20241127Eric Hackett Rebuttal_Redacted.pdf

RECEIVED
Wednesday, November 27, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-24-07
AUTHORITY TO INCREASE RATES FOR )
ELECTRIC SERVICE TO RECOVER )
COSTS ASSOCIATED WITH )
INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS )
AND MAINTENANCE EXPENSES . )
IDAHO POWER COMPANY
REBUTTAL TESTIMONY
OF
ERIC HACKETT

1 Q. Please state your name .
2 A. My name is Eric Hackett .
3 Q. Are you the same Eric Hackett that previously
4 presented direct testimony?
5 A. Yes .
6 Q. What is the purpose of your rebuttal
7 testimony?
8 A. The purpose of my rebuttal testimony is to
9 respond to the generation-related project cost adjustments
10 proposed by Idaho Public Utilities Commission
11 ("Commission") Staff ("Staff") in their direct testimony,
12 including certain interconnection facilities, the Black
13 Mesa 40 megawatt ("MW") Battery Energy Storage System
14 ("BESS") , the Franklin 60 MW BESS, and the Hemingway 36 MW
15 BESS . Based upon my review, there is disagreement as to
16 whether the projects are currently used and useful and
17 whether the Franklin 60 MW BESS was the least-cost, least-
18 risk resource. My testimony will make clear that the
19 interconnection facilities discussed by Staff, the Black
20 Mesa 40 MW BESS, the Franklin 60 MW BESS, and the Hemingway
21 36 MW BESS, are all currently used and useful, have been
22 placed in-service, and are contributing to the delivery of
23 safe, reliable electricity to customers in 2024 . In
24 addition, I will provide evidence that the Franklin 60 MW
HACKETT, DI-REB 1
Idaho Power Company

1 BESS was the least-cost, least-risk resource selected
2 through the Company' s robust competitive bidding process .
3 I . INTERCONNECTION FACILITIES PROJECT COSTS
4 Q. In his testimony, Staff witness Mr. Jason
5 Talford discusses the two interconnection facilities
6 projects associated with the Company' s Franklin 60 MW BESS
7 project and the Hemingway 36 MW BESS projects . Can you
8 generally describe interconnection facilities?
9 A. Yes . Interconnection facilities are the
10 facilities and equipment between the generating facility
11 and the point of interconnection, including any
12 modification, additions or upgrades, that are necessary to
13 physically and electrically interconnect the generating
14 facility.
15 Q. Mr. Talford indicates these interconnection
16 projects should not be included in Idaho Power' s request in
17 this case because the associated resources are not in-
18 service .' Do you agree with his conclusion?
19 A. No. Both interconnection facilities projects
20 associated with generating facilities operational in 2024
21 were placed in-service in May 2024 .2 Further, in his
1 Talford DI at 2, 11. 21-25.
2 See page 120 of Attachment 1 to the Company's Fifth Supplemental Response to
Staff's Request for Production No. 5 included as Exhibit No. 16, page 2. Note,
Attachment 1 to the Company's Fifth Supplemental Response to Staff's Request
for Production No. 5 was filed as Confidential Attachment 1, however, due to
the passage of time, the information included in the attachment is no longer
confidential therefore Idaho Power has removed the confidential designation
from the pages included in Exhibit No. 16.
HACKETT, DI-REB 2
Idaho Power Company

1 testimony, Mr. Talford, has incorrectly identified the
2 Franklin interconnection facilities as being associated
3 with the Franklin 60 MW BESS . 3 For clarification, the
4 project selected through the 2022 Request for Proposals
5 ("RFP") process to fill the identified 2024 capacity
6 deficiency is a 25-year Power Purchase Agreement ("PPA")
7 associated with a 100 MW solar photovoltaic ("PV") facility
8 that supplies energy to an Idaho Power-owned 60 MW energy
9 storage facility. In my testimony I will refer to the
10 combined solar PV plus energy storage project as the
11 Franklin Project, or separately as the Franklin solar or
12 Franklin 60 MW BESS .
13 With respect to the Franklin interconnection
14 facilities Mr. Talford indicates are not used and useful,
15 the Generator Interconnection Agreement ("GIA") associated
16 with these interconnection facilities are specific to the
17 Franklin solar facility,4 not the Franklin 60 MW BESS .
18 Rather, the Franklin 60 MW BESS is utilizing Surplus
19 Interconnection Service as defined in Idaho Power Company' s
20 Open Access Transmission Tariff ("OATT") 5 from the solar
21 facility and does not have separate interconnection
22 facilities .
3 Talford DI at 2, 11. 15-17.
4 See page 120 of Attachment 1 to the Company's Fifth Supplemental Response to
Staff's Request for Production No. 5 included as Exhibit No. 16, page 2.
5 See Idaho Power's GATT, Attachment M.
HACKETT, DI-REB 3
Idaho Power Company

1 Q. Understanding that Staff witness Mr. Talford
2 incorrectly identified one of the interconnection
3 facilities projects, do you agree with Mr. Talford' s
4 assessment that interconnection facilities project costs
5 for the Franklin 60 MW BESS and the Hemingway 36 MW BESS
6 should not be included in Idaho Power' s request in this
7 case because the associated resources are not in-service?
8 A. No. First, as I mentioned earlier, Idaho Power
9 does not own Franklin solar but instead is receiving energy
10 from the project under a PPA, therefore Franklin solar will
11 not have an in-service date in Idaho Power' s accounting
12 records . However, Franklin solar came on-line and began
13 supplying electric energy on June 1, 2024, as expected and
14 is fully utilizing the interconnection facilities, the same
15 interconnection facilities utilized by the Franklin 60 MW
16 BESS . 6 In addition, the Hemingway 36 MW BESS project began
17 its daily cycling on September 20, 2024, and was placed in-
18 service October 25, 2024 . Both resources that required the
19 interconnection facilities came on-line in 2024 .
20 Q. What does it mean when a project is placed in-
21 service?
22 A. A work order, which includes project costs
23 associated with one component of the project, is typically
6 See the Company's Second Supplemental Response to Staff's Request for
Production No. 80 included as Exhibit No. 17, page 7.
HACKETT, DI-REB 4
Idaho Power Company

1 placed in-service when construction has been completed, and
2 the associated assets are used and useful . Projects may
3 have multiple in-service dates, for significant equipment
4 that might be energized at different times, so separate
5 work orders are created for each phase of construction as a
6 single work order can only have one in-service date .
7 Because interconnection facilities are often necessary for
8 the testing and commissioning phase of generation
9 facilities, work orders associated with the interconnection
10 facilities are regularly placed in-service prior to the
11 generating unit being placed in-service.
12 Q. Do you have any additional evidence to support
13 the used and usefulness of the two interconnection
14 facilities projects?
15 A. Yes . In addition to the interconnection
16 facilities projects being placed in-service and
17 appropriately included in the Company' s request in this
18 case, the use of the Franklin solar interconnection
19 facilities is further supported by the backfeed
20 notification that occurred on May 2, 2024, which is the
21 date Idaho Power' s transmission system provided backfeed
22 power to the generating facility. ' Backfeed power generally
23 means the generating facility is interconnected with the
' See the Company's Response to Staff's Request for Production No. 80 included
as Exhibit No. 17, page 5.
HACKETT, DI-REB 5
Idaho Power Company

1 transmission system and energy can flow both from the
2 generator to the transmission system and vice versa, which
3 allows functional testing and commissioning. With respect
4 to the Hemingway 36 MW BESS interconnection facilities,
5 backfeed power to support the testing and commissioning of
6 BESS components occurred on June 26, 2024 . Both the
7 Franklin solar and the Hemingway 36 MW BESS interconnection
8 facilities and the associated resources are in-service and
9 contributing to delivery of safe, reliable electric service
10 to customers .
11 II . BLACK MESA 40 MW BESS
12 Q. Do you agree with Staff witness Mr. Talford' s
13 assessment that the Black Mesa 40 MW BESS is not in-
14 service?8
15 A. No. First, as I discussed earlier, from an
16 accounting perspective, a work order is typically placed
17 in-service when construction has been completed, and the
18 associated assets are used and useful . All work orders
19 associated with the Black Mesa 40 MW BESS had been placed
20 in-service as of June 2024 .9 Second, the commissioning
21 milestone Mr. Talford discusses10 is not indicative of the
22 used and usefulness of the project, but rather of Idaho
8 Talford DI at 4, 11. 5-8.
9 See pages 113 of Attachment 1 to the Company's Fifth Supplemental Response to
Staff's Request for Production No. 5 included as Exhibit No. 16, page 1.
io Talford DI at 4, 11. 12-22.
HACKETT, DI-REB 6
Idaho Power Company

1 Power' s diligent and prudent efforts to ensure the supplier
2 has complied with each and every term of the contract.
3 Q. Why is the commissioning milestone important?
4 A. Under the terms of the Black Mesa 40 MW BESS
5 contract, the Battery Energy Supply Agreement ("BESA") , a
6 Form of Commissioning Certificate is issued when all the
7 required items in the commissioning checklist have been
8 completed. The BESA contains performance criteria including
9 capacity and round-trip efficiency tests, which have been
10 completed satisfactorily thus allowing the BESS to operate
11 as intended. At this time, commercial aspects of the BESA
12 remain outstanding, such as a comprehensive and itemized
13 outstanding punch list which includes immaterial close out
14 services, as-built drawings, final job books, etc.
15 Therefore, the Company has not yet accepted the
16 commissioning certificate even though the project is used
17 and useful .
18 The supplier ran into an issue with the inverters
19 that required derating a few batteries within the facility.
20 While the project is in-service, the Company is maintaining
21 the position that commissioning has not technically been
22 accomplished per the contract. This is a key point as it
23 allows Idaho Power to withhold the milestone payment for
24 commissioning, ensuring there is incentive for the supplier
25 to rectify the issues while also ensuring sufficient
HACKETT, DI-REB 7
Idaho Power Company

1 retention remains to cover liquidated damages or any other
2 withholding. Commissioning not being deemed complete does
3 not invalidate the in-service date of the facility.
4 Q. Does the derating of the batteries impact the
5 40 MW of operating capacity the Black Mesa BESS provides?
6 A. No. The Company held meetings daily with the
7 developer to establish the time when the Black Mesa 40 MW
8 BESS could be taken offline for testing and commissioning,
9 the process referenced in Mr. Talford' s testimony, " and
10 when Idaho Power needed them available for meeting load.
11 During the hot summer days with high load, the Company
12 asked the developer not to work on them at all to allow for
13 charging and discharging whenever needed.
14 Q. Do you have any additional evidence the Black
15 Mesa 40 MW BESS is providing consistent and reliable
16 customer benefits?
17 A. Yes . The chart below includes the Supervisory
18 Control and Data Acquisition ("SCADA") data, presenting the
19 daily charging and discharging of the Black Mesa 40 MW BESS
20 during the top ten peak load days of 2024 .12 Note, positive
21 values indicate time periods in which the batteries are
22 charging while negative values reflect time periods when
23 the batteries are discharging.
11 Talford DI at 4, 11. 12-22.
12 From highest to lowest top ten peak load days: July 22, July 10, July 23,
July 9, July 12, July 11, July 13, July 19, July 24, and July 8, 2024.
HACKETT, DI-REB 8
Idaho Power Company

1 Figure 1
2 Black Mesa 40 MW BESS Cycling Data.
Black Mesa 40 MW BESS
Operation During 2024 Top 10 Days
40
30
20
10
0
1 2 3 4 5 6 7 8 9 1 1 1 13 14 18 19 20 21 22 23 24
a-10
-20 —
-30 —
-40 —
-50
Hour Ending
—1st Highest Peak Day —2nd Highest Peak Day—3rd Highest Peak Day —4th Highest Peak Day —5th Highest Peak Day
3 —6th Highest Peak Day —7th Highest Peak Day —8th Highest Peak Day —9th Highest Peak Day —10th Highest Peak Day
4 The Black Mesa 40 MW BESS was critical to serving load in
5 2024, particularly during the top ten peak load days, and
6 for ensuring continued safe, reliable electric service to
7 customers .
8 III . FRANKLIN 60 MW BESS
9 Q. In his direct testimony, Staff witness Mr.
10 Talford indicates the Franklin 60 MW BESS had not been
11 placed in-service as of August 31, 2024 .13 Has the project
12 since been placed in-service?
13 A. Yes . The Franklin 60 MW BESS is used and
14 useful, having been placed in-service on September 25,
15 2024 . However, the project began its daily cycling on July
13 Talford DI at 6. 11. 8-14.
HACKETT, DI-REB 9
Idaho Power Company

1 8, 2024 . The chart below includes SCADA data, presenting
2 the daily charging and discharging of the Franklin 60 MW
3 BESS for the same top ten peak days of 2024 presented
4 earlier in my testimony:
5 Figure 2
6 Franklin 60 MW BESS Cycling Data.
Franklin 60 MW BESS
Operation During 2024 Top 10 Days
80
60
40
20
0
v 1 2 W67 9 11 12 13 14 15 16 17 18 19 20 21 22 23 24
-20
-40
-60
-80
Hour Ending
-lst Highest Peak Day -2nd Highest Peak Day-3rd Highest Peak Day -4th Highest Peak Day -5th Highest Peak Day
-6th Highest Peak Day -7th Highest Peak Day -8th Highest Peak Day -9th Highest Peak Day -10th Highest Peak Day
7 -
8 Along with the Black Mesa 40 MW BESS, the Franklin 60 MW
9 BESS was critical for ensuring continued safe, reliable
10 electric service to customers in 2024 .
11 Q. Staff witness Mr. Talford further asserts that
12 selection of the Franklin 60 MW BESS through the 2022 RFP
13 process was not least-cost and therefore Idaho Power should
14 not be allowed to recover a portion of the costs associated
HACKETT, DI-REB 10
Idaho Power Company

1 with the project.14 Do you agree with Mr. Talford' s
2 assessment?
3 A. No. As described in my direct testimony, 15 the
4 Company' s competitive solicitation process included the
5 issuance of the 2022 RFP that did not restrict bids based
6 on a resource type or ownership structure, allowing bids
7 for all commercially viable resource types as well as
8 third-party ownership of those resources . Idaho Power
9 received 17 eligible project submittals, comprising 23
10 different proposals, and, following the qualitative and
11 quantitative evaluations, the project submittals were
12 narrowed to a final short list of five different projects .
13 The indicative AURORA modeling scenarios consistently
14 selected the Franklin solar project combined with a 20 MW
15 BESS as the least-cost, least-risk resource addition.
16 Further, following establishment of the final
17 shortlist, developers were provided another opportunity to
18 update and clarify their pricing information, particularly
19 considering the Inflation Reduction Act of 2022 had
20 recently been signed into law and had the potential to
21 lower proposal pricing and the resulting levelized cost of
22 the project submittals . Using the updated levelized cost
23 inputs in AURORA, the Long-Term Capacity Expansion ("LTCE")
11 Talford DI at 7, 11. 5-9.
15 Hackett DI at 11, 11. 1-23.
HACKETT, DI-REB 11
Idaho Power Company

1 modeling was performed once more and, similar to the
2 initial modeling, the Franklin solar combined with a 20 MW
3 BESS was again identified as the least-cost, least-risk
4 resource addition. The table below presents the projects
5 selected to the final shortlist and the resulting ranking.
6 Figure 3
7 2022 RFP Final Shortlist - 2024 Resources .
Developer Project Screening Result
Duke Energy Renewables, 100 MW Solar+20 MW • Project selected as most economic
Inc BESS energy and capacity resource
Idaho Power Company 46 MW Standalone •Project selected as next most
BESS economic energy and capacity resource
150 MW Standalone •Project not selected as a result of
BESS revised LTCE analysis performed with
results of updated 2024 load and
resource balance
52 MW Standalone •Project not selected as a result of
BESS revised LTCE analysis performed with
results of updated 2024 load and
resource balance
100 MW Solar+100 •Developer withdrew from 2024
MW BESS evaluation with site control concerns
8
9 Q. The Company' s request in this case includes
10 costs associated with a 60 MW BESS . Is this the same
11 project submittal bid into the 2022 RFP?
12 A. Yes . While the combined Franklin solar plus 20
13 MW BESS project was consistently selected as the most cost-
14 effective resource for meeting the 2024 capacity deficiency
15 as part of the initial LTCE analysis and again for the LTCE
16 analysis performed with the final short list projects,
17 between the time when the refreshed LTCE analysis was
18 performed and when contract negotiations were to begin, the
19 2024 capacity need had increased.
HACKETT, DI-REB 12
Idaho Power Company

1 Q. Has the Commission acknowledged this increased
2 2024 capacity need?
3 A. Yes . In Order No. 35900, 16 the Commission
4 granted the Company a Certificate of Public Convenience and
5 Necessity for the acquisition of dispatchable energy
6 storage to meet the identified 2024 capacity deficiency. To
7 account for the increased 2024 capacity deficiency, when
8 Idaho Power commenced contract negotiations with the
9 developer, the Company inquired about the feasibility of an
10 increase to the proposed 20 MW BESS . The developer
11 confirmed the battery storage pricing per kilowatt ("kW")
12 could be maintained, and an increased system installed, for
13 up to 60 MW of storage. The combined Franklin solar plus 20
14 MW energy storage project became the Franklin solar plus
15 the Franklin 60 MW BESS, the Franklin Project.
16 Q. Mr. Talford asserts that instead of
17 contracting with the next least-cost resource identified on
18 the final shortlist, Idaho Power negotiated with the
19 developer to increase the capacity of the energy storage
20 component of the project, incurring costs imprudently.17 Do
21 you agree with Mr. Talford' s conclusion?
16 Case No. IPC-E-24-05, Idaho Power Company's Application for a Certificate of
Public Convenience and Necessity to Acquire Resources to be Online by 2024 and
for Approval of a Power Purchase Agreement with Franklin Solar LLC.
11 Talford DI at 12, 11. 2-10.
HACKETT, DI-REB 13
Idaho Power Company

1 A. No. The increase in the capacity of the
2 battery storage facility did not change the economics of
3 the project. Because the pricing of the battery storage on
4 a per kW basis remained nearly the same, the increased
5 capacity would not materially change the levelized cost or
6 the resulting LTCE analysis . Simply stated, the ranking of
7 the final shortlist projects does not change without a
8 change to the levelized cost input in AURORA. The Franklin
9 Project was the least-cost resource resulting from the 2022
10 RFP.
11 Q. In your direct testimony you discuss the
12 prudency of the project costs above the soft cap and point
13 to several necessary methodological adjustments to the soft
14 cap that should be considered when reviewing the cost-
15 effectiveness of total project costs . Staff witness Mr.
16 Talford states the Company' s alternative soft cap is not
17 reasonable.18 Do you agree with Mr. Talford' s analysis of
18 Idaho Power' s proposed alternative soft cap?
19 A. No. However, before addressing Mr. Talford' s
20 conclusion, it is important to note that the combined
21 Franklin Project was the least-cost, least-risk resource
22 resulting from the 2022 RFP and is critical to meeting
23 Idaho Power' s capacity needs . Therefore, the Company
18 Talford DI at 7, 11. 4-5.
HACKETT, DI-REB 14
Idaho Power Company

1 believes all costs associated with the Franklin 60 MW BESS
2 were prudently incurred, including those amounts over the
3 approved soft-cap. Mr. Talford however has responded to the
4 concerns expressed in my direct testimony regarding the
5 quantification of the soft cap which I would like to
6 address, including the practicality, feasibility, and the
7 inability operationally to implement Mr. Talford' s
8 suggestions .
9 Q. What concerns do you have with the
10 practicality of Mr. Talford' s suggestions?
11 A. In my direct testimony I discuss that, while
12 the unit price of the Franklin 60 MW BESS bid into the 2022
13 RFP is greater than the unit price of other BESS projects
14 on the final shortlist, AURORA continually selected the
15 combined Franklin Project in the LTCE analysis, and it is
16 the combination of the Franklin solar and the Franklin 60
17 MW BESS that is economic compared to other projects
18 regardless of technology. I described that the low solar
19 PPA price is contributing to the value the combined project
20 provides as compared to the other final shortlist projects
21 and better meets Idaho Power' s capacity needs, resulting in
22 a higher Effective Load Carrying Capability ("ELCC") than
23 would exist as a standalone energy storage system.
24 Mr. Talford states that he does not believe it is
25 necessary to include Franklin solar in the LTCE modeling
HACKETT, DI-REB 15
Idaho Power Company

1 because both benefits are realized by Idaho Power' s system,
2 regardless of the arrangement of the BESS resource relative
3 to the solar facility.19 Mr. Talford, however, is failing to
4 recognize that the Company cannot unilaterally alter the
5 resource structure of a project submittal into the RFP.
6 Idaho Power could choose the Franklin solar plus BESS bid
7 or choose another project entirely, but choosing just
8 Franklin solar with a different standalone BESS was not an
9 option. Thus Mr. Talford' s proposal is centered around a
10 bid structure that never existed. To align with reality,
11 the combined solar PV plus battery storage project must be
12 analyzed as a single project as that was the bid submitted
13 by the developer; it is not realistic to consider the
14 evaluation of a project submittal that differs from the
15 resource structure proposed and was not an option.
16 Q. The least-cost, least-risk resource bid into
17 the 2022 RFP was initially envisioned as a 100 MW solar PV
18 facility combined with a 20 MW energy storage facility but
19 the Company negotiated instead a 60 MW energy storage
20 facility. Is that a change in the resource structure?
21 A. No. As I discussed earlier, the change in the
22 capacity of the resource did not change the underlying
23 levelized cost input into AURORA, and therefore the
i9 Talford DI at 7, 11. 24-25 - p. 8, 11. 1-2.
HACKETT, DI-REB 16
Idaho Power Company

1 resource structure did not change . The 2022 RFP evaluation
2 process remained fair and competitive even though the BESS
3 capacity increased.
4 Q. What concerns do you have with the feasibility
5 of Staff witness Talford' s proposals?
6 A. Even if Idaho Power was able to separate the
7 resources contained in a bid submitted through the RFP
8 process, all generating facilities wishing to locate in the
9 Company' s service territory must have gone through the
10 generator interconnection process in accordance with Idaho
11 Power' s OATT and have executed the associated GIA. So,
12 while Mr. Talford' s suggestion that any standalone BESS
13 resource on the Company' s system is capable of charging
14 when solar facilities are generating is correct,20 the
15 Company does not have the ability to locate a battery
16 storage facility anywhere it chooses . The Franklin 60 MW
17 BESS was required to be co-located with Franklin solar as a
18 surplus interconnection service customer to utilize the
19 Franklin solar GIA. The resource must be considered and
20 evaluated as a combined solar plus battery facility.
21 Q. Mr. Talford states the structure of the
22 Franklin Project does not resemble a traditional
23 structure .21 Do you agree?
20 Talford DI at 8, 11. 6-9.
21 Talford DI at 8, 11. 23 - 25, - p. 9, 11. 1-2.
HACKETT, DI-REB 17
Idaho Power Company

1 A. No. The structure is similar to the existing
2 Black Mesa project which consists of a 20-year PPA
3 associated with a 40 MW solar PV facility combined with the
4 Idaho Power-owned 40 MW battery storage facility, and two
5 other bids submitted through the 2022 RFP. Prior to the
6 Inflation Reduction Act of 2022, only battery storage
7 facilities that were connected to solar PV facilities were
8 eligible for Investment Tax Credits, increasing the
9 levelized cost benefit of the combined resources, which
10 likely drove these resource structure proposals .
11 Q. What operational-related statements of Mr.
12 Talford' s would you like to address?
13 A. I would like to clarify, specific to the
14 Franklin 60 MW BESS, what grid connected means and what the
15 ability to grid charge means . As I discussed earlier in my
16 testimony, the Franklin 60 MW BESS is utilizing the
17 interconnection facilities under the Franklin solar GIA,
18 which is also the point of interconnection. As a
19 contingency plan, the Company built into its agreement with
20 the developer, the ability to grid charge should the solar
21 PV facility not be operational for extended periods of
22 time . Absent the ability to utilize the interconnection
23 facilities to grid charge when the solar PV facility was
24 inoperable, the Franklin 60 MW BESS would become a stranded
25 generating facility.
HACKETT, DI-REB 18
Idaho Power Company

1 Q. Please summarize the Company' s position
2 regarding Mr. Talford' s analysis of the incremental
3 capacity associated with the Franklin 60 MW BESS .
4 A. As I discussed, other bids for standalone BESS
5 resources submitted through the 2022 RFP are not a direct
6 and appropriate comparison to the Franklin 60 MW BESS
7 incremental capacity as suggested by Mr. Talford, for a
8 variety of practicality, feasibility and operational
9 reasons . Evaluation of the combined Franklin solar and
10 Franklin 60 MW BESS was absolutely necessary, which was
11 determined to be the least-cost, least-risk resource
12 resulting from the 2022 RFP. All costs associated with the
13 Franklin 60 MW BESS were prudently incurred and necessary
14 to ensure continued safe, reliable service to customers .
15 IV. HEMINGWAY 36 MW BESS
16 Q. Staff witness Mr. Talford recommends removing
17 from the Company' s request the costs associated with the
18 Hemingway 36 MW BESS because the project had not been
19 placed in-service as of August 31, 2024 . Is the Hemingway
20 36 MW BESS now contributing to Idaho Power' s efforts to
21 provide safe, reliable electric service?
22 A. Yes . On September 20, 2024, the Hemingway BESS
23 expansion began its daily cycling, which is evidenced by
24 the chart below that includes the SCADA data, presenting
25 the cumulative daily energy charging and discharging during
HACKETT, DI-REB 19
Idaho Power Company

1 the September 19, 2024, through November 16, 2024, time
2 period.
3 Figure 4
4 Hemingway 36 MW BESS Cycling Data.
Cumulative Energy Charging and Discharging
Hemingway 36 MW BESS
1200
1000
800
0
r 600
m
3
m
m
f 400
200
0
,yP ,yP ,yP ,yP ,yP ,yP ,yP ,yP ,yP ,yP ,yP ,yP ,tiP ,yb ,tib ,tiP ,yP ,tib ,tiA ,tib ,yP ,yP ,yP ,yP ,yP ,yP ,yP ,tib ,tiP ,yb
�\1�\~9\ti1\ry9\1�\~�\�y\~9\ti1\~���'\~OO\~\�,y0\�\~OO\y\ryO0\1\vy0\�i\�O\,y1\1O\,3\1O\,tih\yO\,y'�\y0\~�\,YO\ti�\,y0\�3\,,0\Dy\,0\1^\,y0\��\,0\3�ry'11\ry\�y'�P\~Otis\b\•y'yti\$\,Y'i\~�\,y'Y\1�y'1\~P\,y1\�6\•`O
■Discharge ■Charge
5
6 Q. Staff witness Mr. Talford proposes that, if
7 the Commission allows for inclusion in rates of the
8 Hemingway 36 MW BESS, an adjustment associated with the
9 overbuilt capacity should be made to the total project
10 costs, reducing the amount Idaho Power has requested be
11 included in the test year.22 Do you agree with this
12 proposal?
13 A. No. All battery cells associated with the
14 Hemingway 36 MW BESS are used and useful and appropriately
22 Talford DI at 15, 11. 6-10.
HACKETT, DI-REB 20
Idaho Power Company

1 included in the Company' s request in this case; it is not
2 appropriate to include any amounts associated with the
3 Hemingway 36 MW BESS in plant held for future use . As
4 described in my direct testimony, battery cells degrade
5 over time,23 though the degradation rate varies and is a
6 function of time and throughput, or megawatt-hours ("MWh") ,
7 it is estimated that a 7 percent degradation rate occurs in
8 year one followed by a 3 percent degradation rate in years
9 two through five. That means that a 100 MW BESS
10 installation, for example, will supply 100 MW to the system
11 on day one, but will only supply 93 MW to the system after
12 one year. Absent degradation mitigation which includes
13 additional beginning of life battery cells, Idaho Power
14 would immediately be placed in a resource deficit position
15 in the first year of operation. To mitigate the expected
16 degradation, additional battery segments are added to
17 maintain the operating capacity of the battery storage for
18 five years .
19 Q. Mr. Talford suggests that a reasonable amount
20 of overbuild should account for degradation during only the
21 first two years of operation.24 Do you agree that mitigation
22 of degradation for only the first two years is reasonable?
23 Hackett DI at 15, 11. 23 - 25 - p. 16, 11. 1-5.
21 Talford DI at 14, 11. 16-18.
HACKETT, DI-REB 21
Idaho Power Company

1 A. No. Procurement of battery storage facilities
2 take approximately two years, as evidenced by the Company' s
3 recent resource procurement efforts, which means that under
4 Mr. Talford' s proposal, Idaho Power would need to make an
5 augmentation decision immediately upon commercial operation
6 of the battery storage facility. That would result in a
7 decision being made prior to receipt of any operational or
8 performance data based on use of the battery storage
9 facility, which is necessary in helping inform future
10 augmentation decisions beginning in year three . While
11 actual system degradation may be determined from measurable
12 operational characteristics in year three as Staff witness
13 Mr. Talford suggests, the Company would have missed the
14 procurement window for any battery segments during that
15 year and the next.
16 Further, at the time the contract was executed, in
17 addition to the customer reliability risk consideration,
18 the Company made the decision to mitigate for degradation
19 over a five-year period to hedge against future price
20 fluctuations and battery supply availability. The Lithium
21 Carbonate index was volatile, the industry was experiencing
22 a surge in demand, driven by both utility scale batteries
23 and electric vehicles, and it was anticipated that future
24 pricing would increase. With the purchase of the additional
25 battery segments to ensure the battery storage facility
HACKETT, DI-REB 22
Idaho Power Company

I maintained its operating capacity of 36 MW, Idaho Power was
2 able to ensure contractual remedies for underperformance,
3 capacity at a committed price, and battery delivery supply.
4 Q. Does the Company anticipate any costs savings
5 associated with the five-year degradation mitigation?
6 A. Yes . Idaho Power experienced cost savings
7 resulting from economies of scale and anticipated cost
8 savings associated with contractor efficiencies from
9 installing more battery segments now compared to
10 mobilization of resources and equipment at a future date .
11 Q. Are there any operational benefits to the
12 five-year degradation mitigation?
13 A. Yes . It is important to note that the total
14 energy afforded by the Hemingway 36 MW BESS is based on the
15 total installed batteries and is not limited to the
16 project' s capacity size. Meaning that every battery cell
17 installed is used and useful at the beginning of its life .
18 Megawatt-hours is a measurement of the capacity multiplied
19 by the duration of discharge. So, every battery cell is
20 utilized and rotated to get the longest life expectancy,
21 while also maintaining the system performance over the 5-
22 year guarantee. Additionally, because performance is a
23 measurement of MWh over the five years, the Company is not
24 limited to exactly 144 MWh per cycle; the degradation
25 mitigation of 6 . 444 MW allows for an additional 26 MWh per
HACKETT, DI-REB 23
Idaho Power Company

1 cycle . Customers receive the benefit of the capacity of the
2 additional battery cells because the megawatt-hour energy
3 is used at the beginning of its life.
4 In addition to providing additional megawatt-hour
5 energy, the additional battery cells allow for maximum
6 utilization of each inverter by placing more individual
7 energy segments behind the inverter, limiting additional
8 inverter purchases in the future, and aiding in maintaining
9 the performance over the first five years . From a
10 reliability perspective, the additional battery cells
11 ensure the battery storage facility can operate at the full
12 36 MW capacity even if some cells are taken out of service
13 for maintenance. The five-year degradation mitigation
14 ensures the battery cells maintain their full rated
15 capacity, delivers reliable redundancy to ensure a single
16 point of failure is not catastrophic, affords flexibility
17 for maintenance, and allows for cell conditioning and
18 balancing to maintain the facility operational
19 characteristics . All project costs associated with the
20 Hemingway 36 MW BESS were prudently incurred.
21 V. CONCLUSION
22 Q. Please summarize your rebuttal testimony.
23 A. Idaho Power' s unprecedented growth over the
24 past decade has resulted in the need to procure multiple
25 utility-scale battery storage resources including the Black
HACKETT, DI-REB 24
Idaho Power Company

1 Mesa 40 MW BESS, the Franklin 60 MW BESS, and the Hemingway
2 36 MW BESS . The Company' s investments in the utility-scale
3 battery storage resources reflect the least-cost, least-
4 risk options to meeting Idaho Power' s resource needs,
5 ensuring it is able to continue to provide safe, clean and
6 reliable energy to customers .
7 Q. Does this conclude your testimony?
8 A. Yes, it does .
9
HACKETT, DI-REB 25
Idaho Power Company

1 DECLARATION OF ERIC HACKETT
2 I, Eric Hackett, declare under penalty of perjury
3 under the laws of the state of Idaho:
4 1 . My name is Eric Hackett.
5 2 . On behalf of Idaho Power, I present this
6 pre-filed rebuttal testimony in this matter.
7 3 . To the best of my knowledge, my pre-filed
8 rebuttal testimony and exhibits are true and accurate .
9 I hereby declare that the above statement is true to
10 the best of my knowledge and belief, and that I understand
11 it is made for use as evidence before the Idaho Public
12 Utilities Commission and is subject to penalty for perjury.
13 SIGNED this 27th day of November 2024, at Boise,
14 Idaho .
15
16 Signed:
17 ERIC HACKETT
18
19
20
21
22
HACKETT, DI-REB 26
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-07
IDAHO POWER COMPANY
RACKETY, DI-REB
TESTIMONY
EXHIBIT NO. 16

Capital Projects Completed JanuaryThru September 2024-Subtotaled by Budget ID
WORK ORDER ACTUAL START DATE(FIRST MONTH OF
Functional PI—TYYe PROIECTTYPE BUDGET_ID WO_DESC..,noN WO PROIECTTYPE NO. INSERVICE DALE SeIst YTD AMOUNT ACTUAIS) BUSINESS NEED BLANKET BUDGET ID
CONE%SHELVING 24 2024-04-01 6,306 3/31/2024 The blanketrypirally absorbs unforeseen equipment replacements duemfailures or future projects
that are not easily identified in advance B.compliance related.The typical yearly spend includes
plant equipment replacement due to failure,or unforeseen projects that FERC or other regulators
Other Production Plam 24 LGPR23O0O1 27650972 Yes
LGPR22O0O1 REPLACE BMPI PRE/FINAL INTAKE FILTERS 24 127,570 3/31/2024 Th.blanket typically absorbs unforeseen equipment replacements due to failures or future projects
that are not easily identified in advance e.g.compliance related.The typical yearly spend includes
plant equipment replacement due to failure,or unforeseen projects that FERC or other regulators
Other Production Plam 24 27652313 2024-03-25 rqui,tc. Yes
IAH ACIVATOR UPGRADE 24 2024-09-30 8,315 9/30/2024 Th.blanket typically absorbs unforeseen equipment replacements due to failures or future projects
that are not easily identified in advance e.g.compliance related.The typical yearly spend includes
plant ego,pment re placement due in to lure,or unforeseen pmjects that FERC or other regulators
Other Production Plam 24 LGPR22O001 27660456 Ves
LGPR220003T nEmer enc Pro ec[s) Ves
Other Production Plan[ 2 inst 4 LGPR220o02 CCW-HEAT E%CHANG ER PLATE SWAP 27648016 2024 cap-05-24 38,609 6/30/2024 Aital a l lotion work order is required to i nsta ll ca Pita l spare parts.
LOPR2SO0 Plot,
Other Production Plant 24 LGPR23O003 BYPASS VALVE INTERNAL COMPONENTS(EMERGENCY SPARES) 24 27629574 2024-05-24 1,222,024 8/31/2023 The steam bypass valves are critical to the operation PLangley Gulch.They perform essential
functions during startup,shutdown,and certain operating scenarios.The valves have been in-service
>3Ovrs and are due for a maior overhaul.
LGP 1,
Other Production Plant 24 LGPR23O0O5 LGPR-UPGRADE THE GAS TURBINE GENERATOR BREAKER 14 27613536 2024 06 28 2 9/30/2022 To allow!,ll output capacity Tthe Ras turbine Renerator.
LG 102,582
LGPR23ODO7 REPLACE THE CEMS COMPUTER-C15CO 24 13,603 10/31/2023 To replace Th,existing o—p—r for the CEMS.,it The computers are reaching theend of life
expect yand require replacement in order to maintain compliance in record keep,ng with the
Other Production Plant 24 22641293 2024-06-30 Department of Environmental Quality"DEO'.
WPR230O0T Tool LGPR-Re lace the CEMS Com u[ers 13,603
OMer Production Plard""1 126,531,617
Storage Battery Equipment 24 BMSU220002 BMSU220O02-BE55401AWINSTALLATION 24 27599690 2024-C6-14 26,720,O22 3/31/20221PC's service territory contouesto experience customer growth and an increasing peak demand
(load)for electrlc,ty.IPC anticipates sustained load growth that will require the pmcumment of new
t et peak suer demand and maintain system reliability.Additionally.recent
ch anges inthe r mm
egional transmission markets have constrained the transmission system external to
the IPC service territory and impacted the ability to impart energy from western market hubs far
delivery to IPC's sy-on.The addition of new resources to meet peak demand is critical to ensure IPC
reliably meet the growing demands on Its electrical system and serve its customers.
The need foradditianal capacity resources has been identified a,early a,Summer 2023 at
approximately 40 megawatts(M W).
BMSU22O0O2 BMSU220002-DEGRADATION MITIGATION 24 1,071,777 3/31/2023
IPC's service territory Continues to experience customer growth and an increasing peak demand
(load)for eleRriciry.IPC anticipates surtained load growth that will require the procurement of new
t eet peak summer demand and m system aintain reliability.Additionah,r ecent
changes nthe regional transmission markets have constrained the transmission syseem external to
the IPC service territory and impaRed the ability to import energy from western market hubs far
delivery to IPC's sy-on.The addition of new resources to meet peak demand Is critical to ensure IPC
reliably meet the growing demands on its electrical system and serve its customers.
The need foradditianal capacity resources has been identified a,early as Summer 2023 at
Store eBatte ui ent 2427628098 2023-12-22 ately 40 megawatts(MW).
Storage Battery EquEipmment 24 BMSU2200O2 BMSU220O02-2O21 RFP NEW ENERGY RESOURCE-4OMW 2024IN-SVC 24 2763443O 2024-06-14 19,945 12/31/2O23 IPC',service territory continues to experience c Vonlr growth and an increasing peak demand
(load)for eleRriciry.IPC anticipates surtained load growth that will require the procurement of new
t eet peak summer deand and m system aintain reliability.Additionally.recent
changes ntheregional transmissio mn markets have constrained the transmission syseem external to
the IPC service territory and impaRed the ability K,import energy from western market hubs far
delivery to IPC's system.The addition of new resources to meet peak demand is critical to ensure IPC
reliably meet the growing demands on its electrical sysem and serve it,customers.
The need for additional capacity resources h.,been Identified as early as Summer 2023 at
approximately 40 megawatts)M W).
BMS ,N)O2-1 2O23 Peak Capacity Resoume(2O21 All Source
Store eBatte E u ent Total
Substation Fquipmentm 41 ARTN190001 ARTN190O01-LAND ACQUISITION 41 22649852 2024-03-19 2O6,42O 2/29/2024 Transformer capacity.Ina95[M1 percentile temperature event the forecasted peak load of 14.39MW
on ARTN TO51 will exceed the planning capacity by 4.91%in the summer of 2024.40°C(1D4°F)
mepla[e rating=14MVA Planning Capacity=13.22MVA Most recent—.1 peak,Summer 2023=
13.82MW Adjusted 951hrce-pentile temperature event peak=1385MW The average growth trend
in this developing rural area 15 0.82%annually. The following alternatives were considered and
determined to not solve the is..........dditianal problems,or involve greater costs:There i,no
available adjacent transformer/feeder capacity to of..d the transformer.
oral ARTN Add Second 46-12.5 Transformer,Add SMv81 Ca Bank.1 F N O11A,O12A,O13A,O14A
5ubstation Equipment 41 BO3O00o82 REPLACE HVAC ATTHEONTARI OSUBSTATION 41 27633466 2024-01-12 12,396 6/30/2023 Funds for potential facilities infras[rucmre projects at[he substations that could arise In 2023 and Ves
bevond.Budgetary estimates based on his o—I trends of Npical activity.
Substation Equipment 41 BO1O0O082 REPLACE FAILED HVAC UNIT AT THE GROVE STATION 41 22643982 2024-01-15 14,593 12/31/2023 Funds for potential faclllties infastrutture projects atthe substations that could arise In 2O23 and Yes
bevond.Budgetary estimates based on historical trends of twical-wit,
5ubstation Equipment 41 BO3O0O082 RAMSEY MOUNTAIN HVAC INSTALIATION TO 27645852 202404-12 26,200 12/31/2023 Funds for potential facilities infrastr—O,projects at the substations that could arise in 2O23 and Ves
bevond End—, based on historical trends of tvoical a,twity.
Substation Equipment 41 BO1OM82 KARCHER SUBSTATION HVAC REPLACEMENT 41 27648364 2024-03-12 8,518 2/29/2024 Funds for potential facllities in6astrutture FRje at the substations that couldarisei12O23and Ves
bevond.Budgetary estimates based on historical trends of tvoical—it,
KINPORT STATION HVAC REPLACEMENT 32 2024-08-16 15,666 7/31/2024 Funds for potential facilities in6astrudure projects at the substations that could arise 112O23 and
.blt.ti..E,uip.lnl 41 BOIO W82 27660738 beyond.Budgetary estimates based on hisorical trends&Woical activity. Vol
GLENNS FERRY STATION HVAC REPLACEMENT 41 2024-08-30 13,324 7/31/2O24 Funds for potential facilities infrastructure projects a[[he substations tha[could arise in 2O23 and
Shb—im Eq,ip,,nt 41 B01O M82 27660747 beyond.Budgetary estimates based on historical trends oftvpi.1 activity. Yes
FERRY SUBSTATION NEW REDUNDANT HVAC INSTALL 41 2024-09-17 19,764 9/30/2O24 Funds for potential facilitiesinf—t—ture Rjodl a1,thesub,t,t1.n,that could arise in 2023and
.b..ti.b Equip.lM 41 BOIO W82 27663O96 beyond.Budeetary estimates based on historical trends oft,p 11 activity. Vol
SIMPLOT SUBSTATION HVAC REPLACEMENT 41 2024-09-13 12,122 8/31/2024 Funds for potential facilities infrastructure projects at the substations that could a rise in 2O23 and
Shb—im Equip,,,[ 41 3131 082 27663100 beyond mate BudRetary estimates based on historical trends of typical a,ity. Ves
ISO1O6Op62 Total
Substation Equipment 41 RATTFRV41 NWMS REPLACE 13OV CHARGER 41 22644132 2024-06-12 ]0,949 11/30/2023 a required to provide power to opera[e[M1e protection,control and communication Ves
zeof the electrical system on lost of normal AC power.Th.,project is an annual program ts o
ce batteries az required in distribution stations.
BATTERY41 Total VARI Replace batteries-Dist Yes
Exhibit No. 16
Case No. IPC-E-24-07
E.Hackett, IPC
Page 1 of 2

Capital Projects Completed JanuaryThru September 2024-Subtotaled by Budget ID
WORK ORDER AIETUAL START DATE(FIRST MONTH OF
Functional PNIATYPI PROIECFTVPE BUDGET_ID WO_DESCRIPl1ON WO PROIERTYPE NO. INSERVICE DATE SeOt YTD AMOUNT ARUAIS) BUSINESS NEED BLANKET BUDGET ID
REPIACESEL-311LATNPSS 32 2024-07-31 9,880 )/31/2024
Equipment failures occur in spite Nall attempts a[preventive and predictive maintenance.This
project is setup to restore failed equipment to operational status.Examples of Items that could
require repair or replacement include:power transformers,synchronous condensers series/shunt
capacitors,air break switches,relays,getaway cables etc.This projett will also be used to fund
compliance or newly mandated projects that arise during a given year.Budget amount N based on
rendofequipmentfailuresandunplannedstationneeds.Fundsfor[hNBudgoUDare
RIE—im Equip.— 41 VARISTAT 2766E778 [r ansferred to s pecific projects during during thevear. Ves
VARISTAT WNDL FAILED SINGLE PHASE STEP DOWN TRANSFORMER 41 )5,)50 7/31/2024
Equipment failures occur in spite of all attempts at preventive and:nPd,cBi maintenance.This
projM is setup to restore failetl equipment to op.r.B.P.1 status.Examples of Items that mould
require repair orreplacementinclutle:powertransfprmers,s nchronouscondensem,series/shunt
capacitors,air break switches,relays,getaway cables etc.This project will also be used to fund
compliance or newly mandated projects[hat arise during a given year.Budget amount k based on
noconl rend of equipment failures antl unplanned A.B.I,needs.Funds for this BudgetlD a re
RIE—im Equip— 41 27660916 2024-0)-1) [r an4orretl to specific projects during[heyear. Yes
VARISTAT SOPK 012A EMERGENCY REPLACE SEL-315A 32 4,072 7/31/2024
Equipment failures occur in spite Nall attempts at preventive and predictive maintenance.This
projM is setup to restorefailetl equipment to operational status.Examples of items that mould
re quire repair orreplacementinclutle:powertransfprmers,,nchronouscondensers,series/shunt
capacitors,air break switches,relays,getaway cables etc.This projett will also be used to fund
compliance or newly mandated projects that arise tluring a given year.Butlget amount is based on
end of equlpmen[fallures antl unplanned station neetls.Fundsf hi,BudgetIOa
RIE—i Equip— 41 27661204 2024-07-30 ansferredto specific projects during the year. Ves
VARISTAT"I" VAR"'
eme encles 947,769 Yes
Substation Equipment 41 WESR220001 RESSGRID BATTERVRECRUPTION STUDY 41 2J586408 2024-04-03 134 8/31/2021 Transformerrapacity.Ina95th-percentiletemperatureeventtheforecastedpeakloadofl3.96MW
on WESR T-061 will exceed the planning capacity by l.)%in the Summer of 2023. 4FFC(1O47)
meplate rating=14MVA Planning Capacity=13.72MVA Most recent actual peak,Summer 2022=
12.)2MW Adjused 95th-percentile temperature event peak=ll.)6MW The average gr=h lrentl
n this developing rural creak 1.51%annually. A la rge load request totaling l.3MW is already
fattored into the transformer loading. The power factor on the transformer has been c.LNI to
unity. The fallowing alternatives were cpnsitlered antl tleterminetl to not solve the issue,cause
additional problems,or involve greater costs:a WE5R13 to HOLY12 Transfer o W ESR12 to PAET12
Transfer a WESR11 to MDVAll Transfer There iz no available adjacent transformer capacity to
PER dthe nzformer ThelRPidentifiedthevalueofnon-wirezdlrtributedresourcezinhelping
m etpeakdemands.
WESR22O0O1-1 WESR T061 Capacity Battery Resolution 134
Sub-tion Equipment 41 WILS220001 WITS NEW T132448MVA TRANSFORMER,NEW METALCLAD,AND NEW WITS 41 2)592965 2024-06-30 4,395,397 8/31/2022 Transformer Capacity.Ina95th-percentiletemperature even(lheforecazted peakload of 3020MW
on WILS T-131 will exceed the planning capacity by 2.7Y.in the summer of 2024.40°C(104°F)
PR
meplate rating=30MVA Planning Capacity=29.4MVA Most—tactual Doak,Summer­2=
16.92MW Adjusted 95th-poh,oha le tem perature even peak=2).)2MW The average growth trend
Inthlsdeveloping a W-reais58%annually. Aloadtranzferofl.2MWfrom LNS614to WIISll
was Dorformed,h Ma h20Z0. Aload transfer of l.2MW hom LNSGl4 to the new WIL514 was
uted sp ng2023. There is no available adjacent capaciryto offload thetransformer.No
economical Non-Wires Alternatives identified.
,395,39)
5ubsblion Equipment 41 WNOL19O0O1 WNDL190001-FEEDER RELAY ASSET REPLACEM ENT FOR WNDL 011A&012A 41 27585685 2024-03-20 286,646 8/31/2021 GEACRrelavz havereachedtheendoflifeandhave highreplacementpriority.Theyhave OLW hto
be unreliable over many years o!use because the contacts become tarnished and do not allow the
relay to reset properly after being Fn the lockout state.The electromechanical CO feeder breaker
relays do not have Hot Line Hold IN LH)functional Fry used for reducing ACFlazh energy while feeder
mat h—,Is being performed.CO feeder brea ken relays do not have fault data recording used for
protection and reliability analysis
WNDL1900O1-1 WNDL Feeder Rol'y
Asset RIPlacemeT `WNDL 011Aand 012A 286,646
Substation Equipment 41 WYEE190001 WYEE39EO FEEDE R RE LAY ASS ET REPLACEMENT FOR WYEE O13A ANDO14 41 27584293 2024-01-19 130,968 7/31/2021 The 59 year old elecromechanical CO feeder breaker relays have reached the end oft lfe.CO feeder
breaker relays do not have standard protection functions or fault data recording used for protection
and reliability analvsis.
WVEE190O01 Tobl Feeder Relay Asset Replacement for WYEE 013A and 014A 130,968
Sub-U-Equipment Tots 33,507,892
Transmission Plant 12 GINT22OS49 GINT220549 FRANKLIN INTERCONNECTION FACILITIES ONLY 12 27615848 20240503 32,59D 10/31/2022 Th,,project is requiredin order to accommodate Me customer's interconnection request.
GINT22O549 Total Franklin Solar 10O MW EnoRy SE.AE,PrOect GINT4549-Includes Network U rades 32,590
Tbnsmission Plan[ 12 GIMT240629 GIMT24D629-INTERCONNECT FOR 36 MW BESS AT HMWV 12 27640694 2024-05-13 809431 11/30/2023 THls project is requiredin order to accommodatethe customer'sinterconPo,bon request.
61-0629 Tobl Hemingway Storage Expansion Projett 85 MW N29-Idaho Power 809,431
Transmission Plant 12 GINT240648 GIMT240648 STELLAR SOLAR 301MW INTERCONNECT FACILITIES 12 1)633153 1O14 D419 FEE 6/30/2023 Th,,projectisrequired in.,demo accommodate Me cgrt—W,interconnection requert.
GIN-648 Tobl Stellar Solar Pro'ett 3O0 MW GI4648-NetworkU rades -505
Tbnsmission Plant 13 GIMT230567 PLFASANTVALLEY SOLAR LAND PURCHASE 12 2]6185J5 2024-05-10 264 2/28/2023 THls projec[Is required in order to accommodatethe customers interconnection request.
G-305677ob1 Pleasant Valley Solar 1&2(GINEI antl ENTREES)-Inttude,Network Upgrades 264
Transmission Plats 30 VARI21O0O7 REPLACEMENT T866 FOR FAILED UNIT AT DESN 3D 27637472 101401 E3 5,136 10/31/20231n asingfoqu Wof SCADA system failures requiringmultipleTechniciancJ.Ut,to identify and Ves
G.Impact reliability and increase O&M.Obsolete,end of life SCADA equipment is typically Me root
cause.Permanent resolution of the issue requires purchasing and installing new SCADA equipment.
obi Control Tech,SCADA Equipment Replacement 5,136 Ves
VAR122O018 SYSPRO HARDENING PROJECT NYSA 41 6,348 7/31/2023 Phase 111 Of Op—It roatlmap ca llsfor 89 system protection sites to be hardened against cyber
unity threats These systems are on the Craft network and have minimal protection In place.By
I SEE 3622/3620 8rewalls at each site the network traffic in and out of the station can be
hansmission Plant 30 27631377 2024-02-08 ately controlled. Yes
Transmission Plant 30 VARI22O018 APPARATUS MONITOR PROJECT-HMWy 30 27640505 2024-0546 5,767 11/30/2023 Phase 111 of OpsNet roadmap calk for 89 system protection sites to be hardened against cyber Yes
unity threats.These systems are on the Craft network and have minimal protection in place.By
mrtalling SEL 3622/362D frewalls at each site the network traffic in and out of the station can be
ately controlled.
Ops a mng 12,115
VAR123O0O3 o LED ET C ISCOI U CS SUPPDRT RENEWAL 11 10,911 6/30/2024 Op,Net requires replacementand refresh of datacemerandremoteinfranrunonto support of USP
Transmission Plant 30 27656917 2024 06 10 CCTV environments.
3 Tobl Op—[USP and CCN lnfrartrudure Re Iacement 10,921
Exhibit No. 16
Case No. IPC-E-24-07
E.Hackett, IPC
Page 2 of 2

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-07
IDAHO POWER COMPANY
RACKETY, DI-REB
TESTIMONY
EXHIBIT NO. 17

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]
Inordstrom(aMdahopower.com
dwalker idahopower.com
mgoicoecheaallenCabidahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY TO ) CASE NO. IPC-E-24-07
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ) IDAHO POWER COMPANY'S
ASSOCIATED WITH INCREMENTAL ) RESPONSE TO THE ELEVENTH
CAPITAL INVESTMENTS AND ) PRODUCTION REQUEST OF THE
CERTAIN ONGOING OPERATIONS ) COMMISSION STAFF TO IDAHO
AND MAINTENANCE EXPENSES. ) POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Eleventh Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated August 19, 2024, herewith supplements the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 1
Exhibit No. 17
Case No. IPC-E-24-07
E. Hackett, IPC
Page 1 of 8

REQUEST FOR PRODUCTION NO. 80: Please clarify if Capital Project BID
FRBS230001 - 60 MW Franklin BESS has achieved the Substantial Completion
milestone shown in the Build Transfer Agreement - Appendix B as amended April 26,
2024, and documentation of the date that Idaho Power Transmission provided backfeed
power to the project.
a. If so, please provide the Form of Substantial Completion Funds Flow Statement;
or
b. If not, please provide new estimated dates for the remaining unmet milestones as
outlined in the Build Transfer Agreement -Appendix B as amended April 26, 2024,
associated liquidated damages expected to be incurred by the new estimated
dates, and how the damages will be credited in customer rates.
RESPONSE TO REQUEST FOR PRODUCTION NO. 80:
a. Capital Project BID FRBS230001, the 60 MW Franklin BESS, has not achieved
Substantial Completion. However, please see Response to Staff Request No. 80
— Attachment 1 for documentation supporting the backfeed date of May 2, 2024.
b. Guaranteed Substantial Completion Date is anticipated by August 31, 2024, with
Final Acceptance in September 2024. Liquidated damages will apply but the value
is unknown until the project is substantially complete and the parties agree to the
delay damages and the various obligations governed by the Build Transfer
Agreement and the Engineering, Procurement and Construction Agreement. Any
liquidated damages assessed will be applied as a credit to net power supply
expenses and therefore will flow back to customers through the Power Cost
Adjustment mechanism ("PCA").
IDAHO POWER COMPANY'S RESPONSE TO THE ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 14
Exhibit No. 17
Case No. IPC-E-24-07
E. Hackett, IPC
Page 2 of 8

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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 15
Exhibit No. 17
Case No. IPC-E-24-07
E. Hackett, IPC
Page 3 of 8

DATED at Boise, Idaho, this 3rd 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 ELEVENTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER- 22
Exhibit No. 17
Case No. IPC-E-24-07
E. Hackett, IPC
Page 4 of 8

Response to Staff Request No.80-Attachment 1
Hackett, Eric
From: Saxe, Connor
Sent: Thursday, May 2, 2024 8:32 AM
To: Hall, Bryan; Hackett, Eric
Cc: Collins, Christopher; Bischof, Gary; Braun, Mike;Johnson, Matt; Dwight, George;
Hendley, Kelly; Clanin, Jason; Frey, Ann; Maloney, Mike; Christopher R. Boling
Subject: RE: Franklin Ready for Back feed Notification
Hi Bryan,
As referenced in the Second Amendment of the BTA-Section 5, IPC is ready to provide backfeed power to the 345kV
circuit breaker at the Franklin Substation.
Note: Deriva has requested energization on 5/3/24.
Thanks,
Connor Saxe
Sr. Engineering& Construction PM
Idaho Power I Planning, Engineering&Construction
Office 208-388-5251 1 Mobile [phone]
1221 W. Idaho St. I Boise, Idaho 183702
From: Hall, Bryan <[e-mail]>
Sent: Sunday,April 21, 2024 1:26 PM
To: Hackett, Eric<[e-mail]>; Saxe, Connor<[e-mail]>
Cc: Collins, Christopher<[e-mail]>; Bischof, Gary<[e-mail]>;
Braun, Mike<Mike.Braun @derivaenergy.com>;Johnson, Matt<[e-mail]>; Dwight, George
<[e-mail]>; Hendley, Kelly<[e-mail]>; Clanin,Jason
<[e-mail]>; Frey,Ann <[e-mail]>; Maloney, Mike
<[e-mail]>; Christopher R. Boling<[e-mail]>
Subject: [EXTERNAL] Franklin Ready for Back feed Notification
KEEP IDAHO POWER SECURE! External emails may request information or contain malicious links or attachments.Verify the
sender before proceeding, and check for additional warning messages below.
Good afternoon Eric and Connor, as referenced in the Second Amendment of the BTA- Section 5, please
allow this to reflect the Franklin Project being readyfor Back feed at our Breaker.
Thanks,
Bryan Hall MBA,PMP,PMI-RMP,PMI-PBA
Senior Project Manager
Wildflower Solar/ Franklin BESS-Solar Projects
bryan.hall(cOderivaenergy.com
704-363-1113
1 Exhibit No. 17
Case No. IPC-E-24-07
E. Hackett, IPC
Page 5 of 8

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]
Inordstrom(a)_idahopower.com
dwalker idahopower.com
mgoicoecheaallen(o)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-24-07
COMPANY TO INCREASE RATES FOR )
ELECTRIC SERVICE TO RECOVER ) IDAHO POWER COMPANY'S
COSTS ASSOCIATED WITH ) SECOND SUPPLEMENTAL
INCREMENTAL CAPITAL ) RESPONSE TO THE ELEVENTH
INVESTMENTS AND CERTAIN ) PRODUCTION REQUEST OF THE
ONGOING OPERATIONS AND ) COMMISSION STAFF TO IDAHO
MAINTENANCE EXPENSES. ) POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Eleventh Production Request of the Commission Staff ("Commission" or
"Staff") to Idaho Power Company dated August 19, 2024, herewith supplements the
following information:
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE ELEVENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 1 Exhibit No. 17
Case No. IPC-E-24-07
E. Hackett, IPC
Page 6 of 8

REQUEST FOR PRODUCTION NO. 80: Please clarify if Capital Project BID
FRBS230001 - 60 MW Franklin BESS has achieved the Substantial Completion
milestone shown in the Build Transfer Agreement - Appendix B as amended April 26,
2024, and documentation of the date that Idaho Power Transmission provided backfeed
power to the project.
a. If so, please provide the Form of Substantial Completion Funds Flow Statement;
or
b. If not, please provide new estimated dates for the remaining unmet milestones as
outlined in the Build Transfer Agreement - Appendix B as amended April 26, 2024,
associated liquidated damages expected to be incurred by the new estimated
dates, and how the damages will be credited in customer rates.
SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 80:
b. Capital Project BID FRBS230001 , the 60 MW Franklin BESS, was placed in
service as of September 25, 2024. Idaho Power and the contractor are in the
process of completing the final approvals to close out the contract.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
IDAHO POWER COMPANY'S SECOND SUPPLEMENTAL RESPONSE TO THE ELEVENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 2 Exhibit No. 17
Case No. IPC-E-24-07
E. Hackett, IPC
Page 7 of 8

REQUEST FOR PRODUCTION NO. 84: Please clarify if Capital Project BID
BMSU220002 40 MW Black Mesa BESS has achieved the Commissioning milestone.
a. If so, please provide the Form of Commissioning Certificate; and
b. If not, please provide new estimated dates for all remaining unmet milestones as
outlined in IDP0090 — Black Mesa - Exhibit D of the Battery Energy Supply
Agreement, associated liquidated damages expected to be incurred by the new
estimated dates, and how the damages will be credited in customer rates.
SECOND SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION
NO. 84:
b. Capital Project BID BMSU220002, the 40 MW Black Mesa BESS, is in-service and
operational. The Company has received the paperwork necessary to deem the
commissioning complete pursuant to the contract and is working with the vendor
to complete the final approvals and close out the contract.
The response to this Request is sponsored by Eric Hackett, Projects and Resource
Development Director, Idaho Power Company.
DATED at Boise, Idaho, this 26th day of September 2024.
O�L
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 SECOND SUPPLEMENTAL RESPONSE TO THE ELEVENTH
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER - 3 Exhibit No. 17
Case No. IPC-E-24-07
E. Hackett, IPC
Page 8 of 8