20240403Direct Testimony Ellsworth.pdf

RECEIVED
Wednesday,April 3,2024 4:50 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 BENCH )
BATTERY STORAGE FACILITY. )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
JARED L. ELLSWORTH

1 Q. Please state your name, business address, and
2 present position with Idaho Power Company ("Idaho Power" or
3 "Company") .
4 A. My name is Jared L. Ellsworth and my business
5 address is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power as the Transmission, Distribution &
7 Resource Planning Director for the Planning, Engineering &
8 Construction Department .
9 Q. Please describe your educational background.
10 A. I graduated in 2004 and 2010 from the
11 University of Idaho in Moscow, Idaho, receiving a Bachelor
12 of Science Degree and Master of Engineering Degree in
13 Electrical Engineering, respectively. I am a licensed
14 professional engineer in the State of Idaho .
15 Q. Please describe your work experience with
16 Idaho Power.
17 A. In 2004, I was hired as a Distribution
18 Planning engineer in the Company' s Delivery Planning
19 department . In 2007, I moved into the System Planning
20 department, where my principal responsibilities included
21 planning for bulk high-voltage transmission and substation
22 projects, generation interconnection projects, and North
23 American Electric Reliability Corporation' s ("NERC")
24 reliability compliance standards . I transitioned into the
25 Transmission Policy & Development group with a similar
ELLSWORTH, DI 1
Idaho Power Company

1 role, and in 2013, I spent a year cross-training with the
2 Company' s Load Serving Operations group. In 2014, I was
3 promoted to Engineering Leader of the Transmission Policy &
4 Development department and assumed leadership of the System
5 Planning group in 2018 . In early 2020, I was promoted into
6 my current role as the Transmission, Distribution and
7 Resource Planning Director. I am currently responsible for
8 the planning of the Company' s wires and resources to
9 continue to provide customers with cost-effective and
10 reliable electrical service .
11 Q. What is the Company' s request in this case?
12 A. Idaho Power is requesting the Idaho Public
13 Utilities Commission ("Commission") grant the Company a
14 Certificate of Public Convenience and Necessity ("CPCN") to
15 acquire new dispatchable energy storage with 150
16 megawatts ("MW") of operating capacity and necessary to meet
17 the identified capacity deficiency in 2026 .
18 Q. What is the purpose of your testimony in this
19 case?
20 A. The purpose of my testimony is to inform the
21 Commission of the Company' s need for new resources to meet
22 an identified capacity deficit in 2026 as informed by a
23 Loss of Load Expectation ("LOLE") methodology utilized in
24 the 2021 Integrated Resource Plan ("IRP") , again in the
25 2023 IRP, and subsequently further enhanced through system
ELLSWORTH, DI 2
Idaho Power Company

1 reliability evaluations . I will describe the most recent
2 assessment of system reliability and its impact to the
3 capacity deficit identified in the annual capacity position
4 utilized in the 2023 IRP. Finally, I will provide support
5 for the acquisition of resources to address the identified
6 near-term capacity needs .
7 Q. Is this the same assessment of system
8 reliability that was performed to support the Company' s
9 request in Case No . IPC-E-24-12, Idaho Power's Application
10 for Approval of a Market Purchase Agreement filed on March
11 18, 2024?
12 A. Yes, it is .
13 I . BACKGROUND
14 Q. What is the goal of the IRP?
15 A. The goal of the IRP is to ensure : (1) Idaho
16 Power' s system has sufficient resources to reliably serve
17 customer demand and flexible capacity needs over a 20-year
18 planning period, (2) the selected resource portfolio
19 balances cost, risk, and environmental concerns, (3)
20 balanced treatment is given to both supply-side resources
21 and demand-side measures, and (4) the public is involved in
22 the planning process in a meaningful way. Idaho Power uses
23 Energy Exemplar' s AURORA' s Long-Term Capacity Expansion
24 ("LTCE") modeling platform to develop portfolios, through
25 the selection of a variety of supply- and demand-side
ELLSWORTH, DI 3
Idaho Power Company

1 resource options, that are least-cost for a variety of
2 alternative future scenarios while meeting reliability
3 criteria. To verify the top performing portfolios meet the
4 Company' s reliability requirements, Idaho Power utilizes a
5 LOLE methodology.
6 Q. Please explain the Loss of Load Expectation.
7 A. The LOLE is a statistical measure of a
8 system' s resource adequacy, describing the expected number
9 of event-days per year that a system would be unable to
10 meet demand. As utilities continue to add more renewable
11 energy to the electric grid, analyzing the effect variable
12 energy resources have on system reliability has become more
13 critical . The LOLE methodology recognizes that the output
14 of variable energy resources, such as wind and solar,
15 change with time (with their hourly output being dependent
16 on a multitude of factors like weather and environmental
17 conditions) ; it is essential to capture and value that
18 variability.
19 Q. What inputs are derived from the LOLE
20 methodology that are utilized in the AURORA LICE model?
21 A. Idaho Power implements the LOLE methodology
22 through an internally developed Reliability and Capacity
23 Assessment Tool ("RCAT") which is capable of producing
24 inputs such as a Planning Reserve Margin ("PRM") and
25 resource Effective Load Carrying Capability ("ELCC")
ELLSWORTH, DI 4
Idaho Power Company

1 values . The PRM metric can be defined as the percentage of
2 expected capacity resources above forecasted peak demand.
3 The ELCC calculation is a reliability-based metric used to
4 assess the capacity contribution of variable and energy-
5 limited resources . The PRM and ELCC values that are
6 calculated using the LOLE methodology are a direct input to
7 the AURORA LICE model .
8 Q. How are the PRM and ELCC values utilized?
9 A. Because the AURORA LTCE model and the RCAT are
10 two separate tools, a translation is required between the
11 probabilistic LOLE analysis performed in RCAT and the
12 portfolios produced by the AURORA LTCE model . First, PRM
13 and ELCC values are calculated using the LOLE methodology
14 and directly inputted to the AURORA LTCE model . After
15 AURORA solves for and produces portfolios, select resource
16 buildouts and their corresponding data are analyzed with
17 the LOLE methodology and tested to ensure they meet the
18 pre-designated reliability hurdle through the calculation
19 of annual capacity positions . It is critical when comparing
20 future resource portfolios that each plan achieves at least
21 a base reliability threshold. Figure 1 below illustrates
22 the model consolidation process .
23
24
25
ELLSWORTH, DI 5
Idaho Power Company

1 Figure 1 . Idaho Power' s Reliability Flowchart
_ T
Generation ELCC
aftl"LO ao.10 C- wRy I
Jn..,
RCAT LOLE LTCEw��7a�M7 rocs dloatl Fgooctri�., toq 7�m.C-P-M.',P_,..eM7� -� -� y
Blau n NtlRARn •_._
nM
L&R
load
Manning Peurvr Margin CaP-ty PP t.
2
3 Q. Have the LOLE-derived annual capacity
4 positions replaced the previously utilized load and
5 resource balance?
6 A. Yes . While they serve the same purpose, to
7 determine capacity deficiencies, the annual capacity
8 position calculation is a 2023 IRP methodology improvement
9 that replaced the load and resource balance process
10 performed in prior IRP filings . The load and resource
11 balance was a tabulated plan that helped visually ensure
12 Idaho Power had sufficient resources to meet projected
13 customer demand including a margin to account for extreme
14 conditions, reserves, and resource outages, identifying
15 resource deficiencies during the 20-year IRP planning
16 horizon. Beginning with the 2023 IRP, to better align with
17 and represent the probabilistic reliability analyses
18 utilized and to be consistent with best practices in the
ELLSWORTH, DI 6
Idaho Power Company

1 industry, the RCAT was utilized to calculate annual
2 capacity positions in place of the deterministic load and
3 resource balance . The LOLE-derived annual capacity position
4 calculation is a better indication of resource reliability
5 as compared to the previously utilized load and resource
6 balance . The goal is the same under both processes :
7 identification of the timing of the Company' s first
8 resource need, or the point at which Idaho Power' s
9 reliability requirements may not be met .
10 Q. If the goal of both processes is the same, how
11 is the LOLE-derived annual capacity position calculation an
12 IRP methodology improvement?
13 A. In the 2021 IRP, the Company derived static
14 PRM and resource ELCC values that were held constant
15 throughout the 20-year planning horizon. As the RCAT and
16 AURORA serve different purposes in Idaho Power' s planning
17 process, the Company recognized that further efforts were
18 needed to translate and align the data exchanged between
19 the two models . Historically, the PRM was based on the peak
20 load of a given year plus some additional amount to account
21 for abnormal weather events or equipment outages . This
22 method worked well to ensure reliability for Idaho Power as
23 a summer peaking utility with mostly flexible generation
24 resources . However, as the wider industry, and the Company,
25 experience increased reliance on variable energy resources,
ELLSWORTH, DI 7
Idaho Power Company

1 whose hour-to-hour and season-to-season generation changes,
2 it is no longer viable to only contemplate peak hour
3 requirements .
4 To ensure that AURORA would recognize similar
5 capacity needs as identified by the RCAT, the Company
6 developed seasonal PRM values for years in the planning
7 horizon that experience significant changes in the resource
8 buildout, better representing the seasonal resource needs .
9 Historically, when a portfolio added predominantly flexible
10 generation resources it was also sufficient to give these
11 resources a static peak capacity contribution as it was
12 harmonious with a static PRM. As variable energy resource
13 and energy limited resource additions increase, static
14 values no longer account for the reduced peak capacity
15 contribution due to saturation nor do they capture the
16 diversity benefit (positive or negative) of a mix of
17 different types of variable energy resources and energy
18 limited resources .
19 Q. Were any changes made to the use of resource
20 ELCC values as well?
21 A. Yes . The ELCC of future variable energy
22 resources and energy limited resources are dependent upon
23 the resources built before them, making the ELCC
24 calculation of future resources challenging. Idaho Power
25 implemented seasonal resource specific ELCC saturation
ELLSWORTH, DI 8
Idaho Power Company

1 curves for variable energy resources and energy limited
2 resources in the AURORA LICE model for the 2023 IRP.
3 Q. Please explain the synchronization of the RCAT
4 and the AURORA LTCE model .
5 A. To better assess the dynamic diversity benefit
6 caused by a changing resource mix, a feedback process was
7 implemented between the AURORA LICE model and the RCAT for
8 the 2023 IRP. Under the feedback process, the annual
9 capacity positions for an AURORA LTCE main case portfolio
10 buildout were calculated using the RCAT . Once the annual
11 capacity positions were known, the PRM in the AURORA LTCE
12 model was modified in years that had significant resource
13 changes so that both models identified a similar annual
14 capacity position. The feedback loop continued until the
15 main case portfolio was reliable under the LOLE threshold.
16 The resulting AURORA-produced optimized main case
17 portfolios provide the least-cost, least-risk future
18 resource buildouts .
19 II . ANNUAL CAPACITY POSITION
20 Q. What have the previous capacity position
21 results indicated with respect to Idaho Power' s resource
22 sufficiency?
23 A. The Company has been generally resource-
24 sufficient since the addition of the Langley Gulch natural-
25 gas fired power plant almost a decade ago until the filing
ELLSWORTH, DI 9
Idaho Power Company

1 of the 2021 IRP. That is, Idaho Power' s owned generation
2 and transmission resources, along with negotiated purchases
3 under Power Purchase Agreements ("PPA") and mandatory
4 purchases under the Public Utility Regulatory Policies Act
5 of 1978 ("PURPA") , were sufficient to meet the Company' s
6 load growth over that time . With the resource and load
7 inputs from the 2021 IRP, Idaho Power rapidly moved from an
8 expected resource-sufficient position through 2028, 1 to a
9 near-term capacity deficiency starting in 2023 . The rapid
10 change in the resource position, identified during
11 preparation of the 2021 IRP, was caused by several dynamic
12 and converging factors, including third-party transmission
13 capacity constraints, load growth, and a decline in the
14 peak-serving effectiveness of certain supply-side and
15 demand-side resources . These dynamic circumstances led the
16 Company to immediately file a request for a CPCN to acquire
17 resources to be online in 2023 . 2
18 Q. What were the capacity positions ultimately
19 identified in the 2021 IRP?
20 A. The capacity positions identified in Idaho
21 Power' s 2021 IRP, acknowledged with Order No . 35603, 3 were
22 deficits of approximately 101 MW in 2023, 186 MW in 2024,
1 Idaho Power's Second Amended 2019 Integrated Resource Plan, Case No. IPC-E-19-
19.
2 Case No. IPC-E-22-13.
3 Case No. IPC-E-21-43.
ELLSWORTH, DI 10
Idaho Power Company

1 311 MW in 2025, 560 MW in 2026, and 665 MW in 2027 . As a
2 result, in addition to the Company' s request for a CPCN for
3 the 2023 resource procurement, Idaho Power filed a CPCN and
4 approval of a PPA to acquire resources to be online in 20244
5 and a CPCN and approval of an Energy Storage Agreement to
6 acquire resources to be online in 2025 . 5
7 Q. Since the completion of the 2021 IRP, has the
8 Company refreshed its capacity positions, potentially
9 influencing Idaho Power' s resource need?
10 A. Yes . The Company continually assesses system
11 reliability, monitoring near-term known changes,
12 operational enhancements, limitations, or constraints on
13 the existing system, if any, that would impact the resource
14 needs . Furthermore, on September 29, 2023, the Company
15 filed its 2023 IRP, which included current information on
16 the expected timing of major new loads, the resource
17 procurements the Company had made to date, annual capacity
18 positions and other updates .
19 Q. What were the annual capacity positions
20 identified in the 2023 IRP?
21 A. Incorporating modeling input updates and the
22 additional enhancements to the Company' s reliability
23 evaluation discussed earlier in my testimony, the
4 Case No. IPC-E-23-05 and IPC-E-23-20.
5 Case No. IPC-E-23-20.
ELLSWORTH, DI 11
Idaho Power Company

1 incremental capacity needs identified in the 2023 IRP were
2 22 MW in 2026 and 44 MW in 2027, with the need continuing
3 to grow through the remainder of the planning horizon.
4 Q. Did Idaho Power' s modeling updates include the
5 Boardman to Hemingway transmission line ("B2H") as a new
6 resource?
7 A. Yes . B2H was identified and acknowledged as a
8 cost-effective resource in the Company' s 2021 IRP preferred
9 resource portfolio with a current planned in-service date
10 of summer of 2026 . B2H will provide Idaho Power with 750 MW
11 of capacity in the west-to-east direction for market
12 purchases for load service and transmission service to
13 third-party transmission customers under the Company' s Open
14 Access Transmission Tariff. Further, an asset exchange
15 between PacifiCorp and Idaho Power, in complement with B2H,
16 will provide the Company with 200 MW of bidirectional
17 transmission capacity between southern power markets (Mona
18 and Four Corners) and the Idaho Power system. The full B2H
19 capacity is modeled in the transmission portion of AURORA,
20 with separate transmission links modeled for each owner,
21 one with Idaho Power' s share and one with PacifiCorp' s
22 share . The Company treats approximately 500 MW of B2H' s
23 summer capacity as equivalent to a summer resource and the
24 200 MW of transmission capacity to southern power markets
25 as equivalent to a winter resource . All transmission
ELLSWORTH, DI 12
Idaho Power Company

1 capacity has the potential to be leveraged for market
2 purchases . The 2023 IRP continued to confirm the cost-
a effectiveness of B2H and the associated asset exchange and
4 its inclusion in the IRP' s Preferred Portfolio .
5 Q. Did Idaho Power evaluate how the annual
6 capacity position would change should the online date of
7 B2H be delayed?
8 A. Yes . The 2023 IRP considered an alternative
9 B2H online date beyond July 2026 should there be a delay in
10 receiving permits, supply chain constraints, or other
11 unforeseen events . The alternative scenario assumed a
12 November 2026 online date for B2H, which changes the
13 Company' s capacity needs from 22 MW under a July 2026 B2H
14 online date to 356 MW under a November 2026 B2H online
15 date .
16 Q. You indicated Idaho Power continually assesses
17 system reliability. Has the Company updated the system
18 reliability assessment since the 2023 IRP was filed in
19 September 2023?
20 A. Yes . The Company recognizes that during the
21 near-term resource decision-making phase, the annual
22 capacity positions can be very fluid. In addition, in the
23 face of growing loads, Idaho Power constantly monitors
24 resource needs and responds with added urgency, as
25 evidenced by Idaho Power' s consecutive requests for CPCNs
ELLSWORTH, DI 13
Idaho Power Company

1 to acquire resources to be online in 2023, 2024 and 2025 . 6
2 The most recent system reliability assessment, which
3 assumes the online date for B2H is beyond summer of 2026,
4 has identified a capacity deficit of 236 MW in 2026 .
5 Q. What drove the changes to the annual capacity
6 positions for 2026 in the most recent system reliability
7 assessment?
8 A. Aside from modeling input updates associated
9 with the latest load forecast, expected existing resource
10 availability and the most recent 5-year rolling average
11 Equivalent Forced Outage Rates during Demand ("EFORd") , the
12 biggest drivers of the change in the annual capacity
13 position in 2026 are associated with (1) B2H, (2) the
14 Capacity Benefit Margin ("CBM") , and (3) the North Valmy
15 Generating Station ("Valmy") . Due to delays in obtaining
16 some necessary permits, the anticipated in-service date of
17 B2H is beyond the summer of 2026 . Absent the available
18 transfer capacity of B2H in July 2026 the capacity deficit
19 increases .
20 Q. What changes were made to the CBM modeling
21 assumptions since the annual capacity position identified
22 in the development of the 2023 IRP?
23 A. CBM is transmission capacity Idaho Power sets
24 aside on the Company' s transmission system, as unavailable
6 Case Nos. IPC-E-22-13, IPC-E-23-05, and IPC-E-23-20.
ELLSWORTH, DI 14
Idaho Power Company

1 for firm use, for the purposes of accessing reserve energy
2 to recover from severe conditions such as unplanned
3 transmission and generation outages or energy emergencies .
4 An energy emergency must be declared by Idaho Power before
5 the CBM transmission capacity becomes firm. The Company
6 holds 330 MW of import transmission capacity aside on the
7 Idaho to Northwest path for CBM. CBM does not, however,
8 have corresponding third-party transmission reservations to
9 the Mid-C market .
10 Because of continued transmission market
11 limitations beyond the Idaho Power border, in the 2023 IRP
12 the Company reduced the contribution of CBM toward the
13 annual capacity position, from 330 MW for all seasons to
14 200 MW for March through October and 0 MW in the winter for
15 planning purposes . Idaho Power' s continued evaluation of
16 CBM has indicated that, similar to the winter months, last
17 minute transmission acquisition between the market and
18 Idaho Power' s border under emergency conditions in the
19 summer months has not been consistently available . The
20 Company still believes CBM is valuable for customers from a
21 reliability perspective and believes that transmission
22 availability may change in the future . However, for the
23 time-being, for resource planning purposes, the Company
24 believes it is appropriate to adjust CBM to 0 MW year-round
25 given the recent challenges ensuring a connection to the
ELLSWORTH, DI 15
Idaho Power Company

1 Mid-C market in emergency conditions .
2 Q. What changes were made to Valmy' s availability
3 that have impacted the annual capacity position?
4 A. Since identification of the conversion of
5 Valmy Units 1 and 2 to natural gas operations by 2026 as an
6 economic resource alternative in the 2023 IRP, Idaho Power
7 and NV Energy, the Valmy co-owners, have aligned on a
8 decision to convert the units and have finalized a
9 conversion agreement that will amend the pertinent sections
10 of the existing ownership and operations agreements to
11 reflect gas-fired operations of both units . With definitive
12 agreements in place that detail the Company' s increased
13 Valmy capacity beginning in 2026, Idaho Power included the
14 additional 261 MW of available capacity in the latest
15 system reliability assessment .
16 Q. You indicated modeling input changes consisted
17 of updates made to the latest load forecast, resource
18 availability and EFORd. What has changed since development
19 of the 2023 IRP?
20 A. Any time the system reliability evaluation is
21 performed, Idaho Power includes the most up-to-date load
22 and resource inputs . With the continued high load growth in
23 the Company' s service area, the load forecast is
24 consistently monitored and updated as new information
25 becomes available . In addition, planned maintenance of one
ELLSWORTH, DI 16
Idaho Power Company

1 of the Oxbow hydro units will reduce the overall resource
2 availability in 2026 . The 5-year rolling average EFORd was
3 updated with the latest published data from the NERC
4 Generation Availability Data System, reflecting the
5 industry average generation resource performance data and
6 outage rates using the most recent data. Finally, two PURPA
7 contracts with solar projects proposed to be located in
8 eastern Oregon were terminated due to the developers'
9 failure to perform, resulting in the removal of 72 MW of
10 available solar nameplate capacity.
11 Q. Based on your most recent evaluation of system
12 reliability, how has the annual capacity position for 2026
13 changed since Idaho Power' s 2023 IRP was filed?
14 A. The Company' s most recent system reliability
15 assessment to determine the annual capacity positions has
16 identified an increase in the previously identified
17 capacity deficit to 236 MW in 2026 . As I discussed
18 previously, due to the fluidity of the annual capacity
19 positions during the near-term resource decision-making
20 phase, Idaho Power continually assesses system reliability.
21 But because the Company has been repeatedly matching near-
22 term resource procurements with the capacity need
23 identified at a point in time, the fluctuating need is
24 requiring continued procurement of resources .
ELLSWORTH, DI 17
Idaho Power Company

1 Q. Does the load forecast used to identify the
2 236 MW deficit in 2026 include large load inquiries that
3 Idaho Power continues to experience in its service
4 territory?
5 A. No. In the 2023 IRP, the Company provided a
6 large load planning scenario that added 200 MW to Idaho
7 Power' s load forecast to account for potential additional
8 large loads . Although the Company continues to receive
9 inquiries for large loads that are considering siting in
10 Idaho Power' s service territory, the Company has not yet
11 utilized this large load scenario to determine its future
12 resource procurement needs . Idaho Power will continue to
13 evaluate whether a transition to the large load scenario is
14 necessary. Such a transition would increase resource
15 deficits in future years .
16 III . MEETING THE CAPACITY DEFICIENCY
17 Q. Did Idaho Power evaluate any alternative
18 solutions for meeting the capacity deficiencies to avoid
19 building a new resource?
20 A. Yes . As I discussed earlier in my testimony,
21 as part of the IRP process, the Company uses AURORA' s LICE
22 modeling platform to develop portfolios, through the
23 selection of a variety of supply- and demand-side resource
24 options, that are least-cost for a variety of alternative
25 future scenarios while meeting reliability criteria. The
ELLSWORTH, DI 18
Idaho Power Company

1 future supply- and demand-side resources available to meet
2 identified capacity deficiencies, whose costs are generally
3 based on the 2022 Annual Technology Baseline report
4 released by the National Renewable Energy Laboratory, ?
5 include new gas-fired resources, hydrogen, wind, solar,
6 battery storage, market purchases via available
7 transmission capacity, demand response and energy
8 efficiency. The Preferred Portfolio from the 2023 IRP,
9 which included a July 2026 online date for B2H, identified
10 the conversion of Valmy Units 1 and 2 to natural gas, the
11 procurement of 100 MW of solar as the most cost-effective
12 resources for meeting the identified capacity deficits in
13 2026 along with 19 MW of energy efficiency potential
14 (identified in the energy efficiency potential study) . In
15 addition, as part of the 2023 IRP modeling, the Company
16 evaluated an alternative B2H online date beyond July 2026
17 should there be a delay in receiving permits, supply chain
18 constraints, or other unforeseen events, assuming an online
19 date for B2H of November 2026 . This evaluation is, in
20 essence, identifying the most cost-effective alternative
21 for meeting the identified capacity deficit should the B2H
22 online date be delayed to November 2026 .
23 Q. How was the evaluation of the November 2026
24 B2H on-line date performed?
atb.nrel.gov/.
ELLSWORTH, DI 19
Idaho Power Company

1 A. Three different November 2026 B2H simulations
2 were analyzed with AURORA' s LICE modeling: (1) a November
3 2026 B2H on-line date with a conversion of both Valmy Units
4 1 and 2 to natural gas, (2) a November 2026 B2H on-line
5 date with the conversion of only Valmy Unit 2 to natural
6 gas, and (3) a November B2H on-line date without the
7 availability of either Valmy unit . These simulations
8 include the costs associated with adding generation
9 resources (both supply-side and demand-side) and optimally
10 dispatching the resources to meet the constraints within
11 the model . The three different simulations and their
12 associated costs, presented below in Table 1, can be
13 compared to identify the most cost-effective alternative to
14 meeting the 2026 capacity deficit should B2H be delayed to
15 November 2026 .
16 Table 1 . 2023 IRP Portfolio Costs
Portfolio Net Present Value
Years 2024-2043
($ x 1,000 ,000)
(1) Nov2026 B2H Valmy 1&2 $9, 767
(2) Nov2026 B2H Valmy 2 $9, 880
(3) Nov2026 B2H Without Valmy $10, 192
17
18 With a portfolio cost of $9 . 767 billion, the conversion of
19 Valmy Units 1 and 2 to natural gas in 2026 is $113 million
20 less than the conversion of only Valmy Unit 2, and $425
ELLSWORTH, DI 20
Idaho Power Company

1 million less than a portfolio that does not include the
2 conversion to natural gas of either Valmy unit, indicating
3 that the conversions of Valmy Units 1 and 2 to natural gas
4 continues to be a cost-effective resource alternative,
5 particularly with a November 2026 B2H online date .
6 Q. What additional resources were selected as
7 cost-effective alternatives for meeting the capacity
8 deficiency under a scenario with a November 2026 B2H online
9 date and the conversion of both Valmy units to natural gas?
10 A. When compared to the 2023 IRP Preferred
11 Portfolio, in 2026 an additional 300 MW of solar was
12 selected, 400 MW in total, as well as 155 MW of battery
13 storage and 40 MW of demand response, indicative of the
14 Company' s need to procure resources to continue to provide
15 safe, reliable electric service to its customers in 2026
16 and beyond.
17 Q. Has Idaho Power taken any actions to acquire
18 resources to meet the 236 MW capacity deficit in 2026?
19 A. Yes . Under Idaho law, Idaho Power has an
20 obligation to provide adequate, efficient, just, and
21 reasonable service on a nondiscriminatory basis to all
22 those that request it within its certificated service area. 8
23 Further, as indicated by Order No . 35643, Idaho Power is
24 responsible for planning and managing its load and resource
e Idaho Code §§ 61-302, 61-315, 61-507.
ELLSWORTH, DI 21
Idaho Power Company

1 portfolio and the Commission expects "the Company to
2 closely monitor its projected capacity needs going forward
3 and to act proactively to ensure a robust RFP process can
4 be completed. "9 Therefore, in order to meet its obligations
5 to reliably serve customers, on September 15, 2022, Idaho
6 Power filed an application with the Public Utility
7 Commission of Oregon ("OPUC") to open an independent
8 evaluator selection docket to oversee the Request for
9 Proposals ("RFP") process . 10 This also ensured a fair and
10 transparent procurement process that was compliant with the
11 OPUC' s competitive bidding rules, which the Commission
12 directed Idaho Power to follow as well . " The Company' s
13 compliance with the OPUC competitive bidding guidelines,
14 which will be discussed in greater detail in the direct
15 testimony of Mr. Hackett, ultimately led to a competitive
16 solicitation through the issuance of the 2026 All-Source
17 RFP, seeking a combination of energy and capacity resources
18 that provide a minimum of approximately 350 MW of peak
19 capacity and up to 1, 100 MW of variable energy resources
20 for 2026 and 2027 ("2026 RFP") .
21 Q. Why did the 2026 RFP request a minimum of
22 approximately 350 MW of peak capacity and up to 1, 100 MW of
9 Page 13.
10 Docket UM 2255.
11 Order No. 32745. Case No. IPC-E-10-03.
ELLSWORTH, DI 22
Idaho Power Company

1 variable energy resources for 2026 and 2027 if the
2 identified capacity deficit was 236 MW in 2026?
3 A. Following the 2021 IRP, the Company had
4 identified a 311 MW deficiency in 2025 and a 665 MW
5 deficiency in 2027 . Assuming the 311 MW deficiency would be
6 addressed through the 2024 and 2025 resource procurements
7 for which Idaho Power received CPCNs, the incremental need
8 was 354 MW (665 MW - 311 MW = 354 MW) , or approximately a
9 350 MW peak capacity need.
10 Given the significant timeframe related to the RFP
11 process under the OPUC competitive bidding guidelines, the
12 2026 RFP was responsive to the resource needs identified in
13 the Company' s 2021 IRP filing, which included near-term
14 preferred portfolio additions of wind, solar, storage,
15 cost-effective energy efficiency measures, the conversion
16 of coal units to natural gas, incremental demand response,
17 and B2H coming online in 2026 . The transmission included in
18 the 2021 IRP preferred portfolio, including B2H, provides
19 valuable capacity that ultimately must be paired with
20 energy to serve load. In addition to soliciting resources
21 that provide capacity and energy aligned with the resource
22 needs, the 2026 RFP solicited a portion of the energy
23 market purchases that will be necessary to serve load for
24 2026 and beyond. This market purchase approach is intended
25 to allow the Company to begin acquiring a portion of the
ELLSWORTH, DI 23
Idaho Power Company

1 energy that will be needed to serve load using pre-existing
2 firm transmission rights, without acquiring more than what
3 will be needed in a majority of hours, while also allowing
4 Idaho Power to make additional procurement decisions and
5 solicitations over time, considering updated information
6 and the most recent IRP available at that time .
7 Additionally, the RFP needed to remain flexible to
8 account for the fluidity of the Company' s annual capacity
9 positions as well as any potential delays in the B2H online
10 date . Ultimately, the 2026 resources selected through the
11 RFP process were based on the most recent capacity
12 deficiency of 236 MW in 2026 . As detailed in Company
13 witness Mr. Hackett' s testimony, through the Company' s
14 robust competitive bidding process, Idaho Power has
15 identified the most cost-effective bids from the 2026 RFP
16 evaluation as necessary to fill the 2026 capacity deficit .
17 The first bid resulted in the execution of a 200 MW
18 contract with Powerex for a capacity-based product and firm
19 energy contract effective June 2026, for which the Company
20 requested approval in Case No . IPC-E-24-12 . The second bid
21 selected was a benchmark resource, the Idaho Power-owned 4-
22 hour battery storage facility providing up to 150 MW of
23 operating capacity, and the resource the Company is
24 requesting the Commission grant a CPCN in this proceeding.
25 Idaho Power is currently negotiating agreements for a third
ELLSWORTH, DI 24
Idaho Power Company

1 project submittal resulting from the 2026 RFP, a 200 MW
2 solar photovoltaic ("PV") plus a 100 MW 4-hour battery
3 storage project and will present those agreements to the
4 Commission for approval once executed.
5 Q. How do the combined Powerex market purchase
6 and the Company-owned battery storage facility providing up
7 to 150 MW of operating capacity impact the 236 MW capacity
8 deficiency?
9 A. The combined projects are estimated to reduce
10 the 2026 deficit an additional 116 MW. As explained in Case
11 No . IPC-E-24-12, in 2026, the Powerex market purchase
12 reduces the capacity deficiency from 236 MW to
13 approximately 186 MW - a 50 MW reduction. In the 2021 and
14 2023 IRPs, the Company had already assumed that
15 transmission capacity between the Pacific Northwest and
16 Idaho was resource equivalent capacity. Therefore,
17 utilizing that same transmission capacity to import the
18 Powerex 200 MW market purchase results in no incremental
19 resource capacity gain, although it does begin to fulfill
20 the Company' s energy import needs as described in the 2026
21 RFP and earlier in my testimony. The Company was able to
22 acquire 50 MW of incremental transmission, for one year
23 through Montana, in 2026 and therefore the Powerex market
24 purchase provides for 50 MW of capacity in 2026 . Once B2H
25 is completed, the Powerex contract will be treated as 200
ELLSWORTH, DI 25
Idaho Power Company

1 MW of fully incremental capacity. The Idaho Power-owned
2 battery storage facility will further reduce the 2026
3 capacity deficit approximately 66 MW.
4 Q. Why does a battery storage facility that
5 provides 150 MW of operating capacity only reduce the
6 deficit 66 MW?
7 A. When solar photovoltaic ("PV") and energy
8 storage are added together with similar ratios, the ELCC of
9 the combined resource is higher than the ELCC of the stand-
10 alone solar PV or energy storage . When solar PV and battery
11 storage additions become unbalanced via large additions of
12 one and not the other, the result is a lower ELCC for the
13 resource that was added, and a higher ELCC for the resource
14 that was not added. This is occurring in 2026 given the
15 large quantity of battery storage the Company is adding in
16 2025, and now further adding to this storage in 2026,
17 resulting in a lower ELCC for energy storage facilities .
18 However, this lower ELCC is just a year-2026,
19 snapshot in time issue . In addition to the 200 MW solar PV
20 plus 100 MW energy storage project as a cost-effective
21 resource addition in 2026, which the Company will present
22 to the Commission in a future filing once the agreements
23 are executed, Idaho Power is forecasting the addition of
24 approximately 525 MW of solar PV, spread through late-2026
25 and 2028, associated with a large load customer. The
ELLSWORTH, DI 26
Idaho Power Company

1 addition of this stand-alone solar will increase the
2 capacity contribution of the energy storage to the
3 portfolio in those years . Thus, while the procurement of a
4 higher amount of storage to meet 2026 needs may reduce its
5 ELCC (all the procurement is necessary for reliability
6 purposes) , it sets the Company up well to accept planned
7 stand-alone solar additions to the system in the future .
8 Q. Do you believe there is sufficient support for
9 the procurement of the Idaho Power-owned battery storage
10 facility providing up to 150 MW of operating capacity?
11 A. Yes, I do. The resource acquisitions were
12 pursued and procured as a least cost/least risk method of
13 meeting the capacity deficits first identified in the
14 Company' s 2021 IRP, again in the 2023 IRP, and subsequently
15 with the results of system reliability evaluation. The
16 fluidity of the capacity deficit period and continued high
17 load growth further supports these resource procurements
18 which combined are necessary to adequately address 2026
19 capacity deficits .
20 IV. CONCLUSION
21 Q. Please summarize your testimony.
22 A. Idaho Power' s most recent system reliability
23 evaluation has identified a capacity deficiency of 236 MW
24 in 2026 . In response to this resource need, the Company has
25 executed a 200 MW capacity-based product and firm energy
ELLSWORTH, DI 27
Idaho Power Company

1 contract, 12 and identified an Idaho Power-owned battery
2 storage providing 150 MW of operating capacity, for which
3 Idaho Power is requesting the Commission grant a CPCN at
4 this time .
5 Q. Does this complete your testimony?
6 A. Yes, it does .
12 See Case No . IPC-E-24-12 .
ELLSWORTH, DI 28
Idaho Power Company

1 DECLARATION OF JARED L. ELLSWORTH
2 I, Jared L. Ellsworth, declare under penalty of
3 perjury under the laws of the state of Idaho :
4 1 . My name is Jared L. Ellsworth. I am employed
5 by Idaho Power Company as the Transmission, Distribution &
6 Resource Planning Director for the Planning, Engineering &
7 Construction Department .
8 2 . On behalf of Idaho Power, I present this
9 pre-filed direct testimony in this matter.
10 3 . To the best of my knowledge, my pre-filed
11 direct testimony is true and accurate .
12 I hereby declare that the above statement is true to
13 the best of my knowledge and belief, and that I understand
14 it is made for use as evidence before the Idaho Public
15 Utilities Commission and is subject to penalty for perjury.
16 SIGNED this 3rd day of April 2024, at Boise, Idaho .
17 �✓
18 Signed:
19
ELLSWORTH, DI 29
Idaho Power Company