20211025Decision Memo.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: ERICK SHANER
DEPUTY ATTORNEY GENERAL

DATE: OCTOBER 25, 2021

SUBJECT: IDAHO POWER COMPANY’S AND COMMISSION STAFF’S JOINT
MOTION TO SUSPEND PROCEDURAL SCHEDULE; CASE NO. IPC-E-
21-17.

BACKGROUND
On June 3, 2021, Idaho Power Company (“Company” or “Idaho Power”) applied to
the Commission for authorization to accelerate the depreciation schedule for the Jim Bridger
Power Plant (“Bridger”) to allow the plant to be fully depreciated and recovered by December 31,
2030.
In its Application the Company asked to establish a balancing account and the
necessary regulatory accounting to track the incremental costs and benefits associated with the
Company’s cessation of participation in coal-fired operations at Bridger. The Company also asked
that customer rates be adjusted to recover the associated incremental annual levelized revenue
requirement of $30,825,729 with an effective date of December 1, 2021, which equates to an
overall increase of 2.53 percent. The Company separately proposed rate changes associated with
the Depreciation Application in Case No. IPC-E-21-18 in addition to this Application. The
Company is also filing one set of proposed tariff sheets specifying the proposed rates for providing
retail electric service to customers in the state of Idaho for both proposed rate changes. The
Company requested its Application be processed under Modified Procedure.
On June 24, 2021, the Commission issued a Notice of Application and set a deadline
for intervention. The Commission granted intervention into this matter to the Industrial Customers
of Idaho Power (“ICIP”); Idaho Conservation League (“ICL”); the City of Boise (“Boise City”);
DECISION MEMORANDUM 2
Sierra Club; Clean Energy Opportunities, Inc., d/b/a Clean Energy Opportunities for Idaho
(“CEO”); and Micron Technology, Inc. (“Micron”). Order Nos. 35094, 35102, and 35119. On July
28, 2021, the Commission issued a Notice of Parties.
On October 1, 2021, the Company and Commission Staff (“Staff”) filed their Joint
Motion To Suspend Procedural Schedule (“Joint Motion”)(emphasis added). On October 1,
2021, intervenors ICL and Sierra Club responded by filing their Idaho Conservation League and
Sierra Club Response To Joint Motion To Suspend Schedule (“Response”)(emphasis added).
Thereafter, on October 7, 2021, the Company replied to the Response by filing Idaho Power’s
Reply To Joint Motion Response (“Company Reply”)(emphasis added).
The Joint Motion asks the Commission “to suspend responses to discovery requests
and further processing of this docket to address “new developments,” namely 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 Plan (Wyoming SIP).” Response at 1, citing
the Joint Motion at 4.
SUMMARY
Up to this point, this memorandum has provided background information that led to
the filing of the Joint Motion. This memorandum will next briefly note arguments raised in the
filings. The detailed arguments in the filings speak for themselves. It concludes by listing potential
decision points for the Commission to consider in making a ruling.
THE JOINT MOTION
The Company and Staff argue, in summary, that:
• “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 Company and Staff
“respectfully request that the procedural schedule and discovery be
suspended until a procedural schedule can be established. Once more
information is known, Idaho Power will make a filing recommending next
steps in this proceeding.” Joint Motion at 4.

RESPONSE
ICL and Sierra Club’s Response at page 5 argues, in summary, that:
• Given that the uncertainties surrounding PacifiCorp’s proposal to amend the
existing Wyoming SIP and Idaho Power’s independent analysis of whether
to change plans from exiting Bridger will likely be resolved by the end of
2021, ICL and Sierra Club are not opposed to a short delay in the
DECISION MEMORANDUM 3
Bridger depreciation proceedings. However, delaying the proceeding
until “more information is known” is unreasonably vague and fails to
provide IPC customers with certainty regarding the future of the Bridger
plant and any associated rate changes. ICL and Sierra Club request that the
Commission order Idaho Power to:

1. Work with parties to establish a procedural schedule that reflects
the likely resolution of the Wyoming SIP process and Idaho Power’s
resource planning by the end of 2021.

2. Continue to respond [to] discovery requests about coal-related
costs at Bridger[.]

3. File monthly updates on the Wyoming SIP negotiations and Idaho
Power’s independent assessment of the options for Bridger.”
(emphasis added) (footnotes omitted).

COMPANY’S REPLY
The Company’s Reply argues, in summary, that:
• “Because Idaho Power does not expect a need for the requested suspension
to extend beyond calendar year 2021, the Response's recommended actions
are unnecessary. The Company commits to filing an update or request to set
the procedural schedule once more information is known, but in no event
later than December 31, 2021.” Company’s Reply at 2.

COMMISSION DECISION
None of the parties asked for oral argument. Under the Commission’s Procedural Rules
56 and 256, how does the Commission wish to proceed on the parties’ written submissions? For
example:
1. Grant the Suspension as Requested in the Joint Motion. The Commission can order
that this matter be suspended as requested in the Joint Motion. Should the procedural schedule and
discovery be suspended until the Company makes a filing that recommends the next steps for this
matter?
2. Grant the Suspension Upon the Conditions Requested by ICL and Sierra Club. Does
the Commission wish to grant the suspension, but only on the conditions requested by ICL and
Sierra Club? ICL and Sierra Club requested that the suspension be granted by the Commission on
the condition that the Company is ordered to:
a. Work with parties to establish a procedural schedule that reflects the likely resolution
of the Wyoming SIP process and Idaho Power’s resource planning by the end of 2021;
DECISION MEMORANDUM 4
b. Continue to respond to discovery requests about coal-related costs at Bridger; and
c. File monthly updates on the Wyoming SIP negotiations and Idaho Power’s
independent assessment of the options for Bridger.
3. Grant the Suspension as Requested in the Company’s Reply. Does the Commission
wish to order the procedural schedule and discovery be suspended until the Company files an
update or request to set the procedural schedule once more information is known, but no later than
December 31, 2021?
4. Deny the parties’ requests and set a schedule in this case?
5. Something else?

Erick Shaner
Deputy Attorney General

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AnD oolPcompilY
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
Joint Motion to Suspend Procedural Schedule
1 of 8
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
)
)
)
)
)
)
)
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
Joint Motion to Suspend Procedural Schedule
2 of 8
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
Joint Motion to Suspend Procedural Schedule
3 of 8
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
Joint Motion to Suspend Procedural Schedule
4 of 8
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
Joint Motion to Suspend Procedural Schedule
5 of 8
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
Joint Motion to Suspend Procedural Schedule
6 of 8
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
Hand Delivered_U.S. Mail
_Overnight Mail
_FAXX Email: [e-mail]
FTP Site
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX_ FTP SiteX Emai! [e-mail]
FTP Site
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX EMAIL [e-mail]
FTP Site
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX EMAI L [e-mail]
FTP Site
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAX
X EMAIL [e-mail]
bo iseC iWAtto rnev@citvofbo ise. orq
_ FTP Site
City of Boise
Ed Jewell
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701 -0500
JOINT MOTION TO SUSPEND PROCEDURAL SCHEDULE .6
Joint Motion to Suspend Procedural Schedule
7 of 8
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
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX EMAIL [e-mail]
FTP Site
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX EMAIL
mike@clea ne nergyopportu n ities. com
cou rtnev@cleanenerqvopportu n ities.com
FTP Site
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX EMAIL rose. mona han@sie rraclu b.orq
an a. boyd@sierraclub.o rg
FTP Site
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX EMAIL [e-mail]
tnelson@holland hart.com
awiensen@holland hart.com
aclee@holland hart.com
[e-mail]
FTP Site
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX EMAIL [e-mail]
_ FTP Site
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 .7Joint Motion to Suspend Procedural Schedule
8 of 8
ICL/SC Response to Joint Motion to Suspend 1
October 1, 2021
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
Rose Monahan, CA Bar No. 329861 (pro hac vice)
Sierra Club
2101 Webster Street, Suite 1300
Oakland, California 94612
Phone: [phone]
Email: [e-mail]
Attorney for Sierra Club
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
CASE NO. IPC-E-21-17
IDAHO CONSERVATION
LEAGUE AND SIERRA CLUB
RESPONSE TO JOINT
MOTION TO SUSPEND
SCHEDULE
The Idaho Conservation League (ICL) and Sierra Club submit this Response to the Joint
Motion to Suspend Procedural Schedule (Joint Motion). Idaho Power and Staff request to
suspend responses to discovery requests and further processing of this docket to address “new
developments,” namely 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 Plan
(Wyoming SIP).1 ICL and Sierra Club recommend that the Commission require IPC to work
with parties to develop a procedural schedule for this docket that reflects resolving these
uncertainties by the end of 2021 instead of allowing IPC to indefinitely suspend the proceeding.
1 Joint Motion to Suspend Procedural Schedule, Case No. IPC-E-21-17, p. 4 (Oct. 1, 2021).
RECEIVED
2021 OCT -1 PM 5:01
IDAHO PUBLIC
UTILITIES COMMISSION
ICL and Sierra Club Response to Joint Motion
1 of 8
ICL/SC Response to Joint Motion to Suspend 2
October 1, 2021
In addition, ICL and Sierra Club recommend that the Commission condition the suspension of
this docket on Idaho Power submitting monthly status updates on the Wyoming SIP process,
continuing to respond to discovery requests that address coal-related costs at Jim Bridger, and
independently assessing the options for Jim Bridger that benefit Idaho Power customers.
I.IPC Should Work with Parties to Develop a Procedural Schedule for 2022
Although we acknowledge there are uncertainties regarding the future of the Jim Bridger
plant, including the ongoing discussion related to regional haze compliance and the potential gas
conversion of the plant, we do not agree that these uncertainties should indefinitely delay the
current Jim Bridger depreciation proceeding. First, it is likely that ongoing negotiations
regarding regional haze compliance will resolve before the end of 2021. The Joint Motion
correctly notes that Wyoming has submitted a regional haze SIP revision to the U.S.
Environmental Protection Agency (EPA), which the Agency has not acted upon.2 Because
PacifiCorp’s request to amend the Wyoming SIP and Wyoming’s corresponding regional haze
SIP revision has not been approved, the federal requirements to install Selective Catalytic
Reduction (SCR) controls on Bridger Units 1 and 2 by the 2021 and 2022 remain in effect.3
Unless EPA approves the amendment to the Wyoming SIP, PacifiCorp installs SCRs on Bridger
1 by the end of December 2021, or the parties come to some other negotiated resolution,
continued operation of Jim Bridger Unit 1 will constitute a violation of the Clean Air Act
beginning January 1, 2022. As a result, and in light of the fact that negotiations are currently
2 Id. at 3. 3 Id. ICL and Sierra Club Response to Joint Motion
2 of 8
ICL/SC Response to Joint Motion to Suspend 3
October 1, 2021
ongoing,4 we expect there to be a resolution to the regional haze compliance issue before the end
of the year.5
Second, Idaho Power is required to file its 2021 IRP by December 2021.6 Idaho Power is
fully capable of assessing a variety of Bridger options in the IRP, including whether to exit all
units or follow PacifiCorp’s desire to convert Units 1 and 2 to gas. Idaho Power has performed
similar analyses several times, namely for Valmy and the co-owner NV Energy as well as for
Bridger in the 2019 IRP and the beginning of the 2021 IRP. Therefore, the uncertainty of
whether gas conversion is in the best interest of Idaho Power customers will be resolved, or at
least the analysis will be available, by the end of 2021.
Given that the regional haze compliance and gas conversion issues should be resolved, or
largely resolved, by the end of 2021, IPC will be able to move forward on the Bridger
proceeding in early 2022. As a result, we request that the Commission require IPC to work with
parties in 2021 to set a firm schedule for the Bridger docket for early 2022.
II.IPC Should Continue to Respond to Bridger Coal-Related Discovery
ICL and Sierra Club recommend that the Commission move forward with the coal-related
cost portions of this docket in order to resolve issues that are independent of the Wyoming SIP
process or a possible gas conversion at Units 1 and 2. Even if Wyoming and the EPA agree to
PacifiCorp’s proposal to convert Bridger units to gas, this Commission will need to address
Idaho Power’s request here to recover past spending at Bridger and any remediation costs such
4 Id.
5 Sierra Club is a party to the ongoing negotiations concerning regional haze compliance at Jim Bridger. However,
Sierra Club’s representation that a resolution is likely to be achieved by the end of the year is based solely on
publicly available information: namely, that federal requirements mandate that SCRs be installed on Jim Bridger
Unit 1 no later than December 31, 2021, PacifiCorp has taken no action to install SCRs on Unit 1, and the parties are
currently negotiating a resolution to this issue. No inference regarding the status or substance of the ongoing
negotiations should be assumed based on this representation. 6 Final Order, Case No. IPC-E-21-06, p. 3 (May 27, 2021). ICL and Sierra Club Response to Joint Motion
3 of 8
ICL/SC Response to Joint Motion to Suspend 4
October 1, 2021
as coal-ash containment and decommissioning of the coal related infrastructure at the Bridger
site. By addressing these coal-related costs now, the Commission can establish cost recovery
processes that avoid intergenerational equity issues of having future Idaho Power customers pay
for legacy coal-related costs. ICL and Sierra Club recommend the Commission direct Idaho
Power to continue to respond to discovery requests that address coal-related costs at the Bridger
plant.
III.IPC Should Continue to Assess Bridger Options for IPC customers
ICL and Sierra Club also recommend that the Commission require IPC to assess
independently whether converting the Bridger plant to natural gas is the best option for IPC
customers. Idaho Power customers remain unrepresented in the Wyoming SIP negotiation
process because IPC is not a party to the SIP revision discussion and negotiation.7 And, while
PacifiCorp has filed a new IRP that proposes to convert Bridger units to gas, that analysis is only
relevant to PacifiCorp and there is no indication in the record in this case that PacifiCorp’s desire
is in the best interest of Idaho Power’s customers. As this Commission saw in dealing with the
Valmy coal plant, Idaho Power has the ability to make resource decisions independent of a co-
owner who has different objectives.8 The Commission should give little weight to Idaho Power
and Staff’s reason to suspend this docket due to PacifiCorp’s new plan to convert Bridger to
gas—a plan yet to be reviewed by any of the six states that oversee PacifiCorp or approved as a
revision to the existing Wyoming SIP. Rather, ICL and Sierra Club recommend that the
7 Id. (IPC states that “[d]iscussions between EPA, Wyoming, and PacifiCorp regarding the SIP revision and regional
haze compliance at Jim Bridger are ongoing” indicating that Idaho Power is not a party to the negotiations) 8 See Order No. 33771, Case No. IPC-E-16-24 (May 31, 2017). ICL and Sierra Club Response to Joint Motion
4 of 8
ICL/SC Response to Joint Motion to Suspend 5
October 1, 2021
Commission direct Idaho Power to continue assessing the optimal path forward for Idaho Power
customers regarding Bridger in the IRP process.9
IV.Conclusion
Given that the uncertainties surrounding PacifiCorp’s proposal to amend the existing
Wyoming SIP and Idaho Power’s independent analysis of whether to change plans from exiting
Bridger will likely be resolved by the end of 2021, ICL and Sierra Club are not opposed to a
short delay in the Bridger depreciation proceedings. However, delaying the proceeding until
“more information is known”10 is unreasonably vague and fails to provide IPC customers with
certainty regarding the future of the Bridger plant and any associated rate changes. ICL and
Sierra Club request that the Commission order Idaho Power to:
1.Work with parties to establish a procedural schedule that reflects the likely
resolution of the Wyoming SIP process and Idaho Power’s resource planning by
the end of 2021.
2.Continue to respond discovery requests about coal-related costs at Bridger
3.File monthly updates on the Wyoming SIP negotiations and Idaho Power’s
independent assessment of the options for Bridger.
ICL and Sierra Club respectfully submit this Response to the Joint Motion to Suspend the
Procedural Schedule.
DATED this 1st day of October, 2021.
9 ICL and Sierra Club acknowledge this docket is about Bridger depreciation and not directly about the IRP.
However, these processes are intertwined as the IRP provides the analytical basis to determine the optimal path
forward for IPC’s share of the Bridger plant. 10 Joint Motion, supra at 4. ICL and Sierra Club Response to Joint Motion
5 of 8
ICL/SC Response to Joint Motion to Suspend 6
October 1, 2021
Respectfully submitted,
___/s/___________________________
Benjamin J. Otto
Idaho Conservation League
____/s/ ____________________
Rose Monahan
Sierra Club
ICL and Sierra Club Response to Joint Motion
6 of 8
ICL/SC Response to Joint Motion to Suspend 7
October 1, 2021
CERTIFICATE OF SERVICE
I hereby certify that on this 1st day of October 2021, I delivered true and correct copies of
the foregoing RESPONSE TO JOINT MOTION to the following persons via the method of
service noted:
___/s/___________________
Rose Monahan
Sierra Club
Electronic mail only (see Order 35058)
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
[e-mail]
Karl Klein
[e-mail]
Commission Staff
Erick Shaner
[e-mail]
Idaho Power Company
Lisa D. Nordstrom
Matt Larkin
[e-mail]
[e-mail]
[e-mail]
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
[e-mail]
Dr. Don Reading
[e-mail]
Idaho Conservation League
Benjamin J. Otto
[e-mail]
City of Boise
Ed Jewell
[e-mail]
[e-mail]
ICL and Sierra Club Response to Joint Motion
7 of 8
ICL/SC Response to Joint Motion to Suspend 8
October 1, 2021
Clean Energy Opportunities
Michael Heckler
Courtney White
[e-mail]
[e-mail]
Micron Technology, Inc.
Jim Swier
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
ICL and Sierra Club Response to Joint Motion
8 of 8
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LISA D. NORDSTRO]UI
Lead Counsel
I [e-mail]
October 7,2021
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. IPC-E-21-17
ln the Matter of ldaho Power Company's Application for Authority to
lncrease Its 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 ldaho
Power's Reply to Joint Motion Response.
lf you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
,€; l.Y/,*t"^,
Lisa D. Nordstrom
LDN:sg
Enclosure
IPC Reply to Joint Motion Response
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LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (837021
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
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. !PC-E-21-17
IDAHO PO\A/ER'S REPLY TO
JOINT MOTION RESPONSE
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ldaho Power Company (ldaho Power or Company) submits this Reply to the ldaho
Conservation League (lCL) and Sierra Club's Response (Response) to the Joint Motion
to Suspend Procedural Schedule (Joint Motion) filed by ldaho Power and the ldaho Public
Utilities Commission Staff (Movants), both of which were filed on October 1,2021.
The Movants seek a suspension of the procedural schedule to allow Movants the
opportunity to assess this case in light of new developments that may impact operation
of the Jim Bridger power plant. ln their Response to the Joint Motion, lCL and Sierra Club
do not oppose a short delay in the Bridger proceedings, but express conoerns over a non-
specified delay that lacks certainty, and propose a number of recommendations to
address these concerns. To clariff, ldaho Power views the Joint Motion as a request for
a short delay, and agrees with ICL and Sierra Club that sufficient information will be known
IDAHO POWER'S REPLY TO JOINT MOTION RESPONSE.l
IPC Reply to Joint Motion Response
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by year-end with regard to the two items detailed in the Joint Motion - the \Afioming State
lmplementation Plan and the 202l lntegrated Resource Plan. Because ldaho Powerdoes
not expect a need for the requested suspension to extend beyond calendar year 2021,
the Response's recommended actions are unnecessary. The Company commits to filing
an update or request to set the proceduralschedule once more information is known, but
in no event later than December 31,2021.
DATED at Boise, ldaho, this 7m day of October 2021.
X* !.7(""ut***,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER'S REPLY TO JOINT MOTION RESPONSE.2
IPC Reply to Joint Motion Response
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of October 2021,lserved a true and
correct copy of ldaho Powe/s Reply to Joint Motion Response upon the following named
parties by the method indicated below, and addressed to the following:
Commission 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
lndustrial 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. 6h Street
Boise, ldaho 83701
City of Boise
Ed Jewell
150 N. Capitol Blvd.
P.O. Box 500
Boise, ldaho 83701-0500
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IDAHO POWER'S REPLY TO JOINT MOTION RESPONSE.3
IPC Reply to Joint Motion Response
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Clean 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
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
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mike@cleanene rgyopportu n ities. com
cou rtney@cleanenerqyopportu n ities.com
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ana. boyd@sierraclu b.org
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tnelson @holland hart.com
awiensen@holland hart. com
aclee@holland hart.com
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&-^"J=
Stacy Gust, Regulatory Administrative
Assistant
IDAHO PO\A'ER'S REPLY TO JOINT MOTION RESPONSE - 4 IPC Reply to Joint Motion Response
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