The URL can be used to link to this page

Home My WebLink About20240802IPC to Staff 28-31 - Redacted.pdf 0IQAW POWER. RECEIVED DONOVAN WALKER Friday, August 2, 2024 Lead Counsel dwalker(a�id m ahopower.co IDAHO PUBLIC UTILITIES COMMISSION August 2, 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-24-16 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 Fourth 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 Fourth 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 2nd day of August 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 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 FOURTH 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 Fourth Production Request of the Commission Staff ("Commission" or"Staff") dated July 23, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 1 REQUEST FOR PRODUCTION NO. 28: In the Company's response to Production Request No. 10 - Confidential Attachment, Final Short List Portfolio Nos. 10 and 1 are ranked as the top two least cost portfolios; however, neither include the 150 MW Boise Bench BESS project. Please explain the following: a. Please explain why the Company is not pursuing the resources identified in final shortlist Portfolio No. 10; and b. Please explain why the Company is not pursuing the resources identified in final shortlist Portfolio No. 1; and c. Please discuss whether each of the 11 portfolios was run through RCAT and met the 0.1 loss-of-load-event ("LOLE") threshold. RESPONSE TO REQUEST FOR PRODUCTION NO. 28: a. The Company continues to engage with the developers through contract negotiations of the remaining final shortlist projects that are able to deliver by the proposed commercial operation date in an effort to meet its procurement needs in 2026. During the course of contract negotiations, the Company monitors not only economic changes to a project, but the feasibility of the project to deliver by the proposed commercial operation date. One factor that heavily influences the feasibility of a project is acquiring the applicable permits. One project recently encountered a development hurdle related to their county permit, which was denied by the County Commission, thus eliminating the ability to rely on the 2026 commercial operation date. b. See part (a) above. IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 2 c. Each portfolio analyzed as part of the final shortlist sensitivity analysis was run through the RCAT and met the Loss of Load Expectation ("LOLE") threshold of 0.1 event-days per year in 2026. 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 FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 3 REQUEST FOR PRODUCTION NO. 29: Staff notes that in the Company's response to Production Request No. 10 - Confidential Attachment, none of the modeled portfolios contain all three of the selected resources as described in the Application. Please build two more portfolios, as described below, perform the same set of 60 stochastic runs for the two new portfolios, and provide an updated spreadsheet showing the new data alongside the previous runs. The projects described below correspond to the bid rankings provided in Hackett's Confidential Exhibit No. 7. a. Portfolio 12: The 2026 forced projects will be final shortlist Bid Nos. 1, 2, and 4. b. Portfolio 13: The 2026 forced projects will be final shortlist Bid Nos. 1, 2, and 5. c. Please confirm that Portfolio Nos. 12 and 13 meet the RCAT LOLE threshold. RESPONSE TO REQUEST FOR PRODUCTION NO. 29: Following a discussion with staff on July 30, 2024, it was determined the stochastic analysis that included Portfolios 1 through 11 detailed in the London Economics International LLC Closing Report: 2026 All Source Request for Proposals for Peak Capacity and Energy Resources,' ("Closing Report") included as Exhibit No. 8 to Mr. Hackett's testimony provided Staff the information needed, and no additional portfolio runs were required. The response to this Request is sponsored by Eric Hackett, Projects and Resource Development Director, Idaho Power Company. Page 52. IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY-4 REQUEST FOR PRODUCTION NO. 30: As a supplement to the Company's response to Production Request No. 20, please explain why Project No. was not selected as a resource, when its levelized cost of capacity ("LCOC") was lower than the Boise Bench BESS project. RESPONSE TO REQUEST FOR PRODUCTION NO. 30: The referenced project was not selected by AURORA's Long-Term Capacity Expansion modeling platform in any of the scenarios used to develop the final shortlist. The primary contributing factor is the project's constrained ability to deliver its energy/capacity on Idaho Power's transmission system given current Available Transmission Capacity ("ATC") constraints on some of the Company's transmission paths. One of the constrained paths is the Borah West transmission path, which the project will have to cross to deliver its energy to the Idaho Power load pocket. The limited ATC decreases its Effective Load Carrying Capability ("ELCC"). The Boise Bench project does not have to cross such a constrained transmission path, resulting in its ELCC being unaffected. This lower ELCC decreases this project's comparative benefit relative to other standalone BESS projects without similar ATC constraints. While a comparison of the LCOC of like projects provides a useful measure of relative cost, it does not indicate the economic value or overall feasibility of a project, as further evidenced by two Idaho Power BESS projects. Both the and BESS projects were analyzed as part of the scenario analysis performed to develop the preliminary 2026 final shortlist, with the lower LCOC. However, as described in the Closing Report, the BESS project was ultimately removed from final shortlist consideration due to the uncertainty on IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 5 overall interconnection costs triggered by its participation in the 360-day cluster study under FERC Order 2023. 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 FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 6 REQUEST FOR PRODUCTION NO. 31: Hackett's Confidential Exhibit No. 7 is the ranking of the Company's final shortlist of bids for the 2026 RFP. Please provide the following information: a. The LCOC of Bid No. 4 and Bid No. 5; and b. The breakdown of estimated total capital cost for Bid No. 4 and Bid No. 5. RESPONSE TO REQUEST FOR PRODUCTION NO. 31: a. Please see below levelized cost of capacity ("LCOC")for Projects 4 and 5 identified on Confidential Exhibit No. 7, the final shortlist. It is important to note that Project 4 is a combined solar and BESS project which is a different product type than a standalone BESS product and therefore not comparable on a LCOC basis. Product In-Service Total Capital Cost Sum of LCOC Master Project Tvpe Date MW (Inc.AFUDC) ($/kW/Month) Sum of LCOE($/mwh) BESS 6/1/2026 100 N/A N/A Solar 6/1/2026 100 N/A _ BESS 6/1/2026 150 N/A b. Project 4 is a combined Power Purchase Agreement and Battery Supply Agreement project, owned and operated by a third party, therefore Idaho Power does not have a capital cost associated with this project. For Project 5, see the Company's Response to Request for Production No. 4. The response to this Request is sponsored by John Wonderlich, Finance Team Leader, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 7 DATED at Boise, Idaho this 2nd day of August 2024. DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 2nd day of August, 2024, 1 served a true and correct copy of Idaho Power Company's Response to the Confidential Fourth 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 FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 9 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(c)cleanenergyopportunities.com mike(a�_cleanenergyopportunities.com Stacy Gust, Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE CONFIDENTIAL FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY- 10