20220512Reply Comments.pdf

JAYME B. SULLIVAN BOISE CITY ATTORNEY
Ed Jewell ISB No. 10446 Deputy City Attorney BOISE CITY ATTORNEY’S OFFICE 150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500 Telephone: [phone] Facsimile: [phone] Email: [e-mail]
[e-mail]
Attorney for Intervenor
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
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
Case No. IPC-E-21-17
CITY OF BOISE CITY’S REPLY COMMENTS
The city of Boise City (“Boise City”) submits these formal reply comments on the amended
application submitted by Idaho Power Company (“Company”) for a prudency determination and
approval of its proposed accelerated depreciation schedule for coal-related assets at the Jim Bridger
Power Plant (“Bridger Plant”). Boise City submits these formal reply 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 BOISE CITY’S COMMENTS - 1
RECEIVED
2022 May 12, AM 9:08
IDAHO PUBLIC
UTILITIES COMMISSION
1.Boise City reiterates its support for the Company’s overall efforts to exit coal and transition
to clean energy generation resources. The Company’s 2021 Integrated Resource Plan (IRP)
and associated Action Plan clearly identify solar, wind, and battery storage resources as
least-cost least-risk resources to the Company and rate payers to meet growing demand
across the Company’s service area. These non-fueled resources reduce risk of fuel price
volatility and provide clear economic advantages over legacy fossil-fuel generation
resources. See 2021 Idaho Power Integrated Resource Plan, Action Plan, p. 166-67, IPC-
E-21-43.
2.The primary issue in front of the Commission in this proceeding is: were the Company’s
expenditures from 2012 through 2020 in the Bridger Plant coal generation assets prudently
incurred, and if so, how should those costs be recovered? Boise City believes accelerated
cost recovery of expenditures determined to be prudent is only appropriate if combined
with a firm accelerated exit plan in place. Boise City notes the disparity between the
forecasted exit dates in the Company’s 2021 IRP and the forecasted exit dates in
PacifiCorp’s 2021 IRP. As noted by Commission Staff, Idaho Power’s IRP shows it is
economic for the Company to exit units and cease coal-fired generation at the Bridger Plant
between 3 and 12 years earlier than PacifiCorp’s IRP. Commission Staff Comments at 10.
Currently forecasted exit dates for PacifiCorp at the Bridger Plant are as late as 2037. Id.
Current contractual terms between the co-owners do not allow the Company to exit a
Bridger Plant unit earlier than PacifiCorp. Larkin, Supp Di. at 9. Given the discrepancy in
timelines, Idaho Power’s 1/3 position in the plant, and the current contractual arrangement,
a Commission directive to establish firm exit dates or closure dates is appropriate before
granting accelerated ratemaking treatment. Implementing a rate increase under the current
CITY OF BOISE CITY’S COMMENTS - 2
conditions, regardless of the financial mechanism used to enter prudently incurred costs
into rate base, without a guarantee that the Company will achieve the cost savings or other
benefits from a negotiated early Bridger Plant exit, is not reasonable.
3.A negotiated exit plan for all four units of the Bridger Plant is in the best interests of
customers and the Company. The Joint Comments of Idaho Conservation League and
Sierra Club and the Comments of Commission Staff identify the significant challenges the
Company faces managing operational considerations, and the interest of its ratepayers as
the minority, 1/3, owner of the Bridger Plant and the Bridger coal mine. See Joint
Comments of Idaho Conservation League and Sierra Club at 9-11; see also Comments of
Commission Staff at 8. So long as the Bridger Plant continues to operate, there will be
continued need for significant investment at the Bridger Plant. Without clear direction
through a negotiated exit plan with PacifiCorp, the Company may not be able to reasonably
ensure expenses incurred at the Bridger Plant are in line with its system needs and future
generating resource plans. A negotiated exit plan with specifically identified unit exit dates
acknowledged by the Commission is required to mitigate the risk of the Company being
contractually compelled to continue operating an uneconomic and polluting resource that
does not adequately help the Company balance its resource portfolio of the future.
4.With firm exit dates in place, Boise City would continue to encourage the Company to
apply 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-determined costs. Boise City recognizes the significant cost-savings identified
in RMI’s securitization analysis presented by Sierra Club and Idaho Conservation League.
Joint Comments of Idaho Conservation League and Sierra Club at 32. Additionally, the
CITY OF BOISE CITY’S COMMENTS - 3
analysis presented by the Industrial Customers of Idaho Power on the Company’s capital
structure and securitization’s limited impact on the Company’s financial position is
encouraging. Comments of the Industrial Customers of Idaho Power at 4-5. At this period
of transition to cheaper, non-fueled clean energy resources, during which the Company
faces significantly higher than forecasted natural gas and market energy prices, and less
robust hydroelectric generation, promoting affordability through all reasonable
mechanisms is critical to the Company’s ability to provide reliable, least-risk electricity
service at reasonable rates. In addition to customer benefits, a utility cost reduction order
would provide benefits to Idaho Power in the form of a definitive prudency determination
of appropriately incurred expenses and cash up front to invest in replacement resources.
5.In conclusion, Boise City recommends the Commission order the Company to negotiate
exit dates ending the Company’s participation in coal-fired generation at all 4 Bridger Plant
units and provide the Commission and Parties regular status reports on negotiations.
Additionally, Boise City encourages 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 is more favorable in the broader context of the on-going clean
energy resource transition.
DATED this 12th day of May 2022.
______________________________ Ed Jewell,
Deputy City Attorney
CITY OF BOISE CITY’S COMMENTS - 4
CERTIFICATE OF SERVICE
I hereby certify that I have on this 12th day of May 2022, served the foregoing documents
on all parties of counsel as follows:
Jan Noriyuki Commission Secretary
Idaho Public Utilities Commission
472 West Washington Boise, ID 83702 [e-mail]

Personal Delivery
Facsimile
Electronic Means w/ Consent
Other: __________________
Matt Larkin Idaho Power Company 1221 W. Idaho St. (83702)
PO Box 70 Boise, ID 83707-0070 [e-mail] [e-mail] [e-mail]

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Facsimile
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Other: __________________
Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8 Suite 201-A (83714)
PO Box 83720 Boise, ID 83720-0074 [e-mail]
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Emma E. Sperry Idaho Conservation League 710 N. 6th St.
Boise, ID 83702
[e-mail] [e-mail]
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Richardson, Adams, PLLC
515 N 27th. St PO Box 7218 Boise, ID 83702
U.S. Mail
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Other: __________________
CITY OF BOISE CITY’S COMMENTS - 5
Dr. Don Reading 6070 Hill Road
Boise, ID 83703
[e-mail]
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Micron Technology, Inc.
8000 S. Federal Way Boise, ID 83707 [e-mail]
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Thorvald A. Nelson Austin W. Jensen Holland & Hart, LLP 555 17th Street Suite 3200
Denver, CO 80202
[e-mail] [e-mail] [e-mail] [e-mail]
[e-mail]
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Ana Boyd Sierra Club
2101 Webster Street Suite 1300
Oakland, CA 94612 [e-mail] [e-mail]
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Courtney White Clean Energy Opportunities for Idaho Inc. 3778 Plantation River Dr., Suite 102 Boise, ID 83703
[e-mail]
[e-mail]
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CITY OF BOISE CITY’S COMMENTS - 6
Kelsey Jae Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
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________________________________ Michelle Steel Paralegal, City of Boise
CITY OF BOISE CITY’S COMMENTS - 7