20211001Joint Motion to Suspend Procedural Schedule.pdf

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LISA D. NORDSTROM
Lead Counsel
[e-mail]
October 1,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A(837141
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-21-17
ln the Matter of ldaho Power Company's Application for Authority to
lncrease lts Rates for Electric Service to Recover Costs Associated with the
Jim Bridger Power Plant
Dear Ms. Noriyuki
Attached for electronic filing, pursuant to Order No. 35058, please find Joint Motion
to Suspend Procedural Schedule.
lf you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
o€;!.fl"*t"--,
Lisa D. Nordstrom
LDN:sg
Enclosure
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]
Inordstrom@ idahopower.com
Attorney for ldaho Power Company
ERICK SHANER (lSB No. 52141
Deputy Aftorney General
ldaho Public Utilities Commission
P.O. Box 83702
Boise, ldaho 8372-0074
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER PLANT
CASE NO. tPC-E-21-',17
JOINT MOTION TO SUSPEND
PROCEDURAL SCHEDULE
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Pursuant to Procedural Rule 056, ldaho Power Company (ldaho Power or
Company) and the ldaho Public Utilities Commission Staff (StafD (collectively the
"Movants') submit this Motion to Suspend the Procedural Schedule to the ldaho Public
Utilities Commission (Commission) in the above-captioned case. As described in more
detail below, the Movants request this suspension to allow Movants the opportunity to
assess this case in light of new developments that may impact operation of the Jim
Bridger Power Plant (Bridger).
JOINT MOTION TO SUSPEND PROCEDURAL SCHEDULE.l
I. BACKGROUND
1. Idaho Power and PacifiCorp jointly own the Bridger plant located in Rock
Springs, Vfoming. Bridger is comprised of four coal-fired units built in the 1970s.
PacifiCorp owns two-thirds of Bridger and is the plant operator; ldaho Power owns one-
third, or 771 megawatts of generator nameplate capacity.
2. On June 2,2021, ldaho Power submitted an Application requesting the
Commission authorize Idaho Power to (1) accelerate Bridger unit depreciation schedules
to allow the plant to be fully depreciated and recovered 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 customers rates to recover the
associated incremental annual levelized revenue requirement of $30.83 million with an
effective date of December 1,2021, which equates to an overall increase of 2.53 percent.
3. On June 24,2021, the Commission issued Order No. 35088 with a Notice
of Application and Notice of lntervention Deadline in this case.
4. Following the intervention period, the Commission issued a Notice of
Parties on July 28,2021. No other case procedure or deadlines have been set to date.
5. Bridger emission controls are required to comply with the Clean Air Act
Regional Haze Rules and the resulting \Afioming Regional Haze State lmplementation
Plan (V1rloming SIP). To mitigate the effects of nitrogen dioxide (NOxl controls for regiona!
haze, selective catalytic reduction (SCR) equipment was installed on Jim Bridger Units 3
and 4 by the dates required by \Affoming in state law and by EPA in the 2014 final rule.
JOINT MOTION TO SUSPEND PROCEDURAL SCHEDULE - 2
6. On February 5,2019, plant operator PacifiCorp submitted to \Afoming an
application and proposed State lmplementation Plan (SlP) revision instituting reduced
plant-wide month-by-month emission limits for NOx and sulfur dioxide (SOz), in addition
to an annual total combined emission cap of NOx and SOz, on all four Jim Bridger units
in lieu of the requirement to install SCR equipment on Units 2 and 1 by December 31,
2021 and 2022, respectively. The proposed SIP revision states that the proposed limits
are more cost effective while leading to better modeled visibility than the SCR installation
on Units 1 and 2 required in the federally approved SIP.1
7. V1rloming's proposed approval of the SIP revision was published for public
comment July 20, 2019, through August 23, 2019. On May 5, 2020, the hfoming
Department of Environmental Quality issued permit P0025809 with PacifiCorp's proposed
monthly and annual NOx and SOz emission limits. Under the permit, the new emission
limits become effective January 1,2022. Vfoming submitted a corresponding regional
haze SIP revision to U.S. Environmental Protection Agency (EPA) on May '14,2020.EPl.
has not taken formal action responding to the SIP revision. Discussions between EPA,
\Afoming, and PacifiCorp regarding the SIP revision and regional haze compliance at Jim
Bridger are ongoing.
8. On September 1, 202'1, PacifiCorp's Rocky Mountain Power business unit
submitted PacifiCorp's 202'l Integrated Resource Plan (lRP) for Commission
acknowledgment in Case No. PAC-E-21-19.
L PacifiCorp's Application for Acknowledgment of the 2021 lntegrated Resource Plan, Case No. PAC-E-
21-19, pp. 55'56 (updated original filed September 15, 2021).
JOINT MOTION TO SUSPEND PROCEDURAL SCHEDULE - 3
9. PacifiCorp's 2021 IRP preferred portfolio and Action Plan envisions the
cessation of coal-fired generation in Bridger Units 1 and 2 in 2023 with a natural gas
conversion of those units in 2024 to meet its load and reliability requirements.2
II. JOINT MOTION
10. Given that it is not possible to substantively respond to discovery requests
in this case until greater clarity is achieved concerning Bridger emission limits and
possible coal-to-gas unit conversion, the Movants respectfully request that the procedural
schedule and discovery be suspended until a procedural schedule can be established.
Once more information is known, ldaho Powerwill make a filing recommending next steps
in this proceeding.
ilt. coNcLUStoN
11. The Movants seek this suspension to allow Movants the opportunity to
assess this case in light of new developments that may impact operation of the Bridger
plant. Once more information is known, ldaho Power will make a filing recommending
next steps in this proceeding.
DATED at Boise, ldaho, this 1st day of October 2021.
X;!.("t-t -,-,
LISA D. NORDSTROM
Attorney for ldaho Power Company
2 ld., pp. 15,24,253,299,322.
JOINT MOTION TO SUSPEND PROCEDURAL SCHEDULE -4
DATED at Borse, tdaho, *', z*, f*20'21.
_L
EHEKSMNET
Attomey br ldaho Public Utilities
Commhsion
JONT MONON TO SUSPEND PROCEDURA 8C[TEDI'1E.5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1st day of October 2021,lserved a true and
correct copy of the Joint Motion to Suspend Procedural Schedule upon the following
named parties by the method indicated below, and addressed to the following:
Gommission Staff
Erick Shaner
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
Industrial Customer of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 N. 6th Street
Boise, ldaho 83701
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City of Boise
Ed Jewell
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701 -0500
JOINT MOTION TO SUSPEND PROCEDURAL SCHEDULE .6
Glean Energy Opportunities for ldaho, lnc.
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.,
Boise, ldaho 83703
Michael Heckler
Courtney \Mite
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, CA 94612
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cou rtnev@cleanenerqvopportu n ities.com
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tnelson@holland hart.com
awiensen@holland hart.com
aclee@holland hart.com
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i )rLGe^t &^Ek-
Stacy Gust, Regulatory Administrative
Assistant
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Micron Technology, lnc.
Jim Swier
8000 S. FederalWay
Boise, lD 83707
JOINT MOTION TO SUSPEND PROCEDURAL SCHEDULE .7