20240906IPC to Staff 69-73.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

September 6, 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-24-07
Application of Idaho Power Company for Authority to Increase Rates for
Electric Service to Recover Costs Associated with Incremental Capital
Investments and Certain Ongoing Operations and Maintenance Expenses

Dear Commission Secretary:

Attached for electronic filing, please find Idaho Power Company’s Response to the
Tenth Production Request of the Commission Staff to Idaho Power Company.

Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.

The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site will be provided to the parties that execute the
Protective Agreement in this matter.

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,
Lisa D. Nordstrom

LDN:sg
Enclosures
' a1DA11> POWER .
RECEIVED
Friday, September 06, 2024
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

Case No. IPC-E-24-07

Idaho Power Company’s Application for Authority to Increase Rates for Electric
Service to Recover Costs Associated with Incremental Capital Investments and
Certain Ongoing Operations and Maintenance Expenses

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that some of the attachments to Request Nos. 69, 71, and 73 to Idaho Power
Company’s Response to the Tenth Production Request of the Commission Staff dated
September 6, 2024, contains information that Idaho Power Company and/or a third party
claim are trade secrets or business records of a private enterprise required by law to be
submitted to or inspected by a public agency as described in Idaho Code § 74-101, et
seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt
from public inspection, examination, or copying.

DATED this 6th day of September 2024.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
INCREASE RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS
ASSOCIATED WITH INCREMENTAL
CAPITAL INVESTMENTS AND
CERTAIN ONGOING OPERATIONS
AND MAINTENANCE EXPENSES.

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CASE NO. IPC-E-24-07

IDAHO POWER COMPANY’S
RESPONSE TO THE TENTH
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Tenth Production Request of the Commission Staff (“Commission” or
“Staff”) to Idaho Power Company dated August 16, 2024, herewith submits the following
information:
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 69: Please provide an excel spreadsheet
with formulas intact listing all buyer construction costs incurred to date for the Franklin
BESS project. This information should include date, amount, purpose, and payee.
RESPONSE TO REQUEST FOR PRODUCTION NO. 69: See the Response to
Request for Production No. 69 – Confidential Attachment 1 for all Franklin BESS project
charges incurred through July 31, 2024, including a description of the purpose of the
charge. Note, the costs exclude Allowance for Funds Used During Construction
(“AFUDC”) and overheads.
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 TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 70: Please provide a copy of the
Interconnection Agreement for the Franklin BESS project.
RESPONSE TO REQUEST FOR PRODUCTION NO. 70: Please see the
Response to Request for Production No. 70 – Attachments 1 through 3 for a copy of the
Large Generator Interconnection Agreement and subsequent amendments.
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 TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 71: Please provide the following for each of
the BESS projects listed in Larkin workpaper 3 – incremental plant determination at 11.
a. Please provide the AURORA long-term capacity expansion model results
showing the cost-effectiveness of the Company’s BESS resource compared to
the resource Staff used to establish the soft cap, as described in Hackett Direct
at 13.
b. Please provide the forecasted portfolio capacity positions for the life of each
project at time of the associated CPCN filing.
c. Please indicate if the system is stand-alone or if it is paired with a renewable
generation facility. For any system paired with renewable generation, please
explain if the BESS resource is connected in series or in parallel to the generation
facility.
d. Please provide the actual build capacity excluding any overbuild or augmentation.
e. Please provide any overbuild capacity, associated costs, and describe if the
overbuild costs were included in the resource bid.
f. Please provide a timeline showing planned augmentation, associated cost,
and the augmentation amount.
g. Please indicate the battery technology type, the associated maximum depth-of-
discharge specification, the amount of reserved capacity, the assumed degradation
for each year of plant life, the rated number of discharge cycles per year, and the
source for each of these metrics (i.e. Company assumption, manufacturer warranty,
etc.)
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 5
h. Please explain the effect that the additional overbuild capacity will have on
battery degradation and maximum dispatch time.
i. Please provide a total project cost breakdown showing total project budget, total
current spend, amounts already being recovered, ITC amounts received, and
total budget previously closed. Please separate these project costs by AFUDC,
overhead, and customer contribution categories.
RESPONSE TO REQUEST FOR PRODUCTION NO. 71:
a. As described in the Direct Testimony of Mr. Hackett in Case No. IPC-E-23-05,
for which the Commission granted a Certificate of Public Convenience and
Necessity (“CPCN”) for the 60 megawatt (“MW”) Franklin BESS, the bids
received in response to Idaho Power’s 2022 All Source Request for Proposals
(“RFP”) for Peak Capacity and Energy Resources issued on December 30,
2021 (“2022 RFP”) were evaluated through a qualitative and quantitative
evaluation and ranking process to ultimately determine the least-cost, least-risk
resource necessary to fill the 2024 capacity deficiency. The long-term capacity
expansion (“LTCE”) modeling was performed as part of the quantitative
evaluation process, identifying those projects that would move to the final
shortlist following the qualitative evaluation. Under the LTCE modeling
approach, the levelized cost of capacity (“LCOC”) of the 17 eligible projects were
input into AURORA as potential resource additions, along with their project
specific operating characteristics. The LTCE model optimized these potential
resource selections based on the performance of each resource within Idaho
Power’s zone, optimizing for the cost function while meeting the Company’s
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 6
identified capacity deficiency. The following presents the projects selected
through the indicative AURORA modeling scenarios as least-cost, least-risk
projects necessary for meeting the identified 2024 capacity deficiency:
Rank Resource
1 100 MW Solar + 100 MW BESS
2 100 MW Solar + 60 MW BESS
3 150 MW Standalone BESS
4 52 MW Standalone BESS
5 46 MW Standalone BESS

Note, following evaluation of the bids, it was revealed that the first ranked project
had deliverability concerns for meeting the June 2024 commercial operation
date and therefore did not move forward to the final shortlist. The most cost-
effective project able to meet the commercial operation date of June 1, 2024,
was the 100 MW solar photovoltaic (“PV”) facility combined with the 60 MW
BESS, which is the 60 MW Franklin BESS discussed on page 13 of Mr.
Hackett’s Direct Testimony in this proceeding.
Staff’s analysis of the final short list projects only captured the unit price
associated with the BESS, failing to account for the benefit associated with the
low Power Purchase Agreement (“PPA”) costs, and utilized the unit cost of the
fifth ranked project for the soft cap determination. However, as a resource
addition, AURORA continually selected the combined solar PV and battery
storage in the LTCE analysis, indicating the low solar PPA price is contributing
to the value the project provides as compared to the other final short list projects.
In addition to being a lower cost resource, when compared to standalone battery
storage systems, the combined solar PV plus energy storage better meets the
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 7
Company’s capacity needs, resulting in a higher Effective Load Carrying
Capability than would exist as a standalone energy storage system.
b. Following clarification from Commission Staff, please see the first slide in the
Response to Request for Production No. 71 – Attachment 1 for the 2024 capacity
changes since the capacity deficiency was identified in the 2021 Integrated
Resource Plan, including the resource additions for which Idaho Power received
a Certificate of Public Convenience and Necessity, the 60 MW Franklin BESS
(which was combined with the 100 MW solar PV facility) and the 36 MW
Hemingway BESS. The second slide presents the same information but shows
the impact to the capacity deficiency if a standalone 60 MW BESS project
replaced the combined 100 MW solar PV facility combined with a standalone 60
MW BESS. Finally, the third slide presents the change in the capacity deficiency
if the standalone 60 MW BESS is replaced with a standalone 46 MW BESS, the
resource Staff used to calculate the soft cap in Case No. IPC-E-23-05. As
evidenced on slides two and three, the Company would still have a 2024 capacity
deficiency absent the combined 100 MW solar PV facility combined with the 60
MW Franklin BESS.
c. Please see below for a description of each project configuration:
 The 60 MW Franklin BESS is connected to a 100 MW solar PV facility. The
BESS and the solar facilities are connected on the generator side of the Point
of Interconnection as described in the Generator Interconnection Agreement
and are connected at 34.5-kilovolt (“kV”) alternating current (“AC”). The
BESS can be charged by the solar PV facility or grid-charged, as necessary.
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 8
 The 36 MW Hemingway BESS is a stand-alone facility and is charged by the
grid.
 The 40 MW Black Mesa BESS is connected to a 40 MW solar PV facility. The
BESS and the solar facilities are connected on the generator side of the Point
of Interconnection as described in the Generator Interconnection Agreement
and are connected at 34.5-kV AC. The BESS can be charged by the solar PV
facility or grid-charged as necessary.
d. The nameplate capacity of each BESS facility at the beginning of life are as
follows, which is the actual build capacity excluding any overbuild or
augmentation:
Project Contract Capacity
60 MW Franklin BESS 60 MW
36 MW Hemingway BESS 36 MW
40 MW Black Mesa BESS 40 MW

e. Battery cells degrade over time. For example, a 100 MW BESS installation with
no overbuild will supply 100 MW to the system on day one; however, assuming a
3 percent degradation rate, that same 100 MW BESS will only supply 97 MW to
the system after one year. The degradation rate varies and is a function of time
and throughput, or megawatt-hours (“MWh”). To mitigate the degradation,
additional battery segments are added. Most degradation mitigation plans the
Company has observed through project submittals during the recent RFP
processes include an overbuild with a plan to add battery segments in the future
when capacity drops below the desired level. Note, BESS systems are often
expressed in units of MWh. For example, a 4-hour 100 MW BESS would supply
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 9
400 MWh in a cycle whereas a 100 MW BESS with a 20 percent overbuild would
supply 480 MWhs.
If one bidder overbuilds 25 percent and another has a 0 percent overbuild
and their price per MW was equal excluding the overbuild, the cost of the project
with the overbuild would be 25 percent higher than the project with no overbuild.
The results would indicate the overbuild project is more costly. However, the
project without the overbuild would need to add batteries during year one, year
two, year three, and so on to mitigate degradation. Another approach to
degradation mitigation is to enter into a battery augmentation agreement with the
manufacturer of the battery cells. Under an augmentation agreement, the
manufacturer might require the buyer to pay a fixed annual fee over the 20-year
life of the project and the manufacturer would then add batteries as necessary to
get back to the original agreed upon MW capacity.
For project evaluation purposes and to ensure bids of varying overbuild
sizes are comparable, the Company adjusts the overbuild back to zero for each
project, and then adds annual augmentation costs through the life of the project.
This puts projects with varying overbuild sizes on a comparable basis and
assumes capacity output stays flat over the life of the project. The following
summarizes the installed BESS capacity, including any overbuild and associated
project costs:
 60 MW Franklin BESS: the total installed MW AC measured after losses is
65.93 MW. The Company has included $125.47 million in total costs
associated with the project in the request in this case.
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 10
 36 MW Hemingway BESS: the total installed MW AC measured after losses is
42.65 MW. Total project costs of $68.79 million have been included in Idaho
Power’s request in this case.
 40 MW Black Mesa BESS: the total installed MW AC measured after losses is
46.56 MW. Idaho Power estimates total project costs to be $58.98 million.
f. Idaho Power has not entered into battery augmentation agreements, therefore
potential planned augmentation for each project is unknown. The time, scale,
and costs of any future augmentation will require analysis of then-current
operational characteristics. Prior to making any determination related to
expenditures associated with augmentation, the Company will review the
current operational capacity of each project, future identified deficits, and costs
compared to alternative resources. Augmentation is dependent on past usage
including cycle counts, total MWh throughput, and longevity. Therefore, Idaho
Power has eliminated prescriptive obligations on the Company to purchase
future augmentation and has instead elected to analyze the future decision
based on then-current operational and price characteristics.
g. Each of the BESS facilities utilizes Lithium Iron Phosphate battery cells. The scope
of work, technical specifications, and anticipated degradation for each project are
included as Response to Request for Production No. 71 – Confidential
Attachments 2 through 4.
h. Battery cells within a BESS degrade over time and more rapidly in the first year
of use. For example, a BESS installation providing 100 MWh will supply 100
MWh to the system on day one; however, assuming the below degradation
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 11
curve, that same BESS installation will only supply 93 MWh to the system after
one year. The degradation rate varies and is a function of time and throughput,
or megawatt-hours.
Year Beginning of Year
MWhs
Degradation
MWhs
End of Year MWhs
1 100 6.9 93.1
2 93.1 2.3 90.8
3 90.8 1.8 89.0
4 89.0 1.5 87.5
5 86.1 1.4 86.1

To mitigate the degradation, additional battery segments are added. By
including additional battery segments at the beginning of life, Idaho Power can
ensure reliable operation at full nameplate capacity for a minimum of 4 hours
beyond the first year of operation before necessitating a decision to augment the
BESS if the then-current capacity is below the nameplate contract capacity. If
the BESS system is not cycled daily, the longevity and assurance of performing
above the nameplate capacity beyond the performance guarantee is likely and
thus deferral of future augmentation investments can occur. The overbuild is
necessary as it provides for the most efficient plant balancing and cell utilization,
extending the guaranteed performance of the entire system and ensuring the
Company has the capacity necessary to meet customer demand. Absent
overbuild, immediately upon the BESS being placed in service, Idaho Power
would be placed in a resource deficit relative to the required capacity.
Additional benefits exist by having capacity above the nameplate
contract capacity at the beginning of life including the operational flexibility to
discharge the nameplate capacity over a longer duration. As discussed, a
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 12
BESS is often measured in total throughput, or MWh, thus a facility that has
slightly more capacity could be discharged over a duration greater than four
hours. The additional battery cells result in additional time the BESS can
discharge at its nameplate capacity given operational needs. For example, a
100 MW capacity battery would typically discharge for four hours, or 400 MWh.
However, the additional battery cells would allow for 4.5 hours of discharging,
or 450 MWh.
i. Please see the Response to Request for Production No. 71 – Confidential
Attachment 5 for the cost data associated with each of the BESS. Investment
Tax Credits (“ITCs”) are not earned until a project is placed in-service and the
Company cannot realize a benefit until utilized on a tax return. For the battery
storage projects, Idaho Power anticipates earning the 30 percent ITC.
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 TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 13
REQUEST FOR PRODUCTION NO. 72: Paragraphs 31 and 32 of the Company's
Application explain the method used to estimate the incremental costs of the hypothetical
distribution line approved in the 2017 CPCN. Application at 12. Please explain the
following:
a. Please explain why the Company removed "most of the distribution poles," rather
than all the poles; and
b. Please explain why the Company added the following two items:
i. The replacement of a portion of the existing wood poles with taller, steel
poles; and
ii. Distribution intersect poles.
RESPONSE TO REQUEST FOR PRODUCTION NO. 72:
a. In order to estimate the incremental costs associated with the modified distribution
line configuration, a cost estimate was prepared of what the distribution costs
would be if it were underbuilt on planned overhead transmission poles. As such,
the primary costs are equipment such as cross-arms, insulators, conductor/wire,
and distribution equipment such as transformers. As a result, very few distribution
poles are required for an underbuilt distribution line. However, transmission line
routing and pole placement are designed to minimize transmission poles, thus
leaving potential gaps where distribution equipment may be required. In this
scenario, a distribution “intersect” pole may be required (for example to install a
transformer for a customer that is not otherwise able to be accommodated on the
transmission pole). The modified distribution line configuration accounts for some
intersect poles.
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 14
b. Replacement of wood poles with taller, steel poles and the addition of intersect
poles is described in part (a). Specifically, in an “all overhead” transmission line
design with accommodations for distribution underbuild, the height of the
conductor likely would have required some distribution intersect poles to
accommodate equipment where applicable and the intersect poles are assumed
to be taller steel poles compared to the existing overhead distribution.
The response to this Request is sponsored by Mitch Colburn, Vice President of
Planning, Engineering, and Construction, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 15
REQUEST FOR PRODUCTION NO. 73: Please provide invoices for the sample
selected in the confidential attachment titled "Jan-May Capital Project Invoice Sample".
For selections not linked to specific invoices, please explain the accounting method used
to determine the amount and provide calculations that determine the amount in Excel
format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 73: Please see the
Response to Request for Production No. 73 – Confidential Attachment 1 for the “Jan-May
Capital Project Invoice Sample” file with an additional column providing a description of
whether an invoice is available or a reference to the calculation and accounting method
used. The Response to Request for Production No. 73 – Confidential Attachments 2
through 10 provide further support for either the invoice or the calculations and accounting
method used, as referenced in the description included in the updated invoice sample file.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 16
DATED at Boise, Idaho, this 6th day of September 2024.

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 17
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 6th day of September 2024, I served a true and
correct copy of Idaho Power Company’s Response to the Tenth Production Request of
the Commission Staff to Idaho Power upon the following named parties by the method
indicated below, and addressed to the following:

Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

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Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 18
Idaho Conservation League
Brad Heusinkveld
710 N. 6th Street
Boise, Idaho 83702
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701

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IDAHO POWER COMPANY’S RESPONSE TO THE TENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER - 19
Steven Hubble
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Federal Executive Agencies
Peter Meier
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

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Stacy Gust
Regulatory Administrative Assistant

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