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