20240403Application.pdf

0IQAW POWER.
RECEIVED
DONOVAN WALKER
Lead Counsel Wednesday,April 3,2024 4:50 PM
dwalker(Mclahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
April 3, 2024
VIA ELECTRONIC FILING
Monica Barrios-Sanchez, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-24-16
In the Matter of Idaho Power Company's Application for a Certificate of
Public Convenience and Necessity for the Boise Bench Battery Storage
Facility
Dear Barrios-Sanchez:
Attached for electronic filing please find Idaho Power Company's Application in the
above matter.
In addition, please find attached the Direct Testimony of Eric Hackett and the Direct
Testimony of Jared Ellsworth, filed in support of the Application. A Word version of the
testimonies will also be sent in a separate email for the convenience of the Reporter.
Also attached is a Protective Agreement. A portion of the Application and a portion
of the Direct Testimony of Eric Hackett and Exhibits contain confidential information and
will be provided separately via an encrypted email to parties who sign the Protective
Agreement.
Please feel free to contact me directly with any questions you might have about
this filing.
Very truly yours,
Donovan E. Walker
DEW:sg
Attachments

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Application for a Certificate of Public Convenience and Necessity for the Boise
Bench Battery Storage Facility
IPC-E-24-16
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that a portion of the Application, and a portion of the Direct Testimony of Eric
Hackett and Exhibits 3, 5, 7, and 8, contain information that Idaho Power Company and
a third party claims are confidential trade secret as described in Idaho Code § 74-101, et
seq., and/or § 48-801, et seq. As such, they are protected from public disclosure and
exempt from public inspection, examination, or copying.
DATED this 3rd day of April 2024.
Donovan Walker
Counsel for Idaho Power Company

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker(o-)idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A ) CASE NO. IPC-E-24-16
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR THE BOISE ) APPLICATION
BENCH BATTERY STORAGE FACILITY. )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho
Code §§ 61-501, 61-502, 61-503, 61-508, 61-526; as well as Rule of Procedure ("RP")
52, 112 and 201 hereby respectfully makes application to the Idaho Public Utilities
Commission ("Commission" or "IPUC") for an order granting the Company a Certificate
of Public Convenience and Necessity ("CPCN" or "Certificate") to acquire new
dispatchable energy storage with 150 megawatts ("MW") of operating capacity. Approval
of this request is necessary to position Idaho Power to meet its obligation to provide safe,
reliable service to its customers.
APPLICATION - 1

Accompanying this Application are two sets of testimony. The Direct Testimony of
Jared L. Ellsworth presents the Company's need for new resources to meet an identified
capacity deficit in 2026 as informed by the 2021 Integrated Resource Plan ("IRP"), again
in the 2023 IRP, and subsequently further enhanced through system reliability
evaluations. Mr. Ellsworth describes the most recent assessment of system reliability and
its impact to the capacity deficit identified in the 2023 IRP, which led to the solicitation
through a Request for Proposals ("RIFF) seeking to acquire energy and capacity
necessary to address the identified near-term capacity needs. The Direct Testimony of
Eric Hackett provides an overview of the competitive resource acquisition process
undertaken to meet Idaho Power's identified capacity deficiency in 2026, and the resulting
least-cost, least-risk resources selected through the fair and competitive RFP process
that was fully compliant with the required Oregon resource procurement rules.
I. CORPORATE STATUS
1. Idaho Power is a corporation incorporated under the laws of the state of
Idaho. Idaho Power is engaged in the business of generating, purchasing, transmitting,
and distributing electric energy and providing retail electric service in the states of Idaho
and Oregon. Idaho Power's principal offices are situated in Boise, Idaho, and its address
is 1221 West Idaho Street, Boise, Idaho 83702. Copies of Idaho Power's Articles of
Incorporation and Certificates of Convenience and Necessity are on file with the
Commission. Idaho Code § 61-528.
II. BACKGROUND
2. Idaho Power was generally resource-sufficient since the addition of the
Langley Gulch natural-gas fired power plant almost a decade ago until the filing of the
2021 IRP. That is, Idaho Power's owned generation and transmission resources, along
APPLICATION - 2

with negotiated purchases under Power Purchase Agreements and mandatory purchases
under the Public Utility Regulatory Policies Act of 1978, were sufficient to meet the
Company's load growth over that time. However, as described more completely in the
Direct Testimony of Mr. Ellsworth, several dynamic and converging factors, including
limited third-party transmission capacity, extensive load growth, and a decline in the peak
serving effectiveness of certain supply-side and demand-side resources caused Idaho
Power to rapidly move to a near-term capacity deficiency starting in 2023. These dynamic
circumstances led the Company to immediately file a request for a CPCN to acquire
resources to be online in 20231, as well as requests for a CPCN to acquire resources to
be online in 20242 and a CPCN to acquire resources to be online in 2025.3 Idaho Power
expects to acquire additional resources each year thereafter through (at least) 2028. See,
OPUC Case No. UM 2317, In the Matter of Idaho Power Company's Application for
Approval of 2028 All-Source Request for Proposals to Meet 2028 Capacity Resource
Need.
3. Under Idaho law, Idaho Power has an obligation to provide adequate,
efficient, just, and reasonable service on a nondiscriminatory basis to all those that
request it within its service area. Idaho Power has experienced and expects sustained
load growth, thereby requiring the addition of new resources. To meet its obligation to
reliably serve customer load and fill capacity deficiencies identified in 2026 and 2027, the
Company conducted a competitive solicitation through the issuance of an "all-source"
RFP seeking to acquire a combination of energy and capacity resources. Idaho Power
Case No. IPC-E-22-13.
2 Case Nos. IPC-E-23-05 and IPC-E-23-20.
3 Case No. IPC-E-23-20.
APPLICATION - 3

did not define the type of resource (i.e., wind, solar, gas, or battery storage) desired;
however, the Company outlined that the deficit could require as much as 1,100
megawatts (WW") of variable energy resources and a minimum of 350 MW of peak
capacity to help meet Idaho Power's previously identified capacity needs in 2026 and
2027 ("2026 RFP"). The procurement process resulted in the identification of least-cost,
least-risk resources necessary to fill the identified 2026 capacity deficiency of 236 MW.
The proposed acquisition, as described herein, is necessary and required in order to
continue to provide reliable and adequate electric service to Idaho Power's customers
starting in the summer of 2026 and into the future.
III. OREGON PROCUREMENT RULES
4. The Commission, in Case No. IPC-E-10-03, initiated a case seeking to
establish competitive bidding guidelines for the RFP process. In 2013, the Commission
closed Case No. IPC-E-10-03 without establishing Idaho-specific resource procurement
guidelines, but rather directing Idaho Power to follow the RFP guidelines applicable to its
Oregon service territory. The Oregon RFP guidelines to which the Commission referred
were later codified into the administrative rules of the Public Utility Commission of Oregon
("OPUC") resource procurement rules.4 The OPUC resource procurement rules impose
competitive bidding requirements upon an electric utility for the "acquisition of a resource
or a contract for more than an aggregate of 80 MWs and five years in length," among
other requirements.
5. On September 15, 2022, Idaho Power filed an Application with the OPUC
initiating a rule compliant RFP process to acquire resources to be online in 2026 and
4 Oregon Administrative Rule ("OAR") 860-089-0010 et seq.
APPLICATION -4

2027. Subsequently an independent evaluator was appointed, and the Company went
through all the required steps associated with issuance of the RFP, receipt and evaluation
of bids, and ultimately the approval of a final shortlist of prospective projects to meet the
2026 and 2027 deficits. The OPUC found that Idaho Power conducted a fair and
competitive resource acquisition procurement process in accordance with the OPUC
competitive bidding rules, which resulted in OPUC approval of a final shortlist of the least-
cost, least-risk resources. OPUC Order No. 24-055, Docket UM 2255, Feb. 22, 2024.
The Company has identified, through negotiations, the procurement of three resources
from that approved final shortlist, which can help meet the 2026 capacity deficiency, one
of which is the new dispatchable energy storage facility for which Idaho Power is
requesting the Commission grant a CPCN in this proceeding.
IV. RESOURCE PROCUREMENT PROCESS
6. On September 15, 2022, Idaho Power commenced the competitive bidding
process, filing a request with the OPUC to (1) open a docket for approval of the 2026
RFP, (2) appoint an Independent Evaluator ("IE") to oversee the RFP process, and (3)
approve the proposed 2026 RFP scoring and modeling. On December 27, 2022, the
OPUC approved the selection of London Economic International, LLC ("LEI") as the IE
for Idaho Power's 2026 RFP and evaluation of 2026 RFP resources. The OPUC also
approved the concurrent discussion of both scoring and modeling methodologies and
preparation of the draft 2026 RFP.
7. The Company worked with OPUC Staff and stakeholders to finalize the draft
2026 RFP and on June 8, 2023, Idaho Power formally issued the 2026 RFP, soliciting
bids for (1) energy market purchases and (2) new or existing resources. The 2026 RFP
APPLICATION - 5

was well received with 192 bids from 31 different bidders across 47 resources sites,
summing to more than 15 gigawatts of resources. Approximately 40 percent of the bids
reflected a commercial operation date by June 1, 2026, the remaining 60 percent of the
bids reflected a projected commercial operation date after June 1, 2026. The bids
included a variety of ownership structures, including many bids that would result in bidder-
owned resources (i.e., PPA's, and BSA's), as well as three benchmark bids across three
sites, submitted by Idaho Power's Power Supply department.
8. The direct testimony of Mr. Hackett details the bid evaluation process which
was consistent and prescriptive as described in the 2026 RFP, ultimately identifying the
final shortlist of projects, including six with commercial operation in 2026. Confidential
Exhibit No. 7 to Mr. Hackett's Direct Testimony lists the 2026 projects identified on the
final shortlist. As required under the OPUC competitive bidding rules, the OPUC approved
Idaho Power's final shortlist on February 22, 2024. Once the most cost-effective 2026
projects were identified, the Company began negotiations with developers for
procurement of the three resources necessary to meet Idaho Power's 2026 capacity
deficit.
V. RESOURCE DESCRIPTIONS
9. The bid evaluation process of the project proposals submitted through the
2026 RFP is designed to identify the combination and size of the proposed resources that
will maximize customer benefits while ensuring the Company meets its energy and
capacity needs, ultimately resulting in the selection of three least-cost, least-risk projects
to meet the 2026 capacity deficiency of 236 MW: (1) a market purchase product with
Powerex Corp. ("Powerex"), (2) the 200 MW solar photovoltaic ("PW) plus
APPLICATION - 6

100 MW battery storage project, and (3) a benchmark resource, the Idaho Power-owned
battery storage facility providing up to 150 MW of operating capacity. Upon conclusion of
the approximately 16-month mandated competitive bidding rule-compliant process, the
Company immediately executed the Powerex agreement and subsequently filed a
request for Commission approval because of the contractual deadline within the
agreement.5 Idaho Power also immediately initiated the procurement process for the
Company-owned battery energy storage system ("BESS") facility at the Boise Bench
station providing 150 MW of operating capacity. Idaho Power has been working
expeditiously to initiate this CPCN request, because the Company must initiate the
purchase order with the battery supplier and secure the BESS in parallel with the
processing of this case to enable the completion of this critical capacity project in time to
meet the identified 2026 deficit. That said, Idaho Power respectfully requests the
Commission issue a CPCN as soon as practicable. Idaho Power will request approval of
the agreement associated with the 200 MW solar PV plus 100 MW battery storage project
in a subsequent proceeding.
VI. CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
10. Idaho Power has an obligation to provide adequate, efficient, just, and
reasonable service on a nondiscriminatory basis to all those that request it within its
certificated service territory. Idaho Code §§ 61-302, 61-315, 61-507. The Commission
must assure that the rates Idaho Power charges its customers and that the rules and
regulations by which it provides service are just, reasonable, nondiscriminatory, and non-
preferential. Idaho Code §§ 61-501, 61-502, 61-503, 61-507, 61-508. The Company
5 Case No. IPC-E-24-12, Idaho Power's Application for Approval of a Market Purchase Agreement filed
on March 18, 2024.
APPLICATION - 7

must acquire the additional dispatchable resources with 150 MW of operating capacity to
meet the identified capacity deficits on its system in order to comply with its continuing
obligation to serve customers, and thus is requesting an order from the Commission
affirming that the public convenience and necessity requires the same. The proposed
acquisition represents a cost-effective means of providing adequate and reliable service
to the customers in Idaho Power's certificated service territory. The Commission has the
express authority to order a utility to build new structures, or to upgrade and/or improve
existing plant and structures, in order to secure adequate service or facilities.
Whenever the commission, after a hearing had upon its own
motion or upon complaint, shall find that additions,
extensions, repairs or improvements to or changes in the
existing plant, scales, equipment, apparatus, facilities or other
physical property of any public utility . . . ought reasonably to
be made, or that a new structure or structures should be
erected, to promote the security or convenience of its
employees or the public, or in any other way to secure
adequate service or facilities, the commission shall make and
serve an order directing such additions, extensions, repairs,
improvements, or changes be made or such structure or
structures be erected in the manner and within the time
specified in said order.
Idaho Code § 61-508.
11. A CPCN or Certificate represents the exercise by the Commission of
foundational authority and principles that are necessary in Idaho's system of permitting
regulated, vertically integrated, public utilities to exist and to provide necessary services
to the public. Certificates have been utilized in various ways from the time that Idaho's
statutory system of public utility regulation was enacted by the Legislature in 1913, Idaho
Code § 61-101, et seq., to the present time. After nearly 100 years of legislative
enactments, Commission orders, and Idaho Supreme Court reviews, the Certificate
remains the embodiment of the Commission's fundamental power and authority to, at the
most basic level, authorize and direct a public utility to serve in the public interest. See
APPLICATION - 8

Idaho Power& Light Co. v. Blomquist et al., 26 Idaho 222, 141 P.1083 (1914); Idaho Op.
Atty. Gen. No. 87-2, 1987 WL 247587 (Idaho A.G.).
12. In the broadest sense, a Certificate allows a company that meets the
definition of a "public utility" pursuant to Idaho Code § 61-129 to exclusively provide its
service to the public in a specified geographic region, its service territory. It is a codified
part of the "regulatory compact" whereby the utility takes on the exclusive obligation/right
to serve all those requesting service within its service territory and, correspondingly,
submits itself to the rate and service quality regulation of the Commission. In a more literal
sense, a Certificate from the Commission is required for the construction or extension of
a line, plant, or system by any street, railroad, gas, electrical, telephone, or water
corporation. Idaho Code § 61-526. § 61-526 also provides that "if public convenience
and necessity does not require or will require such construction or extension [of a line,
plant, or system] the commission . . . may, after hearing, make such order and prescribe
such terms and conditions for the locating or type of line, plant or system affected as to it
may seem just and reasonable . . . ." A CPCN is required for the utility to construct a new
generation resource or plant but is not required to increase the capacity of existing
generating facilities. Id.
VII. RATEMAKING TREATMENT FOR THE ENERGY STORAGE PROJECT
13. Idaho Power is not requesting binding ratemaking treatment for the battery
storage providing 150 MW of operating capacity in this case as it did for the Langley Gulch
Power Plant CPCN, Case No. IPC-E-09-03. The Company's request in this case is that
the Commission find Idaho Power has met the requirements of Idaho Code § 61-526 and
issue an order granting a CPCN to acquire the energy storage with 150 MW of operating
capacity necessary to meet the identified capacity deficiencies in 2026. The Company will
make a future filing to address the cost recovery associated with this project.
APPLICATION - 9

VIII. FINANCING THE ENERGY STORAGE
14. Idaho Power maintains investment grade credit ratings with Standard &
Poor's Ratings Services and Moody's Investors Service, with a long-term issuer rating of
BBB and Baal, respectively. The Company maintains ready access to the capital markets
and to instruments providing for its liquidity. Idaho Power has a $400 million revolving
credit facility with its banking syndicate, which may be increased to $600 million under
specified conditions, which matures on December 8, 2028. The Company has an option
to request up to two one-year extensions of the agreement, subject to certain
conditions. Idaho Power also has authority from state regulatory commissions to issue up
to $1.2 billion in aggregate principal amount of debt securities, all of which remained
available as of December 31, 2023. The Company also has access to commercial paper
markets, as well as a balance of cash and investments on its balance sheet. Additionally,
Idaho Power has access to capital and credit outside of existing mechanisms and
instruments, such as through term loans, letter of credit, and other
instruments. IDACORP, the parent entity of Idaho Power, sold 3,221,982 shares of
IDACORP common stock in November of 2023 under a forward sale agreement. All of
the shares remain available for share settlement in exchange for cash on a date or dates
to be specified at IDACORP's discretion, but which is expected to occur on or prior to
November 7, 2024. The estimated proceeds of over $291 million will be primarily used
to infuse equity to Idaho Power. The Company intends to finance the energy storage with
150 MW of operating capacity with a combination of available cash and operating cash
flow, available credit facilities and borrowing and debt issuances, and future equity
infusions by IDACORP.
APPLICATION - 10

IX. COMMUNICATIONS AND SERVICE OF PLEADINGS
15. Communications and service of pleadings with reference to this Application
should be sent to the following:
Donovan E. Walker Tim Tatum
Lead Counsel Vice President, Regulatory Affairs
Idaho Power Company Idaho Power Company
1221 West Idaho Street (83702) 1221 West Idaho Street (83702)
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
dwalker idahopower.com ttatumC@.idahopower.com
dockets(aMdahopower.com
X. MODIFIED PROCEDURE
16. The Company believes that a hearing is not necessary to consider the
issues presented herein, and respectfully requests that this Application be processed
under Modified Procedure; i.e., by written submissions rather than by hearing. RP 201, et
seq. If, however, the Commission determines that a technical hearing is required, the
Company stands ready to present its testimony and support the Application in such
hearing.
XI. REQUEST FOR RELIEF
Idaho Power respectfully requests that the Commission issue an order granting
the Company a CPCN to acquire new dispatchable energy storage with 150 MW of
operating capacity. Because approval of this request is necessary to position Idaho Power
to meet its obligation to provide safe, reliable service to its customers, the Company
respectfully requests that the Commission issue an order as soon as practicable.
APPLICATION - 11

DATED at Boise, Idaho this V day of April 2024.
DONOVAN E. WALKER
Attorney for Idaho Power Company
APPLICATION - 12