20220427Comments.pdf

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JAYME B. SULLTVAN
BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446
Deputy City Attomey
BOISE CITY ATTORNEY'S OFFICE
150 N. Capitol Blvd.
P.O. Box 500
Boise,ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
Email: ej ewell(rDcityofboise.ore
[e-mail]
Attorney for lntervenor
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE RATES FOR
ELECTRIC SERVICE TO RECOVER COSTS
ASSOCIATED WITH THE JIM BRIDGER
POWER PLANT
BEFORE TIIE
IDAIIO PUBLIC UTILITIES COMN4ISSION
CaseNo. IPC-E-21-17
CITY OF BOISE CITY'S
COMMENTS
The city of Boise City ("Boise City") submits these formal comments on the amended
application submitted by Idaho Power Company ("Company") for a prudency determination and
approval ofits proposed accelerated depreciation schedule for coal-related assets at the Jim Bridger
Power Plant ("Bridger Plant"). Boise City submits these formal comments pursuant to Rule 203
of the Commission's Rules of Procedure, IDAPA 31.01.01.203, and pursuant to the Notice of
Modified Procedure, Order No. 35340, issued by the Commission on March 10,2022. Order No.
35340 provides a comment deadline of April 27 ,2022, a reply comment deadline for parties that
submitted comments of May 13, 2022, and a final reply comment deadline for the Company of
May 18,2022.
CITY OF BOTSE CITY'S COMMENTS - 1
l. The accelerated depreciation schedule presented by the Company includes significant total
expenditures. The requested prudency determination and ratemaking treatrnent of past and
forecasted expenditures at the Bridger plant would result n a$27,127,333 increase to the
Company's annual revenue requirement. If approved, the amended application would
require collecting an additional $230 million from customers over the proposed eight-and-
a-half-year period. Amended Application at 9. While the Company proposes to generally
follow the procedure for early retirement and financial treatment of the Valmy Plant, it is
important to recognize the proposed accelerated depreciation schedule for the Bridger Plant
results in an annual rate increase that is more than twenty times greater than resulted from
the accelerated depreciation of the Valmy Plant, which was $1.21 million on an annual
basis. Additionally, the length of time between the Company's last general rate case in
20ll and this application results in more than $266 million in coal-related plant
invesfinents across 841 projects at the Bridger Plant requiring prudency determination,
significantly greater than requested for the Valmy Plant. Compare Adelman, Di. at 12 with
Harvey, Di. at 7, Exh. 4, WC-E-16-24. Boise City believes the Company's request to
spread recovery ofprudently incurred costs over a definite timeline is generally reasonable,
even if the timeline does not directly align with the currently anticipated useful life of the
Bridger Plant. Boise City views this docket as an important opportunity to ensure prudently
incurred costs are incorporated into rate base and recovered by the Company.
2. Boise City believes the prudency determination is a critical part of this proceeding and
recognizes the need to assess both the individual expenses incurred at the Bridger Plant
and the system of controls in place between the Company and the plant co-owner,
PacifiCorp, to ensure any costs approved here are reasonable. Based on the Company's
CITY OF BOISE CITY'S COMMENTS - 2
response to Commission Stafls Third Production Request, Boise City is interested in
hearing more from Commission Staff, and other parties in this comment period, regarding
the appropriateness and strength of documentation supporting prudency across the
significant range of expenses presented by the Company.
3. If ratemaking treatment is granted here, Boise City believes the Company should, upon
conclusion of this proceeding, immediately begin work to negotiate "on or before" closure
dates with PacifiCorp for all coal-fired units at the Bridger Plant. While closure dates for
operational purposes can be different than closure dates for ratemaking purposes, the
Commission ordered "on or before" closure dates when approving ratemaking treatment
for the Valmy Plant in IPC-E-16-24. Order No. 33771 (approving the settlement
stipulation, as submitted). Although there are near-term complicating factors because of
uncertainty in the ongoing negotiations with the state of Wyoming and the U.S.
Environmental Protection Agency regarding Clean Air Act compliance at Bridger Units I
and 2 and the Company is forecasting near-term capacity-deficits, establishing exit date
parameters when approving ratemaking treaftnent provides clear expectations for the
medium-term and is a good practice that furthers ratepayer interests by providing rate
certainty and stability. Boise City recognizes the Company's efforts in its application to
promote rate certainty.
4. ln this docket, the Company and the Commission must look backwards to manage
appropriate recovery for incurred expenses. More generally, the Company is also looking
forward to transition to new clean generation resources with lower operating costs than its
current coal units. Across all these efforts, and in the broader context of the changing
energy landscape, affordability must continue to be a key consideration. Idaho Code Title
CITY OF BOISE CITY'S COMMENTS - 3
61, Chapter 16 provides public utilities in Idaho the option to apply for a utility cost
reduction order that would allow the utility to issue cost reduction instruments, such as
bonds. Idaho Code $ 6l-1601 et seq. The cost reduction instruments allow the Company
to recover its prudently incurred investments upfront, providing greater cash on hand for
the Company as it looks to make significant investments in replacement generation
resources. While ldaho Power did not apply for a utility cost reduction order in this case,
Boise City would support the Company applying for a cost reduction order for the expenses
currently in front of the Commission, and for future decommissioning of the Bridger Plant
including environmental remediation and other to-be-deterrrined costs. Boise City believes
this path would allow the Company to reduce ratepayer impact and generational cost
shifting, while allowing the Company to recover its prudently incurred investments more
rapidly.
5. ln conclusion, Boise City commends the Company on its continued efforts to exit coal-
fired power plants while pursuing cost-effective clean energy generation resources. In the
proposed ratemaking ffeaunent and prudency determination of coal-fired assets in this
application, Boise City highlights the importance of thoughtfully determining prudence of
the significant costs incurred by the Company in the operation of the Bridger Plant. Boise
City urges the Company to consider the opportunity to ensure long-term affordability
presented by Idaho Code Title 61, Chapter 16. Boise City believes 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 the Bridger Plant.
CITY OF BOISE CITY'S COMMENTS - 4
DATED this 27th day of April2022
W;fi'r.tt
Ed Jehdll,
Deputy City Attorney
CITY OF BOISE CITY'S COMMENTS - 5
CERTIFICATE OF SERYICE
I hereby certiff that I have on this ZTthday of April 2022,served the foregoing documents
on all parties of counsel as follows:
JanNoriyuki
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, ID 83702
i an. noriyuki (dFuc. i daho. eov
Lisa D. Nordstrom
Matt Larkin
Idaho Power Company
l22l W. Idaho St. (83702)
PO Box 70
Boise,ID 83707-0070
[e-mail]
[e-mail]
mlarkin@ idahopower. com
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
I 1331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
chris.burdin(@nuc. idaho. sov
Benjamin J. Otto
Emma E. Sperry
Idaho Conservation League
710 N. 66 St.
Boise, lD 83702
botto(rD idahoconservation. ore
esperr.v @ idahoconservation. or g
Peter J. Richardson
Richardson, Adams, PLLC
515 N 276. St
PO Box 7218
Boise, D 83702
peter(aD richardsonadams. com
tr U.S. Mailtr Personal Deliverytr FacsimileV Electronic Means w/ Consenttr Other:
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CITY OF BOISE CITY'S COMMENTS - 6
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreadine@mindsprine. com
Jim Swier
Micron Technology, Inc.
8000 S. Federal Way
Boise, TD 83707
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17ft Street Suite 3200
Denver, CO 80202
darueschhoff@hollandhart. com
tnelson@hol landhart. com
awj ensen(Ehol landhart. com
aclee@ hollandhart. com
sl qareanoamari @ hollandhart. com
Rose Monahan
Ana Boyd
Sierra Club
2101 Webster Steet Suite 1300
Oakland, CA946l2
ro se. monahan(@ si erracl ub. o r g
ana.boyd@ sierraclub.ors
Michael Heckler
Courhrey White
Clean Energy Oppornrnities for Idaho Inc.
3T7SPlantation River Dr., Suite 102
Boise,ID 83703
mike@cleanenergyopportunities. com
courtney@ cleanenereyopportunities. com
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CITY OF BOISE CITY'S COMMENTS - 7
Kelsey Jae
Law for Conscious Leademhip
920N. CloverIh.
Boise,ID 83703
kelsey@kelperdaecom
tr U.S. Mailtr P€rsonal Deliverytr FacsimileEl EleofronicMeansdComenrttr Othec
IUiohelle Steel
Paralegal, City of Boise
CITY OF BOISE CITY'S COMMENTS.8