20240716IPC to Staff 23-27.pdf

0IQAW POWER.
DONOVAN WALKER
Lead Counsel RECEIVED
dwalker(Mclahopower.com Tuesday, July 16, 2024
IDAHO PUBLIC
July 16, 2024 UTILITIES COMMISSION
VIA ELECTRONIC FILING
Monica Barrios-Sanchez, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-24-16
In the Matter of Idaho Power Company's Application for a Certificate of
Public Convenience and Necessity for the Boise Bench Battery Storage
Facility
Dear Ms. Barrios-Sanchez:
Attached for electronic filing please find Idaho Power Company's Response to the
Confidential Third Production Request of the Commission Staff to Idaho Power Company.
The confidential version will be sent separately to the 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
Attachment

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Application for a Certificate of Public Convenience and Necessity for the Boise
Bench Battery Storage Facility
IPC-E-24-16
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that Idaho Power Company's Response to the Third Production Request of the
Commission Staff to Idaho Power Company, contains information that Idaho Power
Company and a third party claim is 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 16' day of July 2024.
Donovan Walker
Counsel for Idaho Power Company

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker(o-)idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A ) CASE NO. IPC-E-24-16
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR THE BOISE ) IDAHO POWER COMPANY'S
BENCH BATTERY STORAGE FACILITY. ) RESPONSE TO THE
CONFIDENTIAL THIRD
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Third Production Request of the Commission Staff ("Commission" or
"Staff") dated June 25, 2024, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 1

REQUEST FOR PRODUCTION NO. 23: In the Company's response to Production
Request No. 1 — Confidential Attachment 3, the Bid describes that there are 3 Capacity
Augmentations Estimates for this project:
Please explain if the estimated costs
of each augmentation are included in the Company's final cost estimate. If not, please
explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: Because the
degradation of the Battery Energy Storage System ("BESS") is variable, rather than utilize
the specific estimated dollars pursuant to the augmentation schedule in the bid, the Idaho
Power Evaluation Team applied a consistent annual operations and maintenance
("O&W) cost to all ownership bids to account for augmentation. This estimated cost adder
was $1.10/kilowatt-month or approximately $2 million per year, or $40 million, for a 150
megawatt (WW") project. The Request for Proposal ("RFP") requested that BESS
projects submit bids that would sustain nameplate capacity through the end of year two
of system operations assuming 365 cycles per year. Bidders that did not comply with this
requirement were requested to update bids to ensure all bids were evaluated equivalently.
Augmentation can generally be accomplished in three ways. One is through the
addition of battery segments to the existing battery storage facility. Another option is to
enter into an augmentation agreement with a battery manufacturer where Idaho Power
would pay an annual fee and the manufacturer would add battery segments as needed.
The Company could also mitigate battery degradation by adding batteries on the system
in different locations. The amount of augmentation and the time in which augmentation is
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY-2

needed depends on utilization of the system and duration of time. Adding battery
segments at the site or in another location on the system provides the most flexibility to
increase or decrease the amount of capacity to match system needs. Use of the O&M
cost adder in the bid evaluation process ensures each battery storage bid reflects
augmentation costs regardless of the method by which augmentation is ultimately
achieved.
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 CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 3

REQUEST FOR PRODUCTION NO. 24: The Company's response to Production
Request No. 1 — Confidential Attachment Nos. 3 and 7 refer to a
. Please provide documentation detailing this warranty:
a. Please specify how the _ allows for multiple charge discharge cycles in a
24-hour period.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: The Company does not
have specific warranty information beyond what was included in the Response to
Production Request No. 1 — Confidential Attachment Nos. 3 and 7 as the supplied
information was meant for cost quotation purposes. Warranty information is part of battery
supply contract negotiations and was not utilized in modeling of the submitted bids.
However, Idaho Power's experience is that warranty information is fairly consistent across
BESS suppliers and often includes warranty for workmanship, defects, or failures during
the warranty period. Some limited commercial warranty is typically provided as part of the
battery supply agreement for a specific time period at the beginning of the BESS
operational period. In the case of the submitted bid referenced, it was a standard five-
year warranty. A warranty can typically be extended for a price to be included in a long-
term service agreement if a purchaser chooses such services.
a. The warranty is in place to support the mechanical and electrical integrity of the
BESS components and is utilized to ensure components work as purchased from
the original equipment manufacturer. The charge/discharge cycles and limitations
are not a function of the warranty except for the potential to void a warranty if the
BESS is not operated within the technical specifications that are agreed (which is
where the cycles would be described).
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY-4

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 CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 5

REQUEST FOR PRODUCTION NO. 25: Based on the information provided in
Ellsworth's testimony on page 26, please provide justification, any necessary
documentation, and analysis showing the timeline when the Company projects to utilize
the full effective BESS capacity of 150 MW.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25: Idaho Power will utilize
all operating capacity of the BESS on the first day of operation, if needed. As explained
in the Company's Response to Request for Production No. 11, the Boise Bench BESS
will generally be dispatched daily based on system conditions and needs, although there
may be times when the resource discharge is not needed as other resources are
generating and the system has sufficient resources to serve customer load, which can be
the situation for any of Idaho Power's generating units but does not mean the capacity is
not utilized. Page 26 of Mr. Ellsworth's testimony discusses how the Boise Bench BESS
aids in meeting the Company's 2026 capacity deficiency. As a standalone battery storage
resource, considering the Effective Load Carrying Capability of the Boise Bench BESS,
the project is estimated to reduce the capacity deficit in 2026 by 66 MW.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, and Jared Ellsworth, Transmission, Distribution and Resource
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 6

REQUEST FOR PRODUCTION NO. 26: The Company stated it did not include
the 200 MW large load inquiries in its most recent system reliability evaluation as identified
in 2023 IRP. Ellsworth at 18. Based on the information, please provide the following:
a. An explanation why the Company did not consider this large load scenario in its
assessment; and
b. An explanation of any potential impact on the projected 2026 deficit and system
reliability if the Company included the large load scenario in its analysis.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26:
a. The 2023 Integrated Resource Plan ("IRP") Additional 200 MW Large Load
scenario was developed for informational purposes given the recent level of
inquiries to connect to the Idaho Power system. However, unless there are
contractual commitments and/or agreements established between the Company
and the large load customer, the large load inquiry will not be included in the
Company's base assumptions, which is why the 200 MW Large Load was modeled
as a scenario and not a main case in the 2023 IRP. For resource acquisition
purposes and system reliability evaluation, the Company currently utilizes base
case assumptions.
b. The 2023 IRP Additional 200 MW Large Load scenario considers a high load factor
industrial load, meaning the impact of an additional large load on the projected
2026 deficit would be a one to one with the capacity position of the Company,
dependent on the load ramp.
The response to this Request is sponsored by Andres Valdepena Delgado, System
Consulting Engineer, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 7

REQUEST FOR PRODUCTION NO. 27: Please provide the following information
regarding the BESS resource bids of the 2026 RFP:
a. A detailed final scorecard for the top 10 BESS resource bids (out of 21 BESS bids
that the Company received. Hackett at 27); and
b. A detailed cost-benefit and risk analysis on why the 150 MW Boise Bench BESS
resource was selected compared to the other shortlisted BESS bids.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27:
a. Please note, the 21 standalone BESS projects noted in the Direct Testimony of
Mr. Hackett, page 27 included both 2026 and 2027 bid submittals evaluated as
part of the Initial Shortlist ("ISL"). The final scorecard for the top 10 BESS resources
bid into the RFP can be found in Figure 14 of London Economics International
LLC's Closing Report 2026 All Source Request for Proposals for Peak Capacity
and Energy Resources ("Closing Report") provided as Confidential Exhibit No. 8.
Note, to aid in the identification of the top 10 BESS resource bids, the Company
has provided the project numbers below:
2026 Projects
Project Number
AYP145BEBS15026
ECO201 BEAP20027
IPC75BEAP10026
IPC76BEAP15026
ECO200BEBS20027
AYP144BEBS5026
2027 Projects
Project Number
MIS126BEBS20027
CLE154BEBS24027
MIS127BEAP20027
NEX157BEBS10027
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 8

b. The ISL and Final Shortlist ("FSL") evaluation process is documented in the
Closing Report, included as Confidential Exhibit No. 8 and includes the evaluation
process and resulting bids that make up both the ISL and the FSL including criteria
and results. The Closing Report outlines, among other things, how the FSL was
created, and how bids were ultimately ranked on the FSL by year. The ranked FSL
by year was included as Confidential Exhibit No. 7. Together, these exhibits
illustrate the Boise Bench BESS was a high ranked project on the 2026 FSL and
was the highest ranked (and only) standalone BESS bid on the 2026 FSL.
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 CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 9

DATED at Boise, Idaho this 16t" day of July 2024.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 10

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16t" day of July, 2024, 1 served a true and correct
copy of Idaho Power Company's Response to the Confidential Third 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
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
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Austin W. Jensen FAX
Holland & Hart LLP X Email darueschhoff(a�hol land ha rt.corn
555 17th Street, Suite 3200 tnelson(a)hol land hart.com
Denver, CO 80202 awjensen hollandhart.com
aclee(a)hol land hart.com
mamcmiIlen(a-).hol land hart.com
Micron Technology, Inc. Hand Delivered
Jim Swier U.S. Mail
8000 S. Federal Way Overnight Mail
Boise, ID 83707 FAX
X Email jswier micron.com
Clean Energy Opportunities for Idaho Hand Delivered
Kelsey Jae U.S. Mail
Law for Conscious Leadership Overnight Mail
920 N. Clover Dr. FAX
Boise, ID 83703 X EMAIL Kelsey(a-)-kelseyiae.com
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 11

Courtney White Hand Delivered
Mike Heckler U.S. Mail
Clean Energy Opportunities for Idaho Inc. Overnight Mail
3778 Plantation River Dr., Suite 102 FAX
Boise, Idaho 83703 X EMAIL
Courtney(a)cleanenergyopportunities.com
mike _cleanenergyopportunities.com
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 12