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HomeMy WebLinkAbout20240514IPC 1-19 Redacted to Staff.pdf 0IQAW POWER. DONOVAN WALKER RECEIVED Lead Counsel 2024 May 14, 1:47PM dwalker(Mclahopower.com IDAHO PUBLIC UTILITIES COMMISSION May 14, 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-24-12 In the Matter of Idaho Power Company's Application for Approval of a Market Purchase Agreement Dear Ms. Barrios-Sanchez: Attached for electronic filing please find Idaho Power Company's Redacted Response to the Confidential First Production Request of the Commission Staff in the above matter. The confidential response and attachment 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 Approval of a Market Purchase Agreement IPC-E-24-12 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that the attachment in response to Request No. 16 to Idaho Power Company's Response to Staff's First Production Request of the Commission Staff to Idaho Power Company, dated May 14, 2024 contains 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 14th day of May 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: (208) 388-5317 Facsimile: (208) 388-6936 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 ) CASE NO. IPC-E-24-12 APPROVAL OF A MARKET PURCHASE ) AGREEMENT. ) IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Confidential First Production Request of the Commission Staff ("Commission" or"Staff") dated April 23, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 1 REQUEST FOR PRODUCTION NO. 1: Please provide supporting workpapers of the load and resource balance that details the 236 MW deficit in 2026 as mentioned in Company Witness Ellsworth's Testimony at 14. If not included, please include the expected capacity of contracted projects through 2025. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: As described in the Direct Testimony of Mr. Ellsworth, the load and resource balance has been replaced by the Loss of Load Expectation ("LOLE") derived annual capacity position analysis. Idaho Power's internally developed Reliability & Capacity Assessment Tool ("RCAT") requires various load and resource inputs to apply the LOLE methodology. The Company's Response to Request for Production No. 1 — Attachment includes the following data that was utilized in determining the 236 megawatt ("MW") deficit: • Input: historical hourly load shaped to the monthly peak 70' percentile, September 19, 2023, load forecast • Input: flexible resource monthly capacity and corresponding Equivalent Forced Outage Rate during Demand ("EFORd") • Input: variable and energy limited resource cumulative nameplate by year • Input: historical hourly run of river hydro • Input: historical hourly cogeneration and small power production • Output: resulting capacity position values by test year The response to this Request is sponsored by Jared Ellsworth, Transmission, Distribution and Resource Planning Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 2 REQUEST FOR PRODUCTION NO. 2: Please explain how the Company modeled the Oxbow Hydro maintenance in 2026 in the recent capacity update, including the expected MWs that will be expected to be reduced as a result. Ellsworth at 17. Additionally, please explain when the Company expects the Oxbow Hydro maintenance to be completed. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The four Oxbow units are modeled in the RCAT with monthly capacity values and associated EFORd values. As can be seen in row 16 of the tab labeled Resources — Flexible of the Company's Response to Request for Production No. 1 — Attachment, the start of the Oxbow maintenance occurs in September 2026. Unit capacity was reduced instead of zeroed for maintenance to acknowledge that the other three operational Oxbow units could output more during the Company's highest-risk hours. Utilizing the 236 MW capacity deficit referenced in the Company's Response to Request for Production No. 1, if the Oxbow maintenance was removed, the resulting capacity position from the RCAT would be a 235 MW deficit, which implies the Oxbow maintenance impacts the 2026 annual capacity position by 1 MW, primarily because the outage starts after the summer, and for 2026, the summer season includes the vast majority of risk hours. For modeling purposes in the RCAT, the Company assumes the first Oxbow unit maintenance will conclude in August 2027. The remaining Oxbow unit maintenances are assumed to follow suit, each with a 12-month outage, concluding in August 2030. The response to this Request is sponsored by Jared Ellsworth, Transmission, Distribution and Resource Planning Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 3 REQUEST FOR PRODUCTION NO. 3: Please explain why the Agreement does Confidential Exhibit No. 9 at 1. In the response, please specify who will own the for each transaction i.e., Seller or Purchaser. ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: As described more fully in the Direct Testimony of Eric Hackett, this Agreement is the result of the Seller bidding certain proposals into the 2026 Request For Proposals ("RFP"). All proposals bid into the 2026 RFP went through several stages of a comprehensive bid evaluation process and the Seasonal RA Capacity five-year bid was selected as part of the final short-list as a least-cost, least-risk resource. This final short-list was comprehensively vetted by the Independent Evaluator and approved by the Oregon Public Utility Commission ("OPUC"), finding that Idaho Power had complied with the Oregon Competitive Bidding Rules, for which the Commission requires the Company follow as well.' Thus, the Seller's bid for that product was the starting point for the negotiations. In the interest of meeting the identified needs as economically as possible, the Company did not specifically seek Order No. 24-055. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY-4 The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 5 REQUEST FOR PRODUCTION NO. 4: Please explain why the term _ requires the Confidential Exhibit No. 9 at 2. ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 6 REQUEST FOR PRODUCTION NO. 5: In the event the Company elects to receive Firm Energy, please explain the requirement to have ` -". Confidential Exhibit No. 9 at 4. a. Additionally, please explain if the Company will have to ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 5: As context, and as described more fully in the Direct Testimony of Eric Hackett, this Agreement is the result of the Seller bidding certain proposals into the 2026 RFP. All proposals bid into the 2026 RFP went through several stages of a comprehensive bid evaluation process and the Seasonal RA Capacity five-year bid was selected as part of the final short-list as a least- cost, least-risk resource. This final short-list was comprehensively vetted by the Independent Evaluator and approved by the OPUC, finding that Idaho Power had complied with the Oregon Competitive Bidding Rules, for which the Commission requires the Company follow as well.' Thus, the Seller's bid for that product, was the starting point for the negotiations. 2 Order No. 24-055. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 7 The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 8 REQUEST FOR PRODUCTION NO. 6: The Company may request to increase capacity during the Fixed Term of for a total of_. Confidential Exhibit No. 9 at 4. Please answer the following: a. Please provide the total estimated costs of increasing capacity to b. If the Company increases to_, please explain how this will be the least cost resource in terms of the 2026 RFP shortlist; c. Please explain if the Company will need to renegotiate the Agreement if it chooses to increase the capacity to a total of_; d. Ellsworth stated in his testimony, "Once B2H is completed, the Powerex contract will be treated as 200 MW of fully incremental capacity." Ellsworth at 25. Please explain if the Company requests to increase to_ that contract will be treated as_ of fully incremental capacity; and e. If the Company increases the capacity to _ and B2H is not energized by June 1, 2026, please provide a table that details the alternative delivery points the Company will use during the Bridge Term. ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 6: a. b. Because the Seller's bid into the 2026 RFP was of the Seasonal RA Capacity Product, the was utilized in all bid evaluation modeling, IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 9 and the bid was selected as a least-cost, least-risk resource for inclusion on the final shortlist. As negotiations with the Seller commenced, the Seller indicated that circumstances had changed and it could offer of a Seasonal RA Capacity Product. c. If the opportunity arises to ' Idaho Power anticipates the parties would revise the agreement , however the Company does not anticipate other terms and conditions of the Agreement would need to be renegotiated. d. e. The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company, and Eric Hackett, Projects and Resource Development Director, Idaho Power Company. 3 As defined on page 1 of the Agreement, the Fixed Term is a fixed term commencing on the B2H Energization Reference Date and continuing through to, but excluding, the fifth anniversary of the B2H Energization Reference Date. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 10 REQUEST FOR PRODUCTION NO. 7: Section 12 in Confidential Exhibit No. 9 describes how the Company may Confidential Exhibit No. 9 at 16. Please explain the impacts of converting to this service and answer the following: a. If this option was chosen, please explain how that would impact this Agreement as a cost-effective resource; and b. If this option was chosen, please provide supporting workpapers that detail what the estimated expenses by year of both (a) Bridge Term and (b) Fixed Term. ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 7: a. b. The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company and Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 11 REQUEST FOR PRODUCTION NO. 8: Please provide workpapers that were used to determine the Fixed Capacity price. Confidential Exhibit No. 9 at 6. ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The Fixed Capacity price was determined by the Seller as part of their bid; it was not developed by Idaho Power. As described more fully in the Direct Testimony of Eric Hackett, this Agreement is the result of the Seller bidding certain proposals into the 2026 RFP. All proposals bid into the 2026 RFP went through several stages of a comprehensive bid evaluation process and the Seasonal RA Capacity five-year bid was selected as part of the final short-list as a least-cost, least-risk resource. This final short-list was comprehensively vetted by the Independent Evaluator and approved by the OPUC, finding that Idaho Power had complied with the Oregon Competitive Bidding Rules, for which the Commission requires the Company follow as well.4 Thus, the Seller's bid for that product, including the Fixed Capacity Price, was the basis for the negotiations of the Agreement. This is consistent with how Idaho Power approaches negotiations with any other resource ultimately selected through the bid evaluation process and included on the final short-list: the Seller's pricing that is bid into the RFP is comprehensively evaluated, and if selected for the final short-list, serves as the basis for negotiations. The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company. 4 Order No. 24-055. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 12 REQUEST FOR PRODUCTION NO. 9: Confidential Exhibit No. 9 Additional Provisions 3(a) at 9 states, ` Please explain how the Company will notify the Commission if this occurs. Additionally, please explain how changing the will impact the cost of this Agreement. ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 9: The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 13 REQUEST FOR PRODUCTION NO. 10: In Confidential Exhibit No. 9 - Additional Provisions 3(c)(i), it states, ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 10: e Fed. Energy Reg. Comm. Docket No. ER24-1658-000, https://elibrary.ferc.gov/eLibrary/filelist?accession number=20240329-5340&optimized=false 6 The Markets+ Tariff was submitted to FERC for approval on March 29, 2024. Id. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 14 The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 15 REQUEST FOR PRODUCTION NO. 11: The Agreement states ` " Confidential Exhibit No. 9 at 19. a. Additionally, please explain how Powerex will calculate the "amount". Please provide supporting workpapers; b. Please explain if this "amount" is different than ; and C. ** Note: In the response, please highlight confidential information. RESPONSE TO REQUEST FOR PRODUCTION NO. 11: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 16 The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 17 REQUEST FOR PRODUCTION NO. 12: As part of the Company's All-Source Request for Proposals ("UP"), the Company identified tables of eligible products. Table 3.2 identified "Gas-fired Convertible to Hydrogen (G2H)" as an eligible product. Please answer the following questions about this product: a. Please describe how this product would materially differ from a conventional gas- fired plant; b. Please explain the Company's reasons for requesting this product, but not a conventional gas-fired plant; c. Please provide examples of other utilities or energy companies that implemented this product; and d. Please provide the Company's cost estimate data regarding the extra costs that would be typical between this product and a conventional gas-fired plant. RESPONSE TO REQUEST FOR PRODUCTION NO. 12: a. A G2H product is modeled based on the submitted characteristics and does not differ from a traditional gas-fired product as the product request is that the facility is convertible but installed as a traditional gas-fired facility at the beginning of life. b. Idaho Power requested the ability for facilities to be convertible to plan for futures where there is a higher carbon cost or if the natural gas industry in general trends towards inclusion of hydrogen as a fuel. The ability for the equipment to convert to hydrogen fuel, in whole or in part, provides options for the Company's ongoing operation of a gas facility. c. Idaho Power is not aware of specific other companies' implementation of the G2H facilities. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 18 d. There are no additional costs applicable to a G2H product compared to traditional gas-fired facilities. Note, the proposals bid into the 2026 RFP went through several stages of a comprehensive bid evaluation process, including a quantitative evaluation of each bid proposal and financial analysis, that was comprehensively vetted by the Independent Evaluator and ultimately approved by the OPUC, confirming the validity of the proposals. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 19 REQUEST FOR PRODUCTION NO. 13: Please provide the following information from the Gas-fired Convertible to Hydrogen ("G2H") proposal submitted as part of the RFP: a. Please provide the proposed location of the resource and its natural gas supply plan; b. Please provide the proposed electrical interconnection or delivery path; c. Please provide the proposed nameplate capacity; d. Please provide the proposed price; and e. Please provide the proposed plan to provide convertibility to hydrogen. RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The bid had the following information that was not substantiated or confirmed by Idaho Power during the evaluation: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 20 e. The bid documents had the following information that was not substantiated or confirmed by Idaho Power during the evaluation: The Response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 21 REQUEST FOR PRODUCTION NO. 14: The RFP requested proposals that would alleviate capacity deficits in 2026 and 2027. Because the Company did not determine the final short list of competitive proposals until March of 2023, proposers will now have under three years to finish a 2026 project. a. Please list all potential resource types with typical acquisition lead times that exceed three years; b. Please provide the typical acquisition lead time for those resource types; and c. Please describe roadblocks and solutions the Company can pursue to enable longer lead-time projects. RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Idaho Power would like to clarify the premise of the question. As explained in detail in the testimony of Eric Hackett, Idaho Power followed the Oregon Competitive Bidding Rules and OPUC- established timeline, as directed by the Idaho Commission, throughout the entire RFP process. Following the schedule set forth by the OPUC, the Company issued the RFP in June 2023, evaluated bids throughout the fall of 2023, and the final shortlist of least-cost, least-risk projects was submitted for approval to the OPUC on December 12, 2023. As permitted under the Competitive Bidding Rules, Idaho Power immediately after that date began discussion and negotiations with resources on the final shortlist. The final shortlist was approved by the OPUC on February 22, 2024, with Order No. 24-055. Negotiations are proceeding with the various final shortlist projects. a. Idaho Power cannot speculate on all potential resource types with lead times that exceed three years but, based on proposals received as part of the 2026 RFP, can conclude that none of the projects on both the initial and final shortlist have typical IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 22 acquisition lead times that exceed three years, assuming prompt action is taken with respect to procurement of materials and supplies. That being said, challenges can arise with particular projects that may extend the construction timeline. Such challenges may include permitting, such as county use permits, or generation interconnection studies and facility construction. b. Based on Idaho Power's recent experience, solar and battery storage projects have been executed in approximately two years. The timelines can be variable based on various stages of development, permitting requirements, generation interconnection status, supply chain constraints, and similar unique project characteristics. The Company does not have any recent experience with wind projects but bid submittals suggest wind resource projects can be delivered in under three years. Idaho Power believes that most dispatchable resources, such as natural gas, hydro-electric, pumped storage, and geothermal are likely to take longer than three years to fully develop, permit, procure, and construct. c. The Company has been working for the past several years to try to contract with resources earlier in time and create a longer runway for resources to complete construction in advance of need. Idaho Power proposed schedules in Docket UM 2255, the OPUC's docket for the 2026 RFP under the Competitive Bidding Rules, to expedite the evaluation process as much as possible. Ultimately the final schedule adopted by the OPUC included additional time for reviews by stakeholders, OPUC staff, and the Independent Evaluator. The Company is IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 23 working now to initiate and, to the extent it can, expedite the next RFP for needs in 2028.' The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. Docket UM 2317. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 24 REQUEST FOR PRODUCTION NO. 15: Staff believes that the Company constructed Langley Gulch gas plant ("Langley")with the capability to expand its capacity. a. Please describe the capacity-expansion features currently in place at Langley; b. Please describe the requirements to expand the capacity of the plant, and the additional amount of capacity that could be reasonably achieved; and c. Please explain why the Company did not submit a Langley expansion project as a benchmark project. RESPONSE TO REQUEST FOR PRODUCTION NO. 15: a. Langley does not have immediate expansion capabilities. The site itself has physical space to develop some expansion of the facility; however, the majority of the infrastructure such as interconnection facilities, the water supply, and the gas supply line, have not been sized for expansion and may require additional investments to accommodate a capacity expansion at the site. b. The two primary limitations related to the expansion of the Langley Gulch facility are the air permit and generator interconnect limitations. To expand the permitted emission conditions, the air permit requires a multi-year application and review process through the Idaho Department of Environmental Quality ("DEQ"). Further, the generator interconnect expansion would need to be applied for through the Federal Energy Regulatory Commission-approved generator interconnection cluster study process, like any other resource addition considering locating in Idaho Power's service area. Upon approval of both multi-year processes, securing materials and construction can commence. The additional amount of capacity that IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 25 could be reasonably achieved at Langley is expected to be under 100 megawatts without significant enhancements to the permits and facilities. c. An expansion project at Langley was not submitted because of the time it would take to first develop an air permit application and seek Idaho DEQ approval, approximately two years, before then purchasing materials and constructing the project, which is anticipated to take at least two more years. Because of the anticipated approximately five-year timeline, an expansion of Langley would not have been capable of meeting the 2026 and 2027 in-service dates required in the Request for Proposals. The response to this Request is sponsored Ryan Adelman, Vice President of Power Supply, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 26 REQUEST FOR PRODUCTION NO. 16: Please provide the worksheets (with formulas enabled) determining the life-cycle calculations for the top three 2026 proposals. RESPONSE TO REQUEST FOR PRODUCTION NO. 16: Please see Response to Request for Production No. 16 - Confidential Attachment, which includes the annual portfolio cost output from the 2026 RFP final shortlist stochastic runs. Only the annual portfolio costs for each iteration are exported from the stochastic runs and used by Idaho Power, while the specific resource level detail by year and iteration are not. Note, in the stochastic runs, there is no `base' scenario; each stochastic iteration varies gas price, hydro conditions, load and carbon price uniquely. The unique variations of each stochastic iteration are the same across all of the individual portfolios analyzed. For more information on the stochastic analysis please see the 2023 IRP in the Stochastic Risk Analysis section of Chapter 10. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 27 REQUEST FOR PRODUCTION NO. 17: Please answer the following questions about AURORA modeling of the Powerex Market Purchase Agreement ("MPA"): a. Please describe how the Company modeled the MPA in Aurora; b. Please confirm that the model accounts for the cost of 16 hours of energy at the Day-Ahead Mid-C Peak Index price if a delivery order is placed; and c. Please provide an appropriate range of AURORA hourly data that shows an MPA delivery order being executed during a 2027 summer peak. RESPONSE TO REQUEST FOR PRODUCTION NO. 17: a. The Powerex Market Purchase Agreement will be imported on transmission rights Idaho Power has on third-party transmission systems. Thus, it was modeled in AURORA as import capability, similar to a transmission line that allows access to the Mid-Columbia ("Mid-C") market hub for purchases. To ensure that the model accurately evaluated the capacity value of the Powerex bid, the Company only treated the Market Purchase Agreement as incremental capacity to the extent it was being imported on transmission rights that were additional to what the Company held prior to 2026. The Company has obtained 50 MW of incremental transmission rights on Northwestern Energy's transmission system for 2026 and 2027, and assumed all of B2H is incremental once it comes in service. b. The model accounts for the energy cost of the Market Purchase Agreement at the AURORA internally derived Mid-C hub price, similar to how market purchase costs are accounted for in the Integrated Resource Plan ("IRP"). IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 28 c. The finest temporal granularity for portfolio outputs for the RFP (and IRP) analysis is a monthly level. As such, the following summarizes monthly Market Purchase Agreement-related portfolio outputs for the Powerex agreement for the year 2027: The response to this Request is sponsored by Jared Ellsworth, Transmission, Distribution and Resource Planning Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 29 REQUEST FOR PRODUCTION NO. 18: Please answer the following questions about AURORA modeling of Battery Energy Storage Systems ("BESS"): a. Please describe how the Company models BESS in AURORA; b. Please describe the factors that AURORA uses to determine how and when to recharge the BESS; c. Please clarify if the cost of BESS-recharging energy is accounted for in the portfolio; and d. Please provide appropriate AURORA hourly data from a run that shows a BESS resource discharging and recharging during a peak winter month. RESPONSE TO REQUEST FOR PRODUCTION NO. 18: a. The Company models BESS in AURORA for the RFP the same way it does in the IRP, a BESS has the ability to charge and discharge according to its nameplate MW, storage capacity (duration), and round-trip efficiency. b. BESS in AURORA (consistent with the IRP) is modeled as prioritizing net-demand hours for discharge. This means AURORA generally prioritizes charging the BESS at combined low demand and high renewable output hours of the day and discharging the BESS at high demand and low renewable output hours. c. Yes. The cost of BESS-recharging energy is accounted for in the portfolio. d. The finest temporal granularity for resource outputs for the RFP (and IRP) analysis is a monthly level. As such, the following summarizes monthly resource outputs for a BESS resource in the winter months for the 2026-2027 time period: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 30 The response to this Request is sponsored by Jared Ellsworth, Transmission, Distribution and Resource Planning Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 31 REQUEST FOR PRODUCTION NO. 19: Please describe any steps the Company is considering to shorten the next RFP timeline. RESPONSE TO REQUEST FOR PRODUCTION NO. 19: The Company expedited the timeline for the 2026 RFP as much as possible within the constraints and timeline of the Oregon Competitive Bidding Rules, which the Idaho Commission has directed Idaho Power to follow, and the timeline required by the OPUC regulatory process. Idaho Power is also actively working to expedite the next RFP (for needs in 2028). The Company filed a request$ with the OPUC seeking a waiver to use the same Independent Evaluator as the 2026 RFP and to allow the OPUC to consider Idaho Power's proposed bid scoring and modeling methodology concurrent with the draft 2028 RFP, shortening the RFP timeline from approximately 18 months to approximately 10 months. The OPUC approved the waiver requests on April 30, 2024, with Order No. 24- 120. In addition, the Company has provided a draft version of the 2028 RFP to the OPUC and held an early workshop for stakeholders. In June 2024, the Company intends to solicit competitive bids that are able to meet a spring 2028 commercial operation date and have a final short-list identified and filed with the OPUC by the end of 2024. Executing contracts in early 2025 will provide more than three years to develop and construct the resources. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. 8 Docket UM 2317. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 32 DATED at Boise, Idaho this 14t" day of May 2024. DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 33 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 14th day of May, 2024, 1 served a true and correct copy of Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power Company upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Chris.Burdin(cr puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Stacy Gust, Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 34 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-12 IDAHO POWER COMPANY REQUEST NO. 1 ATTACHMENT NO. 1 SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-12 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 16 ATTACHMENT NO. 1