER PLANT
5. The Bridger plant located near Rock Springs, V[oming consists of four
generating units. PacifiCorp has two-thirds ownership and is the operator of the facility.
ldaho Power owns one-third, or 771 megawatts (MWl of Bridger. Unit 1 began
commercial operation in 1974, Unit 2 in 1975, Unit 3 in 1976 and Unit 4 in 1979. ldaho
Power's one-third share of the units' nominal net (or "net reliable") generation capacities
are 177 MW, 180 MW 174 MWand 175 MW, respectively. The Company and PacifiCorp
(collectively, the Co-Owners) work jointly to make decisions regarding the plant, including
required investments and the retirement of the plant.
6. The plant is connected to the Borah West transmission path west of the
Borah Substation near American Falls, ldaho. ldaho Powe/s one-third share of energy
from Bridger flows west over this path. The ldaho-Vfoming path, or Bridger West,
1 Generator nameplate rating.
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 3
consists of three 345 kV transmission lines between Bridger and southeastern ldaho. The
Company owns 800 MW of the 2,400 MW east-to-west capacity which effectively feeds
into the Borah West path when power is moving east to west from Bridger.
7. The Bridger plant is adjacent to Idaho Power and PacifiCorp's co-owned
Bridger Coal Company mine, which currently supplies sub-bituminous coal to the plant.
Additionally, sub-bituminous coal is currently delivered to Bridger from the BIack Butte
mine via rail. Coalcombustion residuals are disposed of on plant property in a solid waste
Iandfill and a flue gas desulfurization waste surface impoundment. The plant also utilizes
evaporation ponds, which makes it effectively a "zero-discharge" facility.
8. The ownership and operation of Bridger is dictated by three agreements:
the Agreement for the Ownership of the Jim Bridger Project between ldaho Power
Company and Pacific Power & Light Company, the Agreement for the Construction of the
Jim Bridger Project between ldaho Power Company and Pacific Power & Light Company,
and the Agreement for the Operation of the Jim Bridger Project between ldaho Power
Company and Pacific Power & Light Company, all of which are dated September 22,
1969, as amended by Amendments 1 through 9 (collectively, Bridger Agreements). The
Bridger Agreements set forth the respective obligations of the Co-Owners with respect to
the ownership, construction and operation of Bridger.
III. BRIDGER COAL-RELATED INVESTMENTS SINCE 201{
9. Numerous investments have been required to operate the plant in a safe,
efficient, and reliable manner, including investments required to ensure environmenta!
compliance as well as a number of investments for routine maintenance and repair. The
Company is requesting a prudence determination on incremental Bridger coal-related
investments since the last rate case, Case No. IPC-E-11-08, or those coal-related
investments made at the plant during the January 1,2012, through December 31,2020,
time period. Exhibit No. 3 to the direct testimony of Company witness Ryan N. Adelman
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 4
presents ldaho Power's share of all investments made at Bridger since 2011, detailing
841 different projects totaling $266.3 million. For those projects for which ldaho Power's
ownership share is over $1 million, the Company has included a project description and
investment purpose classification as to whether the investment was for environmental
compliance or for reliability.2
10. The investments made at Bridger for environmental compliance make up
nearfy 50 percent of the total Bridger investments since January 1, 2012, with the two
largest being the selective catalytic reduction (SCR) controls installation on Units 3 and
4. Aside from the SCR controls, other projects include mercury controls additions on all
four units, replacement of the catalyst of the SCR control on Unit 3, modifications to the
coal combustion residuals effluent system, and the relining of the scrubber absorber lining
on Unit 4.
11. ldaho Power also funded investments required for the Bridger plant to
reliably operate. There were 15 investments greaterthan $1 million including an upgrade
to the Bridger Unit 2 turbines, the replacement of the finishing superheater within the
boiler of all four units, the replacement of the cooling towers on Units 1 ,2 and 3, an update
to the air preheater baskets on all four units, and the replacement of the pendant platens
within the superheater on Unit 1.
IV. BRIDGER ACCELERATED DEPRECIATION
12. Changing conditions have resulted in an expected exit from participation in
operations of Bridger that is several years earlier than what is currently reflected in
customer rates. ldaho Power's Second Amended 2019 IRP acknowledged in Case No.
IPC-E-19-19 identified a preferred portfolio that included early Bridger unit exits in 2022,
2 While ldaho Power's request in this case is for a prudence determination of Bridger coal-related
investments only, because the estimate of those investments was performed at the plant account level,
the Company cannot precisely determine the portion of the additions presented in Exhibit No. 3 that are
coal-related investments only, and therefore has presented all Bridger investments made during the
January 1,2012, through December 31,2020, time period.
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 5
2026,2028, and 2030. The2021 IRP Preferred Portfolio, filed in Case No. IPC-E-2143,
includes the conversion of Units 1 and 2 from coal to natural gas by the summer of 2024
with a 2034 exit date, and the exit of coa!-fired operations in Units 3 and 4 by year-end
2025 and 2028, respectively. With a current depreciable life of 2034, the 2021 IRP
continues to indicate that an earlier exit from coal-fired generation at Bridger would
provide a more favorable economic outcome as compared to the current end-of-life
assumption of 2034.
13. The suspension of the procedural schedule in this case reduces the
collection period for which recovery of Bridger coal-related revenue requirement occurs.
With exit dates of coal-fired operations approaching and decommissioning costs that will
be incurred on the horizon, ldaho Power believes a depreciable life of year-end 2030 for
all units is appropriate as itwill help minimize revenue requirement impacts to customers.
This method is similar to the Commission-approved cost recovery treatment for the North
Valmy power plant, whereby depreciation expense recovery for both of the two units goes
through 2028, even though ldaho Powe/s participation in coal-fired operations will have
ceased by 2025.3
V. REGULATORY ACCOUNTING AND RATEMAKING TREATMENT
14. ldaho Power believes it will exit coal-fired operations of Bridger by 2028,
earlier than the current depreciable life of 2034. ln addition to the earlier cessation of
coa!-fired operations, Bridger will require incremental coal-related investments to
maintain operations prior to the decommissioning of the plant. However, the specific
timing and exact amounts of these future investments are not yet known. For these
reasons, the Company proposes the establishment of a balancing account that would
3 ln the Mafter of the Application of ldaho Power Company for Authoity to lncrease /fs Rafes for Electric
Service to Recover Cosfs Associated with the Nofth Valmy Plant, Case No. IPC-E-'16-24, Order No.
33771 (May 31,2017)
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 6
allow flexibility for the timing and recovery of the remaining Bridger coal-related
investment reven ue requ irement.
15. There are four types of costs the Company anticipates recording to the
balancing account: (1) the accelerated depreciation associated with existing Bridger coal-
related investments, (2) the return on the undepreciated coal-related investments at
Bridger, (3) non-fuel operations and maintenance (O&M) expense reductions, and (4)
interim decommissioning costs related to the Bridger shutdown. Under the balancing
account approach, the Company replaces the base rate revenue recovery associated
with Idaho Power's existing coal-related investment in Bridger with a levelized revenue
requirement and tracks it in the Bridger balancing account, smoothing revenue
requirement impacts associated with the exit of Bridger coal-fired operations and allowing
for full recovery of Bridger coa!-related costs near the time ldaho Power ceases
participation in coal-fired operations. This will more closely align the cost recovery period
with the Company's remaining participation in Bridger coa!-fired operations and ensure
customers will pay no more or no less than the actual coal-related O&M and capital coal-
related costs of the Bridger plant beginning June 1,2022.
16. The proposed accounting treatment will accelerate depreciation expense
related to all Bridger coal-related plant investments as compared to the current
depreciable life based on a 2034 retirement date. There will be required coal-related
investments at the plant in addition to its normal maintenance in order to keep coal-fired
operations until that time. ldaho Power proposes to track the coal-related investment
return and associated depreciation expense in the balancing account. ln addition, the
Company proposes to track Bridger coal-related interim decommissioning costs and O&M
savings in the balancing account.
AMENDED APPLICAT]ON AND
MOTION TO SET SCHEDULE - 7
17. To accomplish a coal-related levelized revenue requirement collection
period beyond the operational life of some of the Bridger units, ldaho Power is requesting
the Commission issue an accounting order that allows the Company to make the needed
accounting entries, including a regulatory asset account, thatwould allow forthe matching
of Generally Accepted Accounting Principles (GAAP) revenue recognition and related
costs with the actual monthly pattern of the Bridger coal-related revenue requirement as
compared to the levelized collection method and for collection of decommissioning costs
that occur beyond 2030. ln addition, because the Company will be required to make
income tax filings and accounting entries consistent with the economics that actually
occur rather than the levelized assumption, the regulatory accounts are required to adjust
the financial statement impacts resulting from the timing of Bridger-related GAAP
accounting and income tax results.
18. As described more fully in the direct testimony and supplemental direct
testimony of Company witness Matthew T. Larkin, ldaho Power requests recovery of the
coal-related levelized revenue requirement that includes costs of accelerating the
depreciation of the Bridger coal-related plant items, the return associated with coal-
related capital investments net of accumulated depreciation forecasted through the
Company's participation in coa!-fired operations of Bridger, interim decommissioning
costs associated with Bridger's coa!-fired operations, and O&M savings associated with
non-fuel coal-related O&M reductions. The ldaho jurisdictional Bridger coal-related
incremental annual levelized revenue requirement ldaho Power is requesting to recover
in this proceeding is $27,127,333. The following table presents the differences between
each component as quantified in the Company's initial request and the amounts that
reflect a Bridger coal-related investment levelized revenue requirement only:
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 8
June 2021
Request
February 2022
Amended Request % Change
Plant lnvestment $73,470,945 $52,121,340 Q9.11
lnterim Decomm Costs $59.318 $64.449 8.6
O&M Savinqs ($5.736.719)($4.391.349)(23.5)
Levelized Rev Req $67.793.544 $47,794,440 (29.5)
Rev Req in Rates ($36.967.815)($20.667.107)@4.11
Net Chanqe $30.825.729 $27.127.333 (12.0)
19. The Company proposes to allocate the increase related to the Bridger coa!-
related balancing account using the jurisdictiona! separating study methodology
consistent with that utilized to determine the ldaho jurisdictional revenue requirement in
Case No. IPC-E-11-08. ldaho Power requests that the incremental revenue requirement
of approximately $27.13 million be recovered from al! customer classes through a uniform
percentage increase to all base rate components except the service charge. The
proposed change equates to an overa!! increase of 2.12 percent (see Attachment No. 1).
20. On March 15, 2022, and Apri! 15, 2022, ldaho Power will submit to the
Commission its annual adjustment mechanism filings, the Fixed Cost Adjustment (FCA)
and Power CostAdjustment (PCA), respectively, which will include an update to customer
rates effective June 1,2022. By the time the first request is filed, the Company will have
a revised load forecast for which to base customer rates and compute revenue impacts.
To align the test period in this case with that of the FCA and PCA cases, ldaho Power will
supplement Attachment No. 1 to the Amended Application in this case with a more current
revenue impact and overall proposed increase change on March 15,2022.
VI. PROPOSED TARIFF
2'1. Because the test period used to determine customer rates necessary to
recover the incrementa! revenue requirement of approximately $27.13 million will be
updated at the time Company's FCA requested is filed on March 15,2022,1daho Power
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 9
will file one set of proposed tariff sheets specifying the proposed rates for providing retail
electric service to customers in the state of ldaho at that time. The Company believes
that filing individual sets of tariff sheets now, and a revised set on March 15,2022, as
required by RP 121.0'1, would be administratively complex and would not aid the
Commission and interested parties with their review of these proposed rate adjustments.
ln addition, at that time, ldaho Power will file a comparison of revenues from the various
tariff customers under ldaho Power's existing rates to the corresponding new revenue
levels resulting from the proposed Bridger ratemaking treatment as well as the proposed
FCA and PCA rates, reflecting the proposed combined overall rate change to take effect
June 1,2022.
VII. MODIFIED PROCEDURE
22. The Company believes that a hearing is not necessary to consider the
issues presented herein, and respectfully requests that this Amended Application be
processed under Modified Procedure; i.e., by written submissions rather than by hearing.
RP 201, ef seg. lf, however, the Commission determines that a technical hearing is
required, the Company stands ready to present its testimony and support the Application
in such hearing.
VIII. COMMUNICATIONS AND SERVICE OF PROCEEDINGS
23. ldaho Power brought its initial Application, filed on June 2,2021, to the
attention of ldaho Powe/s customers by means of both a press release to the media in
the Company's service area and a customer notice distributed in customers' bills. To
minimize the potential for customer confusion, ldaho Power will notiff customers of the
final potential impact of this amended request in the "combined impact" table of rates
proposed to take effect June 1 , 2022, associated with each of the annual adjustment
mechanism filings. ldaho Power will keep its Amended Application open for public
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 1O
inspection by appointment at its offices throughout the state of ldaho. ldaho Power
asserts that this notice procedure satisfies the Commission's Rules of Practice and
Procedure; however, the Company will, in the alternative, bring the Amended Application
to the attention of its affected customers through any other means directed by this
Commission.
24. Service of pleadings, exhibits, orders, and other documents relating to this
proceeding should be served on the following:
Lisa D. Nordstrom
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
lnordstrom@ida hopower. com
dockets@idahopower. com
Matt Larkin
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
mla rkin@id ahopower.com
IX. MOTION TO SET SCHEDULE
25. ldaho Power invited the Commission Staff and intervenors to a February 7,
2022, discussion of the Company's amended request and the next steps to resume
processing this case. Representatives from the Commission Staff, Clean Energy
Opportunities (CEO), the City of Boise, the lndustrial Customers of ldaho Power (lClP),
the ldaho Conservation League (lCL), and Micron Technology participated. All partiesa
support adoption of the following procedural schedule:
April29, 2022: Party Comments
May 13,2022: Simultaneous Reply Comments
May 18,2022: ldaho Power Final Comments
June 1 ,2022: Rates effective
Pursuant to Rule of Procedure 56, the Company requests that the Commission adopt this
proposed schedule with rates effective June 1 ,2022, which will minimize rate changes to
customers in the near-term and rate impacts over time. ldaho Power appreciates the
a The Sierra Club was unable to attend the discussion on February 7 ,2022, but subsequently advised
ldaho Power of its support.
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 11
support and flexibility of other parties and the Commission as the Company reworked its
Application to reflect operational and regulatory changes occurring in realtime.
X. REQUEST FOR RELIEF
26. ldaho Power respectfully requests the Commission issue an order
authorizing ldaho Power to (1) accelerate the depreciation schedule for all coal-related
Bridger investments to allow for full depreciation and recovery by December 31 ,2030, (2)
establish a balancing account, and the necessary regulatory accounting, to track the
incremental costs and benefits associated with ldaho Power's cessation of participation
in coal-fired operations at Bridger, and (3) adjust customer rates to recoverthe associated
incrementa! annual levelized revenue requirement of $27.13 million with an effective date
of June 1,2022, which equates to an overall increase of 2.12 percent.
DATED at Boise, ldaho, this 16th day of February 2022.
"(,*. !.Y"1-t -*,
LISA D. NORDSTROM
Aftorney for ldaho Power Company
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16th day of February 2022,1 served a true and
correct copy of ldaho Power Company's Amended Application and Motion to Set
Schedule upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Taylor Brooks
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customer of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 N. 6th Street
Boise, ldaho 83701
City of Boise
Ed Jewell
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701 -0500
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE - 13
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Glean Energy Opportunities for ldaho, lnc.
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.,
Boise, ldaho 83703
Michael Heckler
Courtney White
Clean Energy Opportunities for ldaho
3778 Plantation River Drive, Suite 102
Boise, lD 83703
Sierra Club
Rose Monahan
Ana Boyd
2101 Webster Street, Suite 1300
Oakland, CA94612
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Micron Technology, !nc.
Jim Swier
8000 S. FederalWay
Boise, lD 83707
AMENDED APPLICATION AND
MOTION TO SET SCHEDULE.14
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o\tal- 1 Gc,.^+.-
Stacy Gust, Regulatory Administrative
Assistant
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-17
IDAHO POWER COMPANY
AMENDED APPLICATON
ATTACHMENT NO. 1
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