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HomeMy WebLinkAbout20241108Application.pdf 0-10RHO POWER. DONOVAN WALKER Lead Counsel RECEIVED dwalker(cDidahopower.com Friday, November 8, 2024 IDAHO PUBLIC UTILITIES COMMISSION November 8, 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-24-42 In the Matter of Idaho Power Company's Application for Approval of a Power Purchase Agreement with Blacks Creek Energy Center, LLC Dear Commission Secretary: Attached for electronic filing please find Idaho Power Company's Application in the above matter. Also attached is a Protective Agreement. Attachment 1 contains confidential information and will be provided 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 Attachments 1221 W. Idaho St(83702) P.O. Box 70 Boise, ID 83707 CERTIFICATE OF ATTORNEY ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION In the Matter of Idaho Power Company's Application for Approval of a Power Purchase Agreement with Blacks Creek Energy Center, LLC IPC-E-24-42 The undersigned attorney, in accordance with Commission Rules of Procedure 67, believes that Attachment 1 to Idaho Power Company's Application, contains information that Idaho Power Company and a third party claims are confidential trade secret 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, they are protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 8t" day of November 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-24-42 APPROVAL OF A POWER PURCHASE ) AGREEMENT WITH BLACKS CREEK ) APPLICATION ENERGY CENTER, LLC. ) Idaho Power Company ("Idaho Power" or "Company"), in accordance with Commission Rule of Procedure' 52 and Idaho Code §§ 61-502 and 61-503, hereby requests that the Idaho Public Utilities Commission ("Commission") issue an order approving the 20-year Power Purchase Agreement ("PPA") between Idaho Power and Blacks Creek Energy Center, LLC ("Blacks Creek" or "Seller") entered into with the expectation of assigning the associated energy and Green Tags/Environmental Attributes to Brisbie LLC ("Brisbie") under the provisions contained in the Special Contract, as amended, that was approved by the Commission in Order Nos. 35777 and 35958 issued in Case No. IPC-E-21-42. Idaho Power also hereby respectfully submits for Commission approval the associated Tariff Schedule 33 (Attachment 2 hereto) based on the Proposed Payment Hereinafter cited as RP. APPLICATION - 1 Structure (Attachment 3 hereto) in accordance with Commission direction in Order No. 36197 and consistent with the framework previously approved for the Brisbie, LLC ("Brisbie") Energy Services Agreement ("Brisbie ESA" of"Brisbie Special Contract"). Idaho Power's Application is based on the following: I. BACKGROUND AND BRISBIE SPECIAL CONTRACT 1. Brisbie is developing a new data center facility at which it anticipates energy requirements will exceed the threshold for service under Schedule 19, Large Power Service, necessitating special contract arrangements with the Company.' In addition to having large load service requirements in excess of 20 megawatts ("MW"), Brisbie and its parent company, Meta Platforms, Inc. ("Meta"), have a sustainability objective to support 100 percent of its operations with new renewable resources, which will require Idaho Power to add new renewable resources to its system. 2. As such, the Company and Brisbie entered into a Special Contract Agreement dated December 22, 2021, First Amendment thereto dated August 3, 2023, and Second Amendment thereto dated March 14, 2024, also referred to as the Brisbie Special Contract or Energy Services Agreement ("ESA"). To facilitate its sustainability objective, Brisbie's ESA encompasses the pricing associated with retail electric service from Idaho Power as well as cost and credit components associated with new renewable resources to support Brisbie's load, and terms and conditions governing the structure of this new arrangement, including provisions that will hold other Idaho Power customers harmless. 2 See I.P.U.C. No. 29, Tariff No. 101, Schedule 19 (requiring customers with an aggregate power requirement of more than 20,000 kW at the same premises "make special contract arrangements with the Company.") APPLICATION - 2 3. To accomplish its goal of supporting 100 percent of the data center operations with renewable energy, the Brisbie ESA provides for a tailored acquisition of the right amount of renewable generation while also ensuring reliable electric service to the customer. As an enterprise data center, Brisbie's energy will remain high and consistent throughout the day, which is not well aligned with the intermittent nature of renewable resources (e.g., solar only generates electricity during daylight hours). To reconcile this mismatch of energy service requirements and renewable generation but still achieve Brisbie's sustainability objective, the renewable resources for Brisbie must be appropriately sized to ensure that the total renewable generation output over the year matches or slightly exceeds Brisbie's annual energy consumption. 4. Under the regulatory framework contemplated by the Brisbie ESA, the renewable resources are to be procured on the customer's behalf by Idaho Power and connected directly to the Company's transmission system. Brisbie will pay for the costs associated with the renewable resources required to support their load and will also be credited for the value those resources bring to Idaho Power's system. The Brisbie ESA also requires that for each Renewable Resource PPA Brisbie will provide security designed to secure any above-market costs associated with each Renewable Resource PPA in the event of non-performance by Brisbie. Brisbie's supporting renewable resources have been factored into portfolio modeling for the Company's Integrated Resource Plan ("IRP") (presumed to be solar resources for purposes of this analysis). Inclusion of the renewables in the IRP modeling allows them to be treated as system resources for modeling purposes and enables Idaho Power to quantify their value to the Company and its broader customer base. APPLICATION - 3 5. Pursuant to Article 7 of the Brisbie Special Contract, either Brisbie or Idaho Power may solicit and present Renewable Resource Projects either from third-party developers or as Idaho Power owned resources for negotiation and procurement to meet Brisbie's load under the ESA. Renewable Resource PPAs procured under the ESA shall be substantially in the form of the aspirational renewable resource PPA provided as Exhibit 6.2(a) to the ESA. The Blacks Creek PPA is based upon this template as modified based on Staff's recommendations in prior cases. 6. The Brisbie ESA is consistent with and reflects the regulatory framework set forth in the Clean Energy Your Way ("CEYW") - Construction option, as approved by the Commission in Order Nos. 35893 and 35950 in Case No. IPC-E-21-40, as well as the Micron Energy Services Agreement ("Micron ESA"), which was approved by the Commission in Order Nos. 35735 and 35898 in Case No. IPC-E-22-06. 7. This is the third Renewable Resource PPA acquired pursuant to the Brisbie Special Contract. The previous PPAs were: (1) Pleasant Valley, approved by Order No. 35739 in Case No. IPC-E-22-29; and (2) PVS2, approved by Order No. 36197 in Case No. IPC-E-24-01. The Brisbie Special Contract itself was approved, subject to several modifications directed by the Commission, by Order No. 35777 in Case No. IPC-E-21-42. The resulting First Amendment to the Brisbie Special Contract and updated Schedule 33 incorporating the modifications and direction of the Commission were approved in a compliance filing by Order No. 35958. The Second Amendment to the Brisbie Special Contract is awaiting a Commission decision in Case No. IPC-E-24-23. 8. Based on the Commission's direction and guidance related to executing future CEYW Construction agreements generally and the Brisbie Special Contract specifically, the Company hereby submits an updated Schedule 33 as well as the APPLICATION -4 Proposed Payment Structure for approval along with its associated PPA, the Blacks Creek PPA, rather than submitting those items as compliance items after PPA approval as was done on the previous PPAs. II. BLACKS CREEK PPA 9. On October 11, 2024, Idaho Power and Blacks Creek entered into a PPA for the sale and purchase of 320 MW of renewable solar electric generation for a term of twenty years from the Commercial Operation Date ("COD"), scheduled to be December 31, 2027. Under the terms of the PPA, PVS 2 will build, own, operate, and maintain a 320 megawatt alternating current ("AC") solar photovoltaic generation facility ("Renewable Resource" or "Facility") and will supply the output to Idaho Power's system. Brisbie is identified in the PPA as a third-party beneficiary receiving Net Output and Green Tags generated by the Renewable Resource. The PPA is provided as Confidential Attachment No. 1 to this Application and incorporated herein by this reference. Exhibit 5 to the PPA sets forth the Contract Price for Contract Years 1 through 20 on a dollars per megawatt- hour ("MWh") basis. 10. The Blacks Creek PPA is similar in many ways to the numerous energy sales agreements approved by the Commission pursuant to the Company's obligations under Public Utility Regulatory Policies Act of 1978 ("PURPA"), but also contains additional other terms and conditions consistent with recent non-PURPA power purchase agreements approved by the Commission including the previously approved Pleasant Valley and PVS 2 PPAs under Brisbie's Special Contract. 11. The Blacks Creek PPA provides for a Scheduled COD of December 31, 2027, at Section 1.126, and sets forth a Guaranteed COD as 90 days after the Scheduled COD under Section 1.55. Additionally, Section 1.126 provides some flexibility with the APPLICATION - 5 Scheduled COD stating that the parties shall work in good faith to move such date to June 1, 2027 if the GIA backfeed power milestone and limited operation study indicate that June 1 is feasible. Under the PPA, Idaho Power will receive 100 percent of the Green Tags or Environmental Attributes associated with the Facility, which will be claimed by Brisbie pursuant to the Special Contract. 12. Section 3.1 provides that the Blacks Creek PPA can be terminated by Idaho Power if it has not received Commission approval of all the PPA's terms and conditions and declared that all payments Idaho Power makes to Seller for purchases of energy will be allowed as prudently incurred expenses for ratemaking purposes. This section further provides that if Commission approval is not obtained within six months of filing of the PPA with the Commission for approval, the Scheduled COD and Guaranteed COD may be extended on a day-for-day basis until approval is obtained. In the event Idaho Power has not obtained all regulatory approvals deemed appropriate by the Company by the first anniversary of the filing of the PPA with the Commission, then the Agreement may be terminated. 13. Section 7 of the Blacks Creek PPA contains standard provisions for operation and control of the project. These include such things as planned outages, forced outages, and maintenance outages, as well as scheduling, forecasting, generator output limit control ("GOLC"), and metering. For forecasting, the PPA provides the same allocated portion of the total cost of Idaho Power's Solar Energy Production Forecast model that is used for all solar projects that are under contract to provide energy to Idaho Power. APPLICATION - 6 14. Section 7.12 of the PPA also contains a performance requirement in the form of an Output Guarantee. Under the Output Guarantee, the Seller is obligated to deliver 90 percent of the Estimated Net Output Amount of the Facility on a monthly basis. Similar to the provisions included in recent PURPA agreements, Section 7.12.1.1 of the PPA allows the Seller an adjustment of Estimated Monthly Net Output Amounts by the 25th day of the preceding month. If the project delivers less than the Output Guarantee during any full calendar quarter, the Seller must pay the Output Shortfall for that quarter multiplied by Idaho Power's Cost to Cover as liquidated damages in Section 7.12.2.2-3. If the delivered Net Output is equal to or greater than the Output Guarantee, then the Seller is deemed to have satisfied the Output Guarantee in Section 7.12.2.1. 15. Section 9 of the PPA contains provisions requiring the Seller to post and maintain both Facility Development Security and Default Security. Facility Development Security, in a form acceptable to Idaho Power equal to $90,000 per MW of Nameplate Capacity Rating, must be in place within 30 days of Commission approval of the PPA and is to remain in place to ensure the project meets its Commercial Operation Date. Default Security in the amount of$90,000 per MW of Nameplate Capacity Rating must be in place at the Commercial Operation Date and maintained through the entire term of the Agreement. III. SCHEDULE 33 AND PROPOSED PAYMENT STRUCTURE 16. Attachment 2 includes a revised Schedule 33 in clean and legislative copy which includes the Annual Renewable Capacity Credit ("RCC") in Table 1, the Monthly Unadjusted RCC by month in Table 2, and the eligibility date for the RCC in Table 3.3 3 Capacity deficiency date of 2026 established from Order No. 36226, Case No. IPC-E-23-27. APPLICATION - 7 These items are presented in the same way that the initial project, Pleasant Valley Solar LLC, and the second project, PVS 2, were presented and approved. 17. Attachment 3 includes the "Proposed Payment Structure" document which details the payment structure calculations and methodology that was previously developed with Staff and is presented in the same format as that which was previously approved in a previous compliance filing for Brisbie.4 IV. MODIFIED PROCEDURE 18. Idaho Power believes that a hearing is not necessary to consider the issues presented herein and respectfully requests that this Application be processed under Modified Procedure; i.e., by written submissions rather than by hearing. RP 201, et seq. Additionally, the Blacks Creek PPA needs to be online in coordination with Brisbie's load service by the Scheduled COD, and the developer of the Blacks Creek project requires sufficient lead time for financing, procurement, and construction once Commission approval of the PPA is obtained in order to meet the Scheduled COD. The PPA provides for day-for-day extension of the Scheduled COD if Commission approval of the PPA is not obtained by May 8, 2025. Consequently, Idaho Power respectfully requests the Commission consider a procedural schedule that would allow for a final Order prior to May 8, 2025. V. COMMUNICATIONS AND SERVICE OF PLEADINGS 19. Communications and service of pleadings with reference to this Application should be sent to the following: 4 Case No. IPC-E-21-42, Compliance Filing, August 9, 2023. APPLICATION - 8 Donovan E. Walker Tim Tatum Regulatory Dockets Connie Aschenbrenner Idaho Power Company Grant Anderson 1221 West Idaho Street (83702) Idaho Power Company P.O. Box 70 1221 West Idaho Street (83702) Boise, Idaho 83707 P.O. Box 70 dwalker(a1idahopower.com Boise, Idaho 83707 dockets _idahopower.com ttatumC@_idahopower.com energycontracts(c�-idahopower.com caschenbrenner(c)idahopower.com ganderson(aD_idahopower.com VI. CONCLUSION 20. Approval of the Blacks Creek PPA is in the public interest. Idaho Power and Brisbie have worked together to establish a framework that will take a meaningful step towards accomplishing Brisbie's renewable energy goals, while ensuring the related pricing appropriately assigns the costs and benefits of procuring the Renewable Resource to Brisbie. All costs associated with the Blacks Creek PPA will be paid for by Brisbie, which ensures other customers are not harmed by the arrangement. The rates are just, reasonable, consistent with past cost-of-service determinations, and in the public interest. 21. THEREFORE, Idaho Power respectfully requests that the Commission issue an Order prior to May 8, 2025, approving the 20-year PPA between Idaho Power and Blacks Creek, which was negotiated with the expectation of assigning that energy to Brisbie under the Special Contract and that all payments to be made to Seller thereunder shall be allowed as prudently incurred expenses for ratemaking purposes. Additionally, the Company requests approval of the associated Schedule 33 and Proposed RCC filed herewith. APPLICATION - 9 Respectfully submitted this 8t" day of November 2024. DONOVAN E. WALKER Attorney for Idaho Power Company APPLICATION - 10 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY CONFIDENTIAL ATTACHMENT NO. 1 POWER PURCHASE AGREEMENT BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY ATTACHMENT NO. 2 PROPOSED TARIFF SCHEDULE 33 Idaho Power Company Second Revised Sheet No. 33-4 Cancels I.P.U.C. No. 30, Tariff No. 101 First Revised Sheet No. 33-4 SCHEDULE 33 IDAHO POWER COMPANY ELECTRIC SERVICE RATE FOR BRISBIE, LLC. (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 Brisbie, LLC 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 Brisbie, LLC as applicable. The Monthly Adjusted Renewable Capacity Credit will be provided in accordance with Revised Exhibit 3.1 of Brisbie, LLC's Special Contract, dated December 22, 2021, as amended. TABLE 1: RENEWABLE CAPACITY CREDIT a b c d e f Project Most Recently Project Capacity Renewable Renewable Renewable Annual Acknowledged Nameplate Contribution Capacity Capacity Capacity Renewable IRP (kW AC) Factor Contribution Credit Rate Credit Capacity (a * b) ($/kW-yr) Adjustment Credit*' c*d*e Pleasant 2019 200,000 0.3121 62,420 $121.19 1.0 $7,564,680 Valley Solar LLC Pleasant 2021 125,000 0.3154 39,425 $131.60 1.0 $5,188,330 Valley Solar 2 LLC Blacks 2023 320,000 0.1844 59,008 $145.94 1.0 $8,611,628 Creek Energy Center, 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. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs Effective — 1221 West Idaho Street, Boise, Idaho Idaho Power Company First Revised Sheet No. 33-5 Cancels I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 33-5 SCHEDULE 33 IDAHO POWER COMPANY ELECTRIC SERVICE RATE FOR BRISBIE, LLC. (Continued) Renewable Resource Agreements (Continued) TABLE 2: MONTHLY UNADJUSTED RENEWABLE CAPACITY CREDIT BY MONTH Project Jan Feb Mar June July Aug Sept Oct Nov Dec Pleasant $416,057 $416,057 -- $1,380,554$2,761,108$1,380,554 $189,117 $189,117 $416,057 $416,057 Valley Solar LLCM Pleasant $324,271 $324,271 $17,294 $959,841 $1,919,682 $959,841 $17,294 $17,294 $324,271 $324,271 Valley Solar 2 LLC2 Blacks Creek $645,872 $645,872 $57,411 $1,463,977$2,927,953$1,463,977 $57,411 $57,411 $645,872 $645,872 Energy Center, LLC TABLE 3: ELIGIBILITY DATE FOR RENEWABLE CAPACITY CREDIT Project PPA Execution Date Capacity Deficiency Year Renewable Capacity Credit Eligibility Date leasant 10/27/2022 2023 6/1/2023 Valley Solar LC leasant 12/5/2023 2023 6/1/2023 Valley Solar 2 LC Blacks Creek 10/11/2024 2026 6/1/2026 nergy Center LC 1 Amounts to be adjusted by the Performance Ratio Adjustment Factor,which is calculated pursuant to the methodology detailed in Case No. IPC-E-21-42,Attachment 1 to Idaho Power Company's Compliance Filing dated August 9, 2023, as approved in Order No. 35777 (May 11, 2023),to determine the Monthly Adjusted Renewable Capacity Credit. 2 Amounts to be adjusted by the Performance Ratio Adjustment Factor,which is calculated pursuant to the methodology detailed in Case No. IPC-E-24-01,Attachment 2 to Idaho Power Company's Compliance Filing dated June 18, 2024, as approved in Order No. 36270(July 26, 2024), to determine the Monthly Adjusted Renewable Capacity Credit. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs Effective — 1221 West Idaho Street, Boise, Idaho Idaho Power Company Forst Second Revised Sheet No. 33-4 Cancels I.P.U.C. No. 30, Tariff No. 101 04g+ga4-First Revised Sheet No. 33-4 SCHEDULE 33 IDAHO POWER COMPANY ELECTRIC SERVICE RATE FOR BRISBIE, LLC. (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 Brisbie, LLC 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 Brisbie, LLC as applicable. The Monthly Adjusted Renewable Capacity Credit will be provided in accordance with Revised Exhibit 3.1 of Brisbie, LLC's Special Contract, dated December 22, 2021, as amended. TABLE 1: RENEWABLE CAPACITY CREDIT a b c d e f Project Most Recently Project Capacity Renewable Renewable Renewable Annual Acknowledged Nameplate Contribution Capacity Capacity Capacity Renewable IRP (kW AC) Factor Contribution Credit Rate Credit Capacity (a * b) ($/kW-yr) Adjustment Credit*' c*d*e Pleasant 2019 200,000 0.3121 62,420 $121.19 1.0 $7,564,680 Valley Solar LLC Pleasant 2021 125,000 0.3154 39,425 $131.60 1.0 $5,188,330 Valley Solar 2 LLC Blacks 2023 320,000 0.1844 59,008 $145.94 1_0 $8,611,628 Creek Energy Center, 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. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. 36270 Timothy E. Tatum, Vice President, Regulatory Affairs Effective july 26 20241221 West Idaho Street, Boise, Idaho Idaho Power Company -First Revised Sheet No. 33-5 Cancels I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 33-5 SCHEDULE 33 IDAHO POWER COMPANY ELECTRIC SERVICE RATE FOR BRISBIE, LLC. (Continued) Renewable Resource Agreements (Continued) TABLE 2: MONTHLY UNADJUSTED RENEWABLE CAPACITY CREDIT BY MONTH Project Jan Feb Mar June July Aug Sept Oct Nov Dec Pleasant $416,057 $416,057 -- $1,380,554$2,761,108$1,380,554 $189,117 $189,117 $416,057 $416,057 Valley Solar LLCM Pleasant $324,271 $324,271 $17,294 $959,841 $1,919,682 $959,841 $17,294 $17,294 $324,271 $324,271 Valley Solar 2 LLC2 Blacks Creek $645,872 $645,872 $57,411 $1,463,977$2,927,953$1,463,977 $57,411 $57,411 $645,872 $645,872 Ener Center LLC TABLE 3: ELIGIBILITY DATE FOR RENEWABLE CAPACITY CREDIT Project PPA Execution Date Capacity Deficiency Year Renewable Capacity Credit Eligibility Date leasant 10/27/2022 2023 6/1/2023 Valley Solar LC leasant 12/5/2023 2023 6/1/2023 Valley Solar 2 LC Blacks Creek 10/11/2024 2026 6/1/2026 EnerqV Center LC 1 Amounts to be adjusted by the Performance Ratio Adjustment Factor,which is calculated pursuant to the methodology detailed in Case No. IPC-E-21-42,Attachment 1 to Idaho Power Company's Compliance Filing dated August 9, 2023, as approved in Order No. 35777 (May 11, 2023),to determine the Monthly Adjusted Renewable Capacity Credit. 2 Amounts to be adjusted by the Performance Ratio Adjustment Factor,which is calculated pursuant to the methodology detailed in Case No. IPC-E-24-01,Attachment 2 to Idaho Power Company's Compliance Filing dated June 18, 2024, as approved in Order No. 36270(July 26, 2024), to determine the Monthly Adjusted Renewable Capacity Credit. IDAHO Issued by IDAHO POWER COMPANY Issued per Order No. 36270 Timothy E. Tatum, Vice President, Regulatory Affairs Effective july 26 2024 1221 West Idaho Street, Boise, Idaho BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY ATTACHMENT NO. 3 PROPOSED PAYMENT STRUCTURE Case No. IPC-E-24-42- Proposed Brisbie, LLC Renewable Capacity Credit Payment Structure for Blacks Creek The Blacks Creek Power Purchase Agreement ("PPA") was executed on October 11, 2024, and the capacity contribution calculated at the time of contract execution was 18.44%. The annual payment is determined by multiplying the average capacity contribution by the avoided cost of capacity. The avoided cost of capacity is the levelized fixed cost associated with the least-cost dispatchable resource from the Company's most recently acknowledged Integrated Resource Plan ("IRP") at the time of PPA execution. In the case of Blacks Creek, the 2023 IRP was the most recently acknowledged IRP at the time of PPA execution. For the 2023 IRP the identified resource was a simple-cycle combustion turbine ("SCCT") with a Ievelized capacity cost of$145.94 per kW per year. Determine Annual Pam The annual payment is calculated by multiplying the capacity contribution by the nameplate of the selected project by the avoided cost of capacity: Annual Payment = Capacity Contribution * Project Nameplate *Avoided Cost of Capacity Applying the annual payment calculation to the Blacks Creek project, the resulting value is determined to be $8,610,219 per year: Annual Payment = 18.44% * 320,000 kW * $145.94 _ y � � � � kW • yr — $8,611,628/yr Determine Months of Capacity The annual payment will be calculated at the time of contract execution and distributed proportionally over the months that capacity is expected to be needed. To determine the months of capacity need, the Loss of Load Expectation ("LOLE") per month of the different historical years would be used to calculate an average LOLE for each month. If a significant resource stack change is expected in the near future, an adjusted case would be used to guide the monthly weighted average calculations. Because the Blacks Creek Energy Center project is contracted to come online in December 2027, a 2028 Load & Resource ("L&R") year was used to determine the months of capacity need. The average monthly LOLE values for the 2028 L&R year are listed in Table 1. Table 1. 2028 L&R Average Monthly LOLE Month Average LOLE January 0.002168 February 0.000203 March 0.000006 April 0.000000 May 0.000000 June 0.010936 July 0.022652 August 0.002561 September 0.000232 October 0.000321 November 0.040896 December 0.019519 In review of the projected near-term load and resource buildout, Idaho Power adjusted the 2028 monthly LOLE weighted averages to better reflect the expected LOLE distribution of future years. Using the results from the adjusted 2028 L&R year analysis, the monthly LOLE weighted averages are listed in Table 2. Table 2. 2028 Monthly LOLE Weighted Average Month Weighted Average January 5.68% February 0.37% March 0.07% April - May - June 22.55% July 40.53% August 5.37% September 0.54% October 1.07% November 17.76% December 6.06% The twelve months of the calendar year are grouped into three different periods given their Loss of Load Probability ("LOLP") profiles, as described in the list below: • Summer: June, July, and August • Winter: January, February, November, and December • Off-Season: March, September, and October Note that April and May remain at 0% LOLP. A weighted average per period is calculated by adding the percentages of each month within the corresponding period together, as shown in Table 3. Table 3. 2028 LOLE Weighted Average per Period Summer Winter Off-Season June 22.55% January 5.68% March 0.07% July 40.53% February 0.37% September 0.54% August 5.37% November 17.76% October 1.07% December 6.06% Summer Total -68% Winter Total -30% Off-Season Total -2% For the winter and off-season periods, the total is spread out relatively equally over the months; this means the approximate 30% for the winter total would be divided by the 4 months for 7.5% in each month, and the approximate 2% for the off-season total would be divided by the 3 months for 0.67% in each month. For the summer period, the high LOLP hours span from the last 2 weeks of June through the first 2 weeks of August (totaling 8 weeks), meaning there are 4 weeks in July, 2 weeks in June and 2 weeks in August that encompass the high LOLP hours. Because the summer total is set to equal the approximate 68%, the high LOLP hours weekly weighting can be used to smooth the summer period spread: • June - 68% * 2 weeks = 17% 8 weeks • July - 68% * (4weeks1 = 34% 8 weeks • August - 68% * 2 weeks = 17% 8 weeks The final weights by month are shown in Table 4. Table 4. 2028 Seasonal Monthly LOLE Weighted Average Month Weighted Average January 7.50% February 7.50% March 0.67% April - May - June 17.00% July 34.00% August 17.00% September 0.67% October 0.67% November 7.50% December 7.50% The monthly payment is calculated by taking the previously calculated annual payment of $8,611,628 per year and multiplying it by the weighted average for each month, as shown in Table 5. Table 5. 2028 Seasonal Monthly Payment Month Weighted Average Monthly Payment January 7.50% $645,872 February 7.50% $645,872 March 0.67% $57,411 April - - May - - June 17.00% $1,463,977 July 34.00% $2,927,953 August 17.00% $1,463,977 September 0.67% $57,411 October 0.67% $57,411 November 7.50% $645,872 December 7.50% $645,872 Total 100.00% $8,611,628 Performance Metric The Performance Ratio ("PR") is a metric widely used to track performance of photovoltaic ("PW) systems in the industry.' 2,3 The PR metric can be used to ensure a project is being well maintained and is performing as expected. PR can be defined as the ratio of measured output to the expected output for a given reporting period based on the system nameplate rating. Traditionally, PR is mathematically expressed as kWhAc kWoc,sTc PR kW hsun m2 1 kW m2 where kWhAc = Energy Generated by the Plant kWoc,sTc = Rated Direct Current Power of the Plant at Standard Test Conditions kWhsun = Plane of Array ("POA") Irradiance The PR metric is most often used by power plant operators to track plant performance. Idaho Power proposes to modify the previously shown equation to consider the contracted nameplate of the plant on the Alternating Current ("AC") side and not on the Direct Current ("DC") side. The contract with Idaho Power is on the AC side and it has the potential to be the limiting factor during operation. The proposed modification would result in the following PR equation: kWhAc PR = kWNP,Ac * kW hsun IEC 61724-1: 2017 Photovoltaic System Performance 2 Performance of Photovoltaic Systems Recorded by oSPARC, NREL 2020 1 PV System Performance Assessment, Sunspec Alliance, San Jose State University, 2014 One of the interconnection requirements is for the project to provide Idaho Power with weather data via Supervisory Control and Data Acquisition ("SCADA"). One of the variables required is the Plane of Array ("PDX) irradiance (kWh,,,,). The energy injected into the system is also measured via SCADA, making the PR calculation relatively straight-forward. Performance Ratio Target The PR metric is directly impacted by the energy output which is proportional to irradiance and inversely proportional to module temperature. The PR equation accounts for irradiation; changes in irradiation will have little effect on the PR. However, changes in temperature are not accounted for in the PR calculation and the PR will decrease as temperature increases. To account for the impact of temperature on the PR calculation, Idaho Power proposes to set a different PR target for the summer months than the non- summer months. The Company proposes to use the PR targets described in Table 7 and graphically displayed in Figure 1 . Table 7. PR Targets by Period Period Target January through May PR > 1.0 June through September PR > 0.95 October through December PR > 1.0 Performance Metric Threshold by Month 1 0 0.9 t E-- 0.8 v U C m 0.7 i O w N 0.6 0.5 2 4 6 8 10 12 Month of the Year Figure 1. PR Targets by Month Hours of Need Capacity is only avoided during certain hours of the calendar year. The hours where capacity is needed are the hours which have high LOLP values. To provide compensation for capacity when it is needed, the PR metric will be calculated based on the high LOLP hours from the timing of highest risk analysis published in the 2023 IRP, which are provided in Table 8. Table 8. High LOLP Hours Period Identified High LOLP Hours Summer + September4 3:00 pm - 11:00 pm Winter + March & Octobers 6:00 am - 12:00 pm & 3:00 pm - 9:00 pm 4 Identified Summer risk hours from the 2023 IRP are 5:00 pm - 11:00 pm. Due to the limited solar PV generation possible in the 5:00 pm to 11:00 pm window in certain months of the Summer period; the 3:00 pm -5:00 pm hours are included to reduce the solar generation measurement variability. For LOLP hours outside of solar PV generation hours, the expectation of solar PV generation based on irradiance at the site is zero. s Identified Winter risk hours from the 2023 IRP are 6:00 am - 12:00 pm &4:00 pm -9:00 pm. Due to the limited solar PV generation possible in the 4:00 pm to 9:00 pm window in certain months of the Winter period; the 3:00 pm -4:00 pm hour is included to reduce the solar generation measurement variability. For LOLP hours outside of solar PV generation hours, the expectation of solar PV generation based on irradiance at the site is zero. For clarification, the hours presented in Table 8 are Hour Beginning ("HB") for the first interval and Hour Ending for the second interval ("HE"). Using the summer + September period as an example, 3:00 pm HB represents the hour spanning from 3:00 pm to 4:00 pm while 11:00 pm HE represents the hour spanning from 10:00 pm to 11:00 pm; this means the identified summer period high LOLP hours begin at 3:00 pm and conclude at 11:00 pm. Reduction on Pam To receive the full monthly payment, the project will have to meet the PR threshold in the corresponding high LOLP hours (as set in Table 8). If the PR is not met, a reduction in payment will be applied to the project. The reduction will be calculated based on the impact to capacity as measured by the ELCC. The impact on capacity will be determined by reducing the output of the project and calculating its ELCC. For the Blacks Creek Energy Center project, the relationship between output and ELCC reduction was calculated over the range of 0.5 PR to 1.0 PR, as shown in Figure 2. Performance Ratio vs ELCC 100.00% V — �— 80.00% w —� — io ,— — c .LV 60.00% L O F v 40.00% to M c u 20.00% Q) v a 0.00% 0.5 0.6 0.7 0.8 0.9 1 Pv Output Figure 2. Relationship Between PR & ELCC The results shown in Figure 2 will be used to determine the monthly payment reduction if the project did not meet the monthly PR target. In any month where capacity payments are applied do not meet the corresponding target PR, a reduction as presented in Figure 2 would be applied (the reduction is calculated by interpolating between the monthly PR value and the target PR value for that month). As an example of how the PR versus ELCC approach would be implemented, data for a similar project near the Blacks Creek Energy Center site was collected for the 2021 L&R; the PRs were then calculated for the corresponding high LOLP hours of each month with the results shown in Table 9 (bolded values represent calculated PR values that did not meet the targets identified in Table 7). Table 9. Monthly Performance Ratio & Payment Example Month Performance Ratio Payment Reduction Monthly Payment January 1.08 0.00% $645,872 February 1.13 0.00% $645,872 March 1.08 0.00% $57,411 April - - - May - - - June 0.98 0.00% $1,463,977 July 1.00 0.00% $2,927,953 August 0.99 0.00% $1,463,977 September 0.97 0.00% $57,411 October 1.01 0.00% $57,411 November 1.11 0.00% $645,872 December 0.98 1.31% $637,411 Total $8,603,167