20220601Final_Order_No_35423.pdf

ORDER NO. 35423 1
Service Date June 1, 2022
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 POWER PLANT
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ORDER NO. 35423

On June 3, 2021, Idaho Power Company (“Company” or “Idaho Power”) applied to the
Commission for authorization to: (1) accelerate the depreciation schedule for the Jim Bridger
Power Plant (“Bridger”) to allow it to be fully depreciated and recovered by December 31, 2030;
(2) establish a balancing account, with necessary regulatory accounting, to track the incremental
costs and benefits associated with Idaho Power ending its participation in coal-fired operations at
Bridger; and (3) raising customer rates to recover the incremental, annual levelized revenue
requirement of $30.83 million or an overall increase of 2.53 percent.
Bridger is located near Rock Springs, Wyoming, and consists of four generating units.
PacifiCorp owns two-thirds of the facility and is its operator, while Idaho Power owns the other
one-third. The Company and PacifiCorp work jointly to make decisions regarding Bridger
including required investments and the proposed retirement of Bridger. Bridger is connected to the
Borah West transmission path west of the Borah Substation near American Falls, Idaho. The
Company’s one-third share of energy flows west over this path. The Idaho-Wyoming path consists
of three 345 kV transmission lines. The Company owns 800 MW of the 2,400 MW east-to-west
capacity which feeds into the Borah West path when power is moving east to west from Bridger.
PROCEDURAL HISTORY
Clean Energy Opportunities for Idaho (“CEO”); City of Boise City (“Boise City”);
Industrial Customers of Idaho Power (“ICIP”); Idaho Conservation League (“ICL”); Micron
Technology (“Micron”); and Sierra Club all intervened in this case. Order Nos. 35094, 35102, and
35119.
On November 17, 2021, the Commission suspended the procedural schedule and discovery
until the Company filed an update or requested to set the procedural schedule once more
information was known regarding PacifiCorp’s proposal to convert Bridger Units 1 and 2 from
burning coal to burning gas and the ongoing negotiation over the Wyoming State Implementation
ORDER NO. 35423 2
Plan (“Wyoming SIP”), but no later than December 31, 2021. Order No. 35222. The Commission
also suspended the effective date for 30 days and 5 months, or until May 31, 2022, unless the
Commission issued an earlier order accepting, rejecting, or modifying the Company’s Application.
On December 30, 2021, the Company filed a letter with the Commission stating that it filed
its 2021 Integrated Resource Plan (“IRP”) with a preferred portfolio that also identified the
cessation of coal-fired generation in Bridger Units 1 and 2 in 2023 with a natural gas conversion
of those units in 2024. The Company also stated that the Environmental Protection Agency
(“EPA”) had not yet formally acted on PacifiCorp’s proposed alternative regional haze compliance
plan for Bridger Units 1 and 2. The current PacifiCorp plan would require emission controls by
December 31, 2021, for Unit 2 and December 31, 2022, for Unit 1. The Company stated that on
December 27, 2021, Wyoming Governor Mark Gordon issued a temporary emergency suspension
extending the compliance date of Unit 2 through April 30, 2022, to give more time for the EPA to
act on the SIP. The EPA remains in discussions with PacifiCorp regarding this issue.
On February 16, 2022, the Company filed an Amended Application and Motion to Set
Schedule (“Amended Application”), and requested almost identical Commission authorizations as
it did in the Application. However, in the Amended Application the Company requested that the
Commission issue an order authorizing it to adjust customer rates to recover the associated
incremental annual levelized revenue requirement of $27.13 million (rather than $30.83 million as
requested in the Application), which would result in an overall rate increase of 2.12 percent. The
Company requested that its proposed rates take effect June 1, 2022.
On March 10, 2022, the Commission issued Notice of Amended Application, Order No.
35340, setting a public comment deadline of April 29, 2022, a simultaneous reply comment
deadline of May 13, 2022, and a Company reply deadline of May 18, 2022.
THE AMENDED APPLICATION
The Company represented that it had made numerous investments into Bridger to ensure
environmental compliance and routine maintenance and repair. The Company requested a
prudence determination on the incremental Bridger coal-related investments since the last general
rate case1, from January 1, 2012, through December 31, 2020. The Company represented that its
investments for environmental compliance make up nearly 50 percent of the total Bridger

1 See Case No. IPC-E-11-08.
ORDER NO. 35423 3
investments made since January 1, 2012. The Company also represented that it funded 15
investments greater than $1 million for operational maintenance.
The Company represented that changing conditions have resulted in an earlier than
expected exit from participation in Bridger operations. The Company’s 2019 IRP proposed Bridger
exits in 2022, 2026, 2028, and 2030.2 The Company’s 2021 IRP 3 included the conversion of
Bridger Units 1 and 2 from coal to natural gas by the summer of 2024 with a 2034 exit date, and
the exit of coal-fired operations in Units 3 and 4 by year-end 2025 and 2028. The Company claimed
that the 2021 IRP indicated that an earlier exit from coal-fired generation at Bridger would be more
economical. The Company stated that a depreciable life of year-end 2030 for all Bridger Units is
appropriate as it would help minimize revenue requirement impacts to customers. The Company
estimated that it would exit coal-fired operations of Bridger completely by 2028.
The Company estimated that Bridger would require incremental coal-related investments
to maintain operations prior to the decommissioning of the facility. However, because the specific
timing and exact amounts of future investments were unknown, the Company proposed that the
Commission establish a balancing account to allow flexibility for the recovery of the remaining
Bridger investment revenue requirement. The Company stated that 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 coal-related costs near the time [the Company] ceases participation in coal-fired operations.
Amended Application at 7. The Company represented that this approach aligned the cost recovery
period with the Company’s remaining participation in coal-fired operations more closely and
ensured that Customers would “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.” Id. The Company proposed
that the Commission track the coal-related investment, return and associated depreciation
expenses, as well as the decommissioning costs, through the balancing account.
The Company requested an accounting order that allowed the Company to make necessary
accounting entries, including a regulatory asset account that would match Generally Accepted

2 See Case No. IPC-E-19-19. 3 See Case No. IPC-E-21-43.
ORDER NO. 35423 4
Accounting Principles (“GAAP”) revenue recognition with actual monthly patterns of coal-related
revenue requirement. The Company stated that regulatory accounts would be required to adjust
the financial statement impacts resulting from Bridger-related GAAP accounting and income tax
results.
The Company requested recovery of the coal-related levelized revenue requirement that
included costs of accelerating the depreciation of coal-related assets at Bridger; the return
associated with coal-related capital investments net of accumulated depreciation forecasted
through the Company’s participation in Bridger; interim decommissioning costs associated with
Bridger; and O&M savings associated with non-fuel coal-related O&M reductions. The Company
totaled those costs to $47,794,440 annually. The Company submitted the following table to present
the differences between each component as quantified in the Company’s initial request and the
amounts that reflected Bridger’s investment levelized revenue requirement:
The Company proposed to allocate the increase related to Bridger’s balancing account
using the jurisdictional separating study method. The Company requested that the incremental
revenue requirement increase of $27.13 million be recovered from all customer classes through a
uniform percentage increase to all base rate components except the service charge.
COMMENTS
Commission Staff (“Staff”); Idaho Power; CEO; Boise City; ICIP; Micron; ICL; and Sierra
Club all filed comments in this case.
A. Staff Comments
Staff reviewed the Company’s Amended Application and all discovery responses. Staff
recommended the Commission: find that capital investments through 2020 were prudently
June 2021 Request Amended Request
ORDER NO. 35423 5
incurred; approve the accelerated depreciation rates and the establishment of a balancing account;
and deny the requested change in rates.
With respect to the capital investments analysis, Staff performed: (1) an examination of all
projects over $1 million to ensure those projects were necessary and conducted in a least-cost
manner; (2) a comparison of the total investment amount normalized by the capacity of each unit
to ensure the overall amount of plant investment was reasonable; (3) a review of any project cost
overruns; and (4) an examination of the Company’s due diligence efforts with PacifiCorp.
While Staff ultimately recommended the Commission find the capital investments were
prudently incurred, Staff was concerned that the Company may not have been adequately involved
with the plant co-owner and operating partner, PacifiCorp, to assure those projects were
implemented in a least-cost manner. Staff recommended that the Company establish a formalized
process to document the circumstances, the Company’s justifications, and the final decisions made
for those types of investment decisions. Further, Staff believed that additional oversight by the
Company was warranted, and such direct oversight should include more frequent onsite inspection
of capital projects with field reports documenting project activity and progress, to ensure that
capital investments made at the plant would be completed at a least-cost to customers.
With respect to the depreciation rates, Staff believed it was reasonable for the Company to
identify December 31, 2030, as the end of the depreciable life of coal assets for Bridger. However,
Staff recommended that the Company include costs identified in an exit agreement with PacifiCorp
as soon as practical and include those costs in future IRPs to eliminate it as a source of error in its
IRP analysis. Additionally, Staff recommended that the Company re-evaluate the depreciable life
of Bridger and file changes with the Commission if warranted.
With respect to the balancing account, Staff believed that a balancing account was
appropriate to track any difference in the annual revenue requirement for the coal-related assets at
Bridger. Staff believed that the 2020 revenue requirement, which included operations costs,
depreciation costs, and the return on net plant in service, should be used as the base, and any
differences from the 2020 revenue requirement should be recorded in the balancing account year.
However, Staff noted that the balance in the deferral, both positive and negative, should not be
subject to any carrying charges or return. Staff believed it was appropriate for capital investments
to be reviewed for prudency at regular intervals, and Staff recommended that the Commission
ORDER NO. 35423 6
order the Company to submit reports to the Commission referencing projected expenses for
Bridger after every IRP was acknowledged.
Staff did not recommend any changes to the Company’s rates in this case. Staff noted
several uncertainties surrounding the future of Bridger and Staff did not support including
estimates in rates when the future was uncertain. Staff believed this would not significantly impact
the Company’s present financial position and Staff believed the balancing account would capture
any differences in revenue requirement and ensure the Company recovered no more and no less
than the actual costs associated with the closure of Bridger.
Staff recommended that the Commission: rule that the capital investments in Bridger
through 2020 were prudently incurred; order the Company to establish a formalized process to
document the circumstances, the Company’s justifications, and the final decisions made for capital
investments in its partner plants; establish the accelerated depreciation rates proposed in the
Company’s Amended Application that fully depreciate the coal assets of Bridger by December 31,
2030; authorize the use of a balancing account to record differences between the 2020 revenue
requirement and actual revenue requirement for the coal related assets at Bridger; and reject the
Company’s request to change rates at this time.
1. Staff Reply Comments
With respect to the issue of securitization, Staff believed there were too many uncertainties
involving the cost and date of the Bridger closure for securitization to be a viable option at this
time. Staff believed that to conduct an analysis of the benefits of securitization, the date and costs
of closure must be known. Staff believed that Bridger Units 1 and 2 could be shut down at the end
of this year, or they could last until 2030 or beyond. Staff reasoned that without a confirmed closure
date, future operating and capital costs remained uncertain, and all decommissioning costs would
be estimates and have a potential error of up to 30%.
With respect to the prudence and recovery of Bridger Units 3 and 4, Staff continued to
support its original recommendations and conclusions regarding the overall prudence of
investments in Bridger during the period from January 1, 2012, through December 31, 2020. Staff
provided an explanation of the two types of prudence determinations, decisional and operational,
and Staff provided a list of items it considered as part of its analysis to develop its recommendation,
as well as a timeline of the facts related to the evaluation of the Selective Catalytic Reduction
(“SCR”) investments prior to completion of the projects.
ORDER NO. 35423 7
B. CEO Comments
CEO believed that the notice provided to customers in this case was inadequate. CEO
believed that based on how contentious the original SCR Certificate of Public Convenience and
Necessity (“CPCN”) decision was, customers should have been given more notice that the
Company was requesting recovery of those investments. Additionally, CEO believed that the
record was inadequate to make a determination as to whether the proposed rate of return of 7.86%
was fair, just, reasonable, and in the public interest. CEO believed that decisions regarding the
prudency of prior expenditures on the Bridger units and what return the Company deserved on
those investments was more appropriate for inclusion in a general rate case.
1. CEO Reply Comments
CEO did not submit any reply comments.
C. Boise City Comments
Boise City highlighted the importance of thoughtfully determining the prudence of the
significant costs incurred by the Company in operating Bridger and urged the Company to consider
the opportunity to ensure long-term affordability presented by Idaho Code Title 61, Chapter 16.
Boise City noted that while the Company proposed to generally follow the same procedure for
early retirement and financial treatment that was used for the Valmy Plant, the proposed
accelerated depreciation schedule for Bridger resulted in an annual rate increase that was more
than twenty times greater than resulted from the accelerated depreciation of the Valmy Plant. Boise
City believed it would be prudent and consistent with treatment for the Valmy Plant for the
Company to begin negotiations with PacifiCorp to establish “on or before” closure dates for each
unit at Bridger.
1. Boise City Reply Comments
Boise City recommended that the Commission order the Company to negotiate exit dates
ending the Company’s participation in coal-fired generation at all 4 Bridger units and provide the
Commission and parties regular status reports on negotiations. Additionally, Boise City
encouraged the Company to consider the benefits of applying for a utility cost reduction order to
the Commission to promote affordability and a cost recovery schedule that would be more
favorable in the broader context of the on-going clean energy resource transition.

ORDER NO. 35423 8
D. ICIP Comments
ICIP believed that the Company’s filings asked for a large rate increase on top of other
large increases such as the Company’s annual PCA rate case in IPC-E-22-11. ICIP believed the
Commission, the Company, and other stakeholders should seriously investigate whether a
securitization of the Bridger accelerated depreciation amounts would be beneficial to both the
utility and its ratepayers. ICIP requested that the Commission convene the parties with instructions
to explore the securitization options available to the Company with the goal of implementing the
same to the extent they are determined to provide rate shock mitigation consistent with prudent
utility practices.
1. ICIP Reply Comments
ICIP did not submit any reply comments.
E. Micron Comments
Micron did not take a specific position on the Company’s proposal to adjust customer rates
to accelerate the depreciation schedule for all coal-related Bridger investments to allow for full
depreciation and recovery by December 31, 2030. Micron reserved the right to respond to other
comments. Micron encouraged the Company and the Commission to consider rate impacts of the
early retirement of carbon emitting generation resource units in the broader context of the
Company’s resource decisions and resource planning process. Micron supported the Company’s
planned investments in renewable resources to replace retiring carbon-emitting units.
1. Micron Reply Comments
Micron agreed with the initial Staff comments that the Commission should not approve a
rate increase and should direct Idaho Power to further analyze potential rate mitigation options.
F. ICL/Sierra Club Comments
ICL and Sierra Club filed joint comments. They believed that the Commission should not
guarantee the Company cost recovery on its Bridger expenditures prior to a firm commitment to
exit the plant. They believed that the Company’s analysis of the SCR project on Units 3 and 4 was
insufficient and resulted in the imprudent investment of over $100 million into Bridger, and that
the Company failed to robustly reevaluate the decision to install SCR updates at Units 3 and 4 at
decision points that would have allowed the Company to avoid substantial project costs. ICL and
Sierra Club believed that the plant owners made the decision to move forward with the SCRs long
before the Company performed any analysis, and the Commission warned the Company that it was
ORDER NO. 35423 9
obligated to reevaluate alternatives as regulations changed and the Company was not guaranteed
cost recovery.
ICL and Sierra Club believed that the Company relied on a simplistic screening analysis in
2013, and then a flawed updated analysis in 2015, to justify its decision to move forward with the
SCR project, and that the limited analyses conducted by the Company Regarding the SCRs should
not have been relied upon to make such a consequential decision as investing over $100 million
of ratepayer dollars into Bridger. ICL and Sierra Club believed the Commission should now protect
customers from the Company’s imprudence.
ICL and Sierra Club believed that the Company should consider securitizing prudently
incurred coal debt on Bridger. They believed that securitization was an appropriate ratemaking
tool to address the changing economic life of Bridger. They noted that Idaho’s existing
securitization legislation provided an optimal ratemaking treatment to recover Bridger costs. ICL
and Sierra Club represented that RMI had modeled the benefits of recovering Idaho Power’s
Bridger costs through securitization and found that securitization would save ratepayers $63.7
million. ICL and Sierra Club concluded that Idaho Power should explain why it was not
considering securitization that could save ratepayers tens of millions of dollars.
1. ICL/Sierra Club Reply Comments
ICL and Sierra Club reaffirmed their position that the Commission should: deny any rate
recovery until Idaho Power had secured a firm exit agreement with PacifiCorp allowing for Idaho
Power’s early exit from the Bridger; direct Idaho Power to explain why it was not pursuing
securitization of past, prudently incurred expenditures at Bridger; carefully scrutinize Idaho
Powers past investments in Bridger; and find that the SCR investment was imprudent.
G. Public Comments
The Commission received 112 public comments. One interested person commented that
rate payers should not be paying for the Company’s poor past business decisions. The Commission
received 13 comments that supported the idea for using Utility Cost Reduction Bonds. One
interested person commented that depreciation is a non-cash expense, and Idaho Power should not
be allowed to make rate payers pay cash to offset a non-cash expense. Additionally, 103 of the
comments stated that the Commission should choose customers over shareholders and save money
while closing coal.

ORDER NO. 35423 10
H. Idaho Power Reply Comments
With respect to the capital investments analysis, the Company agreed with Staff’s
recommendation that the Commission find that all of the capital investments were prudently
incurred. However, the Company believed that it provided adequate oversight of capital
investment decisions at Bridger. The Company also believed that it had met all of the
Commission’s customer communications requirements.
With respect to the balancing account, the Company represented that its proposed Bridger
levelized revenue requirement mechanism achieved Staff’s stated goal of ensuring customers pay
no more or no less than actual costs associated with Bridger; but that Staff’s proposed mechanism
did not. The Company believed that if Staff’s proposal was approved, Idaho Power would be
recording the difference between a base 2020 revenue requirement, a revenue requirement amount
the Company had not yet been authorized to collect, and a non-levelized declining revenue
requirement annually from 2021 through 2030. The Company believed that the resulting effect of
applying Staff’s proposed method would be to require the Company to track for future return to
customers, amounts Idaho Power never actually recovered from customers, which would result in
an estimated cumulative negative financial impact to Idaho Power of $95.4 million for 2021
through 2030. In the Company’s own words:
The recommendation by Commission Staff to use the 2020 revenue
requirement as the base for the tracking of revenue requirement differences in the
Bridger balancing account would cause significant financial harm to Idaho Power, resulting in the immediate need for Idaho Power to file a general rate case. The Company believes there is an alternative to accomplishing Commission Staff’s objectives without unwarranted financial harm.
Idaho Power Company’s Reply Comments p. 7 (emphasis added).
Simply put, the resulting effect of applying Staffs proposed method of computing balancing account differences would be to require the Company to track differences between a 2020 base amount that is $34.9 million higher than the $20.7 million currently included in customer rates associated with Bridger and authorized
by the Commission in the last general rate case. Consequently, Idaho Power would
have an obligation for future return to customers of $95.4 million -- amounts Idaho Power never actually recovered from customers. In fact, a complete denial of the Company’s proposed implementation of a Bridger balancing account would do less financial harm to Idaho Power than implementing Staffs proposed methodology for tracking Bridger coal-related revenue requirements.
Idaho Power Company’s Response to All-Party Reply Comments p. 9.
ORDER NO. 35423 11
With respect to the issue of securitization, the Company believed that securitization of
Bridger levelized revenue requirement amounts would cause undue financial harm, and that
securitization of those costs would effectively prevent the Company and its investors from earning
a fair rate of return on prudently incurred, used and useful investment at Bridger.
1. Idaho Power Response Comments
The Company affirmed its position that the Commission should accept Staff’s prudence
recommendation for Bridger investments made from January 1, 2012, through December 31, 2020,
and that the Commission should reject securitization of Bridger levelized revenue requirement
amounts. The Company believed that the Commission should authorize Idaho Power’s proposed
Bridger levelized revenue requirement mechanism.
Additionally, the Company presented a proposed rate mitigation alternative. The Company
proposed that it could instead utilize previously deferred non-cash income tax benefits associated
with Case No. GNR-U-18-01 to offset the incremental annual levelized revenue requirement of
$27.13 million. The Company explained that in Case No. GNR-U-18-01, the Commission
approved a Settlement Stipulation that provided for the annual deferral of approximately $7.4
million of non-cash deferred tax benefits stemming from the federal Tax Cuts and Jobs Act
(“TCJA”) of 2017. The Company believed that its proposed rate mitigation alternative addressed
the issues raised by the parties concerning a rate increase that was particularly coincident with the
proposed rate increase associated with the Company’s PCA.
i. ICIP’s Objection to the Mitigation Alternative
ICIP objected to the mitigation alternative. ICIP represented that by executing the
Settlement Stipulation in GNR-U-18-01, Idaho Power agreed to consult with the parties to the
stipulation regarding the appropriate use of the seven-million-dollar deferral; those parties
included ICIP and Staff. ICIP stated that Idaho Power has not consulted with the ICIP, nor Staff,
regarding the application of the tax deferral to offset accelerated Bridger depreciation costs.
The relevant provision of the Settlement Stipulation provided:
Beginning June 1, 2019, and each year thereafter, until the Company’s next general rate case proceeding or until otherwise modified by the Commission, and non-cash customer benefits associated with Tax Reform are reflected in customer
rates, the entire $7,417,848 will accumulate in a regulatory liability account
annually to serve as an offset to non-specific current or future deferrals deemed prudent and approved for recovery from customers by the Commission. Parties agree that deferred Tax Reform benefits used to offset future regulatory deferrals
ORDER NO. 35423 12
should be applied in a manner consistent with applicable federal and state income tax law. The Parties also agree this will be discussed further in future recovery cases
as appropriate. Amounts in this account will accrue a carrying charge at the
authorized customer deposit rate.
Case No. GNR-U-18-01, Settlement Stipulation and Motion to Approve Settlement Stipulation p.
9, ¶ 14.b (emphasis added).
ii. Idaho Power’s Response to the Objection
The Company represented that the terms of the Settlement Stipulation did not require the
Company to consult with parties prior to suggesting how the deferred TCJA benefits would be
used, rather the application of the benefits would be determined in a future case. The Company
reasoned that this was a “future recovery case” and the Commission could make findings as to
whether use of the tax credits was appropriate.
The Company believed that now was an opportune time to utilize those deferred TCJA
benefits to offset the annual levelized revenue requirement proposed in this case. The Company
requested that the Commission consider its proposed rate mitigation alternative and authorize the
Company to utilize the non-cash deferred TCJA benefits to offset the incremental annual levelized
revenue requirement of $27.13 million associated with its prudent Bridger investments until
customer rates could be adjusted in a future revenue requirement proceeding.
COMMISSION FINDINGS AND DECISION
The Commission has jurisdiction over the Company’s Amended Application and the issues
in this case under Title 61 of the Idaho Code including, Idaho Code §§ 61-501, -502, and -503.
The Commission is empowered to investigate rates, charges, rules, regulations, practices, and
contracts of all public utilities and to determine whether they are just, reasonable, preferential,
discriminatory, or in violation of any provisions of law, and to fix the same by order. Id.
The Commission has reviewed the Company’s Amended Application including all
submitted evidence and argument, Staff’s comments, all Intervenor and public comments, and all
Company reply comments. Based on its review of the record, the Commission finds it fair, just,
and reasonable to approve the Company’s Amended Application with some modifications.
The Commission finds that the incremental Bridger coal-related capital investments from
January 1, 2012, through December 31, 2020, were prudently incurred. The Commission
acknowledges the objections to certain capital investments contained in the arguments of some
Intervenors, specifically with regard to the SCR investments. We note that in 2013 the Commission
ORDER NO. 35423 13
issued Order No. 32929, in case IPC-E-13-16, finding it fair, just, and reasonable to approve Idaho
Power’s application for a CPCN for the SCRs at Units 3 and 4. The Commission finds that the
Company has complied with the reporting requirements as set forth in the Commission’s previous
order4 concerning the investments in SCRs for Units 3 and 4, and having considered all evidence
submitted in this case, we find the Company’s implementation of the investment was conducted
in a least-cost manner and prudent. However, the Commission believes that the process by which
the Company documents the decision-making aspect of its capital investments, both in this case
and cases in the future, can be strengthened by working with Staff to develop a more
comprehensive future documentation process.
Given the different exit dates included in IRP filings by the Bridger partners and the
potential exit costs that have not been fully evaluated, the Commission finds additional filings to
be required in the future. Idaho Power must provide additional exit cost information establishing
payments between the Bridger partners if common exit dates are not established and included in
proposed exit agreements between the Bridger partners for approval once negotiated.
The Commission finds it fair, just, and reasonable to approve the Company’s Amended
Application to establish accelerated depreciation rates that fully depreciate the coal assets of
Bridger by December 31, 2030, and to establish a balancing account using the 2011 revenue
requirement embedded in rates, with the necessary regulatory accounting, to track the incremental
costs and benefits associated with the Company’s cessation of coal-fired operations at Bridger.
However, the Commission denies the Company’s request to include a carrying charge on deferral
balances that may accrue from the differences between the annual levelized revenue requirement
and the annual revenue collected as tracked under the balancing account.
The Commission finds it fair, just, and reasonable to approve the Company’s Amended
Application for some adjustment of customer rates to recover the associated incremental annual
levelized revenue requirement. However, the Commission is sensitive to the economic conditions
affecting ratepayers throughout Idaho. It is always our responsibility to balance the ratepayer’s
access to affordable energy prices with the Company’s right to recover its costs and earn a
reasonable return on its investments. The Commission also notes the uncertainty that remains with
respect to the Company’s exit date from Bridger and the absence of any current plan to develop a
firm exit date. With these things in mind, the Commission believes that a 1.5 percent adjustment

4 See Order No. 32929.
ORDER NO. 35423 14
to customer rates strikes a balance between the Company’s recovery of its costs and a reasonable
return, with the economic conditions facing Idaho customers. Any unrecovered amounts shall be
differed into the balancing account for future recovery.
The Commission acknowledges the requests from multiple Intervenors to consider
securitization as an alternative to an increase in customer rates; however, as noted above, the
Commission believes there are too many uncertainties involving the cost and date of the Bridger
closure to allow securitization to be a viable option at this time. The Commission notes that
establishing a balancing account to track the closure costs and accelerated depreciation of Bridger
does not preclude a future filing where securitization may be considered once the necessary
information is known.
Based upon the above findings, the Commission need not consider the Company’s
alternative rate mitigation proposal to utilize non-cash deferred tax benefits stemming from the
2017 TCJA. However, even if the Commission were to consider the Company’s alternative
proposal, the Commission notes that the Company did not present adequate analysis in its briefings
with respect to the usage of such benefits in this case, nor adequate opportunity for Staff and other
parties to reply to the alternative rate mitigation proposal. The Commission makes no finding as
to the use of non-cash differed tax benefits stemming from the 2017 TCJA at a future time.
ORDER
IT IS HEREBY ORDERED that the Commission finds that the incremental Bridger coal-
related capital investments from January 1, 2012, through December 31, 2020, were prudently
incurred.
IT IS FURTHER ORDERED that the Commission approves the Company’s Amended
Application to establish accelerated depreciation rates that fully depreciate the coal assets of
Bridger by December 31, 2030, and to establish a balancing account using the 2011 revenue
requirement embedded in rates, with the necessary regulatory accounting, to track the incremental
costs and benefits associated with the Company’s cessation of coal-fired operations at Bridger.
IT IS FURTHER ORDERED that the Company shall not be entitled to any carrying charge
on deferral balances that may accrue from the differences between the annual levelized revenue
requirement and the annual revenue collected as tracked under the balancing account.
IT IS FURTHER ORDERED that the Commission approves the adjustment of customer
rates by 1.5 percent to recover the associated incremental annual levelized revenue requirement,
ORDER NO. 35423 15
with an effective date of June 1, 2022, and the Company shall file conforming tariffs reflecting the
rate increase.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date upon this Order regarding any
matter decided in this Order. Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. See Idaho Code §§ 61-
626 and 62-619.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 1st day of
June 2022.

ERIC ANDERSON, PRESIDENT
JOHN CHATBURN, COMMISSIONER

JOHN R. HAMMOND JR., COMMISSIONER

ATTEST:
Jan Noriyuki
Commission Secretary

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