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Home My WebLink About20240709IPC to Staff Supplemental No. 2.pdf 0-10RHO POWER. RECEIVED DONOVAN WALKER Tuesday, July 9, 2024 Lead Counsel IDAHO PUBLIC dwalker(a)idahopower.com UTILITIES COMMISSION July 9, 2024 VIA ELECTRONIC FILING Commission 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-24-18 In the Matter of Idaho Power Company's Application for Approval of a Clean Energy Your Way Construction Agreement with the City of Boise and the First Amendment Thereto Dear Commission Secretary: Attached for electronic filing please find Idaho Power Company's Supplemental Response to the First Production Request of the Commission Staff in the above matter. Please feel free to contact me directly with any questions you might have about this filing. Very truly yours, 'ZI-o-, Z�. &)&a, Donovan E. Walker DEW:sg Attachments 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-24-18 APPROVAL OF A CLEAN ENERGY YOUR ) WAY CONSTRUCTION AGREEMENT ) IDAHO POWER COMPANY'S WITH THE CITY OF BOISE AND THE ) SUPPLEMENTAL RESPONSE FIRST AMENDMENT THERETO. ) TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Commission Staff ("Commission" or "Staff") dated May 13, 2024, herewith supplements the following information: IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 1 STAFF REQUEST FOR PRODUCTION NO. 2: Please explain if any part of Micron's Special Contract, the Schedule 26 tariff, or both need to be modified if the proposed CEYW Renewable Construction Agreement with the City of Boise and the First Amendment are approved. If any modification is required, please explain the modification required and the process the Company plans to submit the modification to the Commission. IDAHO POWER'S SUPPLEMENTAL RESPONSE TO STAFF'S REQUEST FOR PRODUCTION NO. 2: After submitting Response to Staff's Request for Production No. 2, the Company identified a modification to Schedule 26 that would provide better clarity regarding the Renewable Capacity Credit calculation. The currently approved tariff Sheet No. 26-2 includes "Table 1: Renewable Capacity Credit" and "Table 2: Monthly Unadjusted Renewable Capacity Credit by Month." Both tables calculate the total credit for the total renewable resource project. The intent was that this value would be adjusted to account for Micron and the City of Boise's share ("Buyer's Share"). However, this is not explicitly stated in the existing Schedule 26. Per informal conversations with Staff, the Company proposes to address this through a compliance filing following a final Commission order to clearly define the Renewable Capacity Credit for (1) the total project and (2) Micron's share of the Project Output. Please see the file labeled "Attachment — Supplemental Response to Request No. 2" for the proposed modifications to Schedule 26. In addition to the modification to Schedule 26, the Company would intend to execute a revised pricing exhibit in the City of Boise's Renewable Power Purchase Agreement to align the Renewable Capacity Credit tables and to reflect the Buyer's Share IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 2 of 25 percent of the total project output in the same manner as the attached proposed modifications to Schedule 26. After receiving a final Commission order, the Company plans to execute a revised pricing exhibit with the City of Boise. The response to this Request is sponsored by Alison Williams, Regulatory Policy and Strategy Leader, Idaho Power Company. IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 3 Respectfully submitted this 9th day of July 2024. DONOVAN WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF -4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 9th day of July 2024, 1 served a true and correct copy of the within and foregoing IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Adam Triplett 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 Adam.TriPIett(a)puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Holland & Hart LLP FTP Site 555 17t" Street, Suite 3200 X Email darueschhoff(@hollandhart.com Denver, CO 80202 tnelson(a)hol land hart.com awmensen(@,hollandhart.com Jim Swier Hand Delivered Micron Technology, Inc. U.S. Mail 8000 South Federal Way Overnight Mail Boise, ID 83707 FAX FTP Site X Email iswier(a�micron.com City of Boise Hand Delivered Ed Jewell U.S. Mail Deputy City Attorney Overnight Mail Boise City Attorney's Office FAX 150 N. Capitol Blvd. FTP Site P.O. Box 500 X Email Boise, Idaho 83701 BoiseCityAttorney_(a)cityofboise.org e0ewell(o-)-cityofboise.org IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 5 Steven Hubble Hand Delivered Climate Action Senior Manager U.S. Mail Boise City Dept. of Public Works Overnight Mail 150 N. Capitol Blvd. FAX P.O. Box 500 FTP Site Boise, Idaho 83701 X Email shubble(a�cityofboise.org Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF - 6 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-18 IDAHO POWER COMPANY SUPPLEMENTAL RESPONSE TO REQUEST NO. 2 ATTACHMENT NO. 1 Idaho Power Company First Revised Sheet No. 26-2 Cancels I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 26-2 SCHEDULE 26 IDAHO POWER COMPANY ELECTRIC SERVICE RATE FOR MICRON TECHNOLOGY, INC. BOISE, IDAHO SPECIAL CONTRACT DATED MARCH 9, 2022, AMENDED MAY 31, 2023 (Continued) RENEWABLE RESOURCE AGREEMENTS Calculation of the Monthly Unadjusted Renewable Capacity Credit for each Project is quantified in the tables below. The Monthly Adjusted Renewable Capacity Credit will be provided to Micron monthly, starting the month of the Project's Renewable Capacity Credit Eligibility Date (as defined in Table 3) or the month following the respective Project's commercial operation date, whichever is later, and will remain in effect for the duration of the term of the Renewable Resource PPA or the period of time during which the Idaho Power-owned Renewable Resource will provide Project Output to Micron, as applicable. The Monthly Adjusted Renewable Capacity Credit will be provided in accordance with Revised Exhibit 1 of Micron's Special Contract, dated March 9, 2022, as amended. TABLE 1: RENEWABLE CAPACITY CREDIT a b c d e f h Project Most Recently Project Capacity Renewable Renewable RCC Annual Micron's Micron's Acknowledged Nameplate Contribution Capacity Capacity Adjustment RCC Project Annual IRP (kW AC) Factor Contribution Credit (c*d*e) Output RCC*' (a*b) (RCC) Rate Share (f*g) $/kW- r Black 2019 40,000 0.3642 14,568 $121.19 1.0 $1,765,495.91 0.75 $1,324,121.94 Mesa Energy LLC *Table 2 denotes the Monthly Unadjusted Renewable Capacity Credit. 'Table 3 denotes each project's date of eligibility for the Annual Renewable Capacity Credit. TABLE 2: MONTHLY UNADJUSTED RENEWABLE CAPACITY CREDIT BY MONTH Jan Feb June July Aug Sept Oct Nov Dec Black $69,517 $69,517 $231,721 $463,442 $231,721 $59,585 $59,585 $69,517 $69,517 Mesa Energy LLC1 TABLE 3: ELIGIBILITY DATE FOR RENEWABLE CAPACITY CREDIT Project PPA Execution Date Capacity Deficiency Year Renewable Capacity Credit Eligibility Date Black Mesa 2/16/2022 2026 7/1/2026 Energy LLC Amounts to be adjusted by the Performance Ratio Adjustment Factor,which is calculated pursuant to the methodology detailed in Case No. IPC-E-22-06,Attachment 1 to Idaho Power Company's Compliance Filing dated December 23, 2022, as approved in Order No. 35735(Apr. 12, 2023), to determine the Monthly Adjusted Renewable Capacity Credit.Amounts shown are for Micron's assigned Project Output of 30 MW and will be adjusted for each month that Micron's assigned Project Output is greater than 30 MW. IDAHO Issued by IDAHO POWER COMPANY Issued — Timothy E. Tatum, Vice President, Regulatory Affairs Effective — 1221 West Idaho Street, Boise, Idaho Idaho Power Company 9r+giRaLFirst Revised Sheet No. 26-2 Cancels I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 26-2 SCHEDULE 26 IDAHO POWER COMPANY ELECTRIC SERVICE RATE FOR MICRON TECHNOLOGY, INC. BOISE, IDAHO SPECIAL CONTRACT DATED MARCH 9, 2022, AMENDED MAY 31, 2023 (Continued) RENEWABLE RESOURCE AGREEMENTS Calculation of the Monthly Unadjusted Renewable Capacity Credit for each Project is quantified in the tables below. The Monthly Adjusted Renewable Capacity Credit will be provided to Micron monthly, starting the month of the Project's Renewable Capacity Credit Eligibility Date (as defined in Table 3) or the month following the respective Project's commercial operation date, whichever is later, and will remain in effect for the duration of the term of the Renewable Resource PPA or the period of time during which the Idaho Power-owned Renewable Resource will provide Project Output to Micron, as applicable. The Monthly Adjusted Renewable Capacity Credit will be provided in accordance with Revised Exhibit 1 of Micron's Special Contract, dated March 9, 2022, as amended. TABLE 1: RENEWABLE CAPACITY CREDIT a b c d e f h Project Most Recently Project Capacity Renewable Renewable Renewable Annual Micron's Micron's Acknowledged Nameplate Contribution Capacity Capacity Sapaeity Renewable Project Annual IRP (kW AC) Factor Contribution Credit SreditRCC Gapaeity Out ut RCC*' (a*b) R( CC) Rate Adjustment GreditRCC Share (f*g) $/kW- r c*d*e Black 2019 40,000 0.3642 14,568 $121.19 1.0 $1,765,495.91 0.75 $1,324,121.94 Mesa Energy LLC *Table 2 denotes the Monthly Unadjusted Renewable Capacity Credit. 'Table 3 denotes each project's date of eligibility for the Annual Renewable Capacity Credit. TABLE 2: MONTHLY UNADJUSTED RENEWABLE CAPACITY CREDIT BY MONTH Jan Feb June July Aug Sept Oct Nov Dec Black $69,517 $69,517 $231,721 $463,442 $308,962 $79,447 $59,585 $69,517 $69,517 Mesa 92,689 92,689 308,962 617,924 231,721 59,585 79,447 92,689 92,699 Energy LLC1 TABLE 3: ELIGIBILITY DATE FOR RENEWABLE CAPACITY CREDIT Project PPA Execution Date Capacity Deficiency Year Renewable Capacity Credit Eligibility Date Black Mesa 2/16/2022 2026 7/1/2026 Energy LLC Amounts to be adjusted by the Performance Ratio Adjustment Factor,which is calculated pursuant to the methodology detailed in Case No. IPC-E-22-06,Attachment 1 to Idaho Power Company's Compliance Filing dated December 23, 2022, as approved in Order No. 35735(Apr. 12, 2023),to determine the Monthly Adjusted Renewable Capacity Credit.Amounts shown are for Micron's assigned Project Output of 30 MW and will be adjusted for each month that Micron's assigned Project Output is greater than 30 MW. IDAHO Issued by IDAHO POWER COMPANY Issued_�er�rr KIE)�6042= Timothy E. Tatum, Vice President, Regulatory Affairs Effective— aR ar„ 1, 2024 1221 West Idaho Street, Boise, Idaho