20240508Staff 1-10 to IPC.pdf

RECEIVED
Wednesday, May 8, 2024 1:23PM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0314
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
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 ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY,MAY 29, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 MAY 8, 2024

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please provide the Company's final proposal of the Boise Bench
Battery Energy Storage System ("BESS") for the 2026 RFP. Please include a description of
construction or expansion, a map of the project, construction timelines, cost estimates, and
impact on revenue requirements. Please answer the following:
a. Please explain when the Company obtained the final cost estimate for the BESS
project;
b. Did the Company include inflation in the final cost estimate? If so,please provide the
escalation factor which was used;
c. Please provide the final configuration and pricing of the BESS project that the
Company used for the AURORA modeling assessment; and
d. Please explain if the Company's proposal is based on a specific battery supplier. If
so, please explain who the battery supplier will be.
REQUEST NO. 2: Please answer the following regarding battery degradation:
a. Please explain what the expected annual battery degradation of the Boise Bench
BESS project is and provide any supporting documentation;
b. Please provide a table of the expected capacity contribution in MW for the Boise
Bench BESS for each year across the life of the batteries; and
c. Please explain if the Company will overbuild the Boise Bench BESS to maintain 150
MW of operating capacity.
i. If so,please explain by how much the Company will overbuild and the cost
estimate; and
ii. If so,please explain if the cost of overbuilding was included in the Company's
total cost estimate in its final proposal for the 2026 RFP.
REQUEST NO. 3: Please provide estimates for the round-trip efficiency across the life
of the system along with supporting documentation. Additionally,please explain how the
Company is modeling and factoring in round-trip efficiency for the Boise Bench BESS.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 MAY 8, 2024

REQUEST NO. 4: Please provide an updated total cost estimate for the development
and construction of the Boise Bench BESS project, similar to the table contained in Response to
Production Request No. 11 in Case IPC-E-23-20.
REQUEST NO. 5: Page 46 of Hackett's Direct Testimony states that"the Company will
initiate a purchase order with a battery supplier and enter into a contract specific to the delivery
and contract price of the BESS. Upon notification of selection by the Evaluation Team
following approval by the OPUC of the final shortlist, the Company's Power Supply department
began discussions with suppliers for procurement of the BESS but has not yet executed a
purchase order." Please respond to the following:
a. Has the Company executed any contract to purchase the 150 MW BESS from a
supplier?
b. If so,please provide a copy of the contract; or
c. If not, when does the Company plan to execute the contract?
REQUEST NO. 6: In Hackett's Testimony, he stated, "Idaho Power will enter into a
Long-Term Services Agreement for [operational and maintenance costs ("O&M")] services
performed for the energy storage project following commercial operation of the project."
Hackett at 47. Please explain if the estimated cost of this contract was included in the
Company's final proposal of the Boise Bench BESS.
a. If the Company has an executed Long-Term Services Agreement,please provide the
Agreement; and
b. Please provide the estimated cost of the Long-Term Services Agreement.
REQUEST NO. 7: Please explain in detail how the Company models when to charge
the Boise Bench BESS. Additionally, please explain the following:
a. Please explain how the Company will initiate charging as part of operations;
b. Please explain in detail what energy sources will be used to charge the Boise Bench
BESS and how these resources are determined; and
c. Please describe how the energy sources will vary between seasons.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 MAY 8, 2024

REQUEST NO. 8: Please explain how the Company modeled Renewable Energy
Credits ("RECs"), Investment Tax Credits ("ITCs"), and Production Tax Credits ("PTCs") in
AURORA. Please provide the model input values for these credits. Please provide the
underlying data the Company relied on to determine those values.
REQUEST NO. 9: Several proposals for the 2026 RFP included Long-Duration Energy
Storage ("LDES"). Please provide an overview of the LDES technologies proposed, the range of
nominal storage capacities, and the range of discharge durations.
REQUEST NO. 10: Page 8 of Exhibit No. 6 shows an example of the 60 stochastic
iterations for various portfolios. Please provide the actual stochastic results for the portfolio
containing this BESS project and for the portfolios containing the other 2026 shortlist projects.
DATED at Boise, Idaho, this 8th day of May 2024.
JJVI�A� J"
11
t0 Chris Burdin
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\IPC-E-24-16 PR#I.docx
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 4 MAY 8, 2024

CERTIFICATE OF SERVICE
rZDAY
I HEREBY CERTIFY THAT I HAVE THIS OF MAY 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-24-16, BY E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER TIM TATUM
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: dwalkerRmidahopower.com E-MAIL: ttatum(a),idahopower.com
dockets(@,idaligpower.com
PATRICIA JORDA , S CRETARY
CERTIFICATE OF SERVICE