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HomeMy WebLinkAbout20241226IPC to Staff 1-20 (Redacted).pdf 0-10RHO R® RECEIVED DONOVAN WALKER Monday, December 26, 2024 Lead Counsel dwalker(cDidahopower.com IDAHO PUBLIC UTILITIES COMMISSION December 26, 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 Response to the First Production Request of the Commission Staff to Idaho Power Company in the above matter. The confidential documents 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 Idaho Power Company's Response to the First Production Request of the Commission Staff and Attachment Nos. 1 and 2 in Response to Request No. 15, contain information that Idaho Power Company and a third party claims are confidential trade secret public records exempt from disclosure by state or federal law (material nonpublic information under U.S. Securities and Exchange Commission Regulation FD) as described in Idaho Code § 74-101, et seq., and/or§48-801, et seq. As such, it is protected from public disclosure and exempt from public inspection, examination, or copying. DATED this 26th day of December 2024. �to'I�t &)da, 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(a-)_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 ) IDAHO POWER COMPANY'S ENERGY CENTER, LLC. ) RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the First Production Request of the Commission Staff ("Commission" or "Staff")to Idaho Power Company dated December 4, 2024, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 1 REQUEST FOR PRODUCTION NO. 1: In Attachment No. 3 of the Application, the Company states that different historical years would be used to calculate an average Loss of Load Expectation ("LOLE") for each month. Please explain what historical years are used and why those historical years are used. In addition, please explain how the average monthly LOLE is calculated. RESPONSE TO REQUEST FOR PRODUCTION NO. 1: The referenced historical data represents years 2017 through 2023, which is consistent with what was discussed in a meeting between Idaho Power and Idaho Public Utilities Commission Staff on June 6, 2024, for Case No. IPC-E-24-01. For additional context, Idaho Power has utilized historical test years in the LOLE reliability analysis beginning with initial implementation in Case No. IPC-E-21-32. Historical test years are utilized in the LOLE calculation to maintain the relationship between variable energy resource output, system load, and weather and environmental conditions. Please see page 2 of the file labeled "Response to Request for Production No. 1" for further information regarding the utilized historical test years. As presented in the Integrated Resource Plan Advisory Council ("IRPAC") virtual meeting on December 8, 2022, for the Reliability and Capacity Assessment topic (and available on Idaho Power's website under the 20-Year Plan Educational Resources), the LOLE is the expected number of days per period for which the available generation capacity is insufficient to serve the demand at least once per day. The monthly LOLE is individually calculated for each of the seven test years (i.e., 2017 through 2023). Each month's seven LOLE values are then averaged to produce the average monthly LOLE result. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 2 The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 3 REQUEST FOR PRODUCTION NO. 2: In Attachment No. 3 of the Application, the Company states "[i]f a significant resource stack change is expected in the near future, an adjusted case would be used to guide the monthly weighted average calculations." Is the Company referring to how a Load & Resource ("L&R") year is selected? If so, please explain in detail how a L&R year is selected in the context of a significant resource stack change. If not, please explain what an adjusted case means and how it would be used to guide the calculations. RESPONSE TO REQUEST FOR PRODUCTION NO. 2: The Blacks Creek Power Purchase Agreement ("PPA") is a twenty-year contract, and the proposed payment structure analysis (Attachment No. 3 to the Application) is based upon the project's commercial operation date and contribution to the Company's timing of highest risk for L&R year 2028. If a significant resource stack change is expected in the near term (e.g., calendar year 2029) that significantly shifts the monthly weighted average LOLE distribution, the values calculated for 2028 would be adjusted to account for the 2029 impact. At the time of the Blacks Creek PPA execution, Idaho Power was assessing potential resources in the 2027 Request for Proposal ("RFP") process. Two potential 2027 RFP projects were modeled as being online in 2028 as Idaho Power knows resources will be selected in the 2027 RFP to fill the capacity shortfall; the resulting LOLE values were then considered in the monthly weighted average LOLE calculation. Also, Idaho Power has industrial customers whose load is ramping during the 2028 L&R year. These load ramps cause the forecasted peak load in January and February to be significantly less than expected once the load ramps have concluded. Because the Blacks Creek PPA is IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY-4 a 20-year contract, the monthly weighted average LOLE calculation was adjusted to account for the eventual conclusion of the industrial customer load ramps. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 5 REQUEST FOR PRODUCTION NO. 3: In this case, Blacks Creek project is expected to come online in December 31 , 2027, and thus Year 2028 (the year after the online date) is used to determine the months of capacity need. In Case No. IPC-E-24-01, the Pleasant Valley Solar 2 project was expected to come online in December 31, 2026, but the Company used Year 2026 (the year before the online date) to determine the months of capacity needs. Please explain why the Company changed the method in this case. RESPONSE TO REQUEST FOR PRODUCTION NO. 3: As a point of clarification, the methodology used to select the L&R year for the proposed payment structure analysis has not changed between Case No. IPC-E-24-01 and Case No. IPC-E-24-42. As noted in the Company's Response to Request for Production No. 2, the proposed payment structure analysis included in Attachment No. 3 to the Application is based upon the project's commercial operation date ("COD") and contribution to the Company's timing of highest risk. The Blacks Creek Power project COD is December 31, 2027. As a result, the Blacks Creek project would not contribute to the 2027 highest-risk summer season, so a 2028 L&R was utilized. The Pleasant Valley Solar 2 project's COD was December 31, 2026; however, in Case No. IPC-E-24-20, the Commission approved that the COD date be changed to May 31, 2026. Therefore, the Pleasant Valley Solar 2 project will be online and contributing to the 2026 highest-risk summer season. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 6 REQUEST FOR PRODUCTION NO. 4: In Attachment No. 3 of the Application, the Company states that "[i]n 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." Please respond to the following: a. Please explain in detail how adjustments were made; b. Please explain how the projected near-term load and resource buildout affected the adjustments; c. Please define "future years"; and d. Please explain how the adjusted 2028 monthly LOLE in Table 2 of Attachment No. 3 of the Application better reflected the expected LOLE distribution of future years. RESPONSE TO REQUEST FOR PRODUCTION NO. 4: a. For the Blacks Creek project, incorporation of the projected resources and load ramp adjustments described in the Company's Response to Request for Production No. 2 were done through a separate LOLE simulation where those adjustments were incorporated. These modified LOLE values were used to produce Table 2 in Attachment No. 3 of the Application. b. Incorporation of the projected near-term L&R buildout was the adjustment made to the LOLE analysis. These were the only adjustments applied and utilized in the remainder of the analysis; only Table 1 of Attachment No. 3 of the Application contains results prior to any adjustments. c. "Future years" refers to years that have not yet occurred. For the Blacks Creek project analysis, "future years" ranged from 2027 to the early 2030s. d. Please see the Company's Response to Request for Production No. 2. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 7 The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 8 REQUEST FOR PRODUCTION NO. 5: In Attachment No. 3 of the Application, the Company states that "[t]he twelve months of the calendar year are grouped into three different periods given their Loss of Load Probability ("LOLP") profiles. Please respond to the following: a. Please provide the LOLP profiles; b. Please explain how the LOLP profiles are generated; c. Please explain whether the LOLP profiles are based on L&R Year of 2028; d. Please explain the relationship between the LOLP profiles and the original 2028 monthly LOLE in Table 1 of Attachment No. 3 of the Application; e. Please explain the relationship between the LOLP profiles and the adjusted 2028 monthly LOLE in Table 2 of Attachment No. 3 of the Application; and f. Please explain how the LOLP profiles guided the grouping into three different periods (i.e. Summer, Winter, and Off-Season). RESPONSE TO REQUEST FOR PRODUCTION NO. 5: a. Please see the file labeled "Response to Request for Production No. 5" for the requested Loss of Load Probability ("LOLP") profiles. b. As presented in the December 8th, 2022, Integrated Resource Plan Advisory Council virtual meeting for the Reliability and Capacity Assessment topic (and available on Idaho Power's website under the 20-Year Plan Educational Resources), the LOLP is the probability of the system peak or hourly demand exceeding the available generating capacity during a given period. The LOLP values are an output of the Company's Reliability and Capacity Assessment Tool ("RCAT"). IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 9 c. Yes, the LOLP profiles in the file labeled "Response to Request for Production No. 5" are based on the 2028 L&R year. d. The 2028 monthly LOLE values in Table 1 of Attachment No. 3 of the Application are the resulting LOLE calculations before any adjustments. These adjustments are described in the Company's Response to Request for Production No. 2. The LOLP profiles provided in the file labeled "Response to Request for Production No. 5" correspond with the simulation performed after adjustments were made to the load and resource buildout. Please note that to calculate a LOLE of a particular month, the maximum LOLP value for each day in that specified month are summed together. e. After making load and resource buildout adjustments, the 2028 monthly LOLE weighted average values in Table 2 of Attachment No. 3 of the Application are the resulting LOLE calculations. These adjustments are described in the Company's Response to Request for Production No. 2. The LOLP profiles provided in the file labeled "Response to Request for Production No. 5" are from the same simulation performed to develop the information provided in Table 2 of Attachment No. 3 of the Application. f. Please note that the LOLP profiles do not guide the seasonal grouping; the three periods (Summer, Winter, and Off-Season) are selected before the analysis. As noted in part d. of this response, please note that the maximum LOLP value for each day in that specified month is summed together to calculate the LOLE of a particular month. Once the adjusted monthly LOLE values are obtained and the weighted average calculation performed, the values are condensed into the three IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 10 different periods as described in Attachment No. 3 of the Application. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 11 REQUEST FOR PRODUCTION NO. 6: In Attachment No. 3 of the Application, the Company states that "[b]ecause 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." Please explain the relationship between the LOLP profiles used in this step and the LOLP profiles used in the grouping step that generated the adjusted 2028 monthly LOLE in Table 2 of Attachment No. 3 of the Application. RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The LOLP profiles are the same LOLP profiles used to generate the 2028 monthly LOLE weighted average values from Table 2 of Attachment No. 3 of the Application. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 12 REQUEST FOR PRODUCTION NO. 7: In Attachment No. 3 of the Application, the Company states that the capacity contribution of the Blacks Creek project is 18.44%. Please explain what capacity contribution represents, how this value is determined, and why it is significantly lower than the capacity contributions of the Pleasant Valley Solar project (31.21%) and Pleasant Valley Solar 2 project (31.54%). RESPONSE TO REQUEST FOR PRODUCTION NO. 7: As presented in the December 8, 2022, Integrated Resource Plan Advisory Council virtual meeting for the Reliability and Capacity Assessment topic (and available on Idaho Power's website under the 20-Year Plan Educational Resources), the capacity contribution of variable or energy- limited generation is its ability to reliably meet demand during high-risk hours; capacity value is measured either in terms of physical capacity or the fraction of the power plant's nameplate capacity. The Effective Load Carrying Capability ("ELCC") methodology concept provides a way to assess the capacity value of a given resource. ELCC can be defined as the equivalent perfect capacity needed to improve the system's reliability by the same amount as a particular generator. The ELCC of a given resource is calculated by determining the reliability without the selected generator and then including it in the system to calculate the reliability again. An improvement will be seen; the delta between these two scenarios divided by the resource nameplate is its ELCC. The capacity contribution calculation is dependent on the resource type and selected L&R buildout. Please note that the Pleasant Valley Solar project has a COD of 2025, the Pleasant Valley Solar 2 project has a COD of 2026, and the Blacks Creek Solar project has a COD of 2027. Idaho Power has published an RFP for each year listed, meaning the resource buildout is changing considerably each year. The capacity IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 13 contribution of the Blacks Creek project is lower than the Pleasant Valley Solar projects due to differing L&R years, changing resource buildouts, and load growth. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 14 REQUEST FOR PRODUCTION NO. 8: According to Table 5 of Attachment No. 3 of the Application, the annual payment is distributed to each month based on 2028 seasonal monthly LOLE, regardless of Black Creek's generation capabilities. Please respond to the following: a. Under normal circumstances, how well does the project's generation capabilities align with the Company's 2028 seasonal monthly LOLE? b. Under normal circumstances, how well does the project's generation capabilities align with the capacity contribution of 18.44%? c. The total annual payment is based on the capacity contribution of 18.44%, which will be further reduced if the measured output does not match the expected output based on Performance Ratio metric. Please explain how well the capacity contribution of 18.44% aligns with the expected output based on Performance Ratio metric. RESPONSE TO REQUEST FOR PRODUCTION NO. 8: a. A project's hourly generation capabilities are not comparable to seasonal monthly LOLE results. The project generation is an input to the LOLE calculation. For the Blacks Creek project, Idaho Power assumes its generation capabilities will be similar to the Company's existing utility-scale solar fleet. b. A project's hourly generation capabilities are not comparable to its annual capacity contribution. The project generation is an input to the LOLE calculation, and the project's capacity contribution or ELCC calculation requires two separate LOLE simulations. The Company's Response to Request for Production No. 7 explains the ELCC calculation. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 15 c. As a point of clarification, the capacity contribution is utilized to determine the annual payment; once the annual payment is determined, the performance ratio metric can be applied. Therefore, the capacity contribution is "locked in." for the term of the PPA. As described in Attachment No. 3 of the Application, the performance ratio measures the actual system performance compared to its expected output. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 16 REQUEST FOR PRODUCTION NO. 9: Please explain why the Performance Ratio Target for summer months is lower than that for non-summer months. RESPONSE TO REQUEST FOR PRODUCTION NO. 9: As described in Attachment No. 3 of the Application, Idaho Power selected a lower target for the summer months to account for the impact of temperature on the performance ratio calculation. While solar energy potential is higher in the summer months, the lower efficiency due to increased temperatures (which reduces the voltage of the solar cells) and other environmental factors lead to lower generation output for the same irradiance level compared to the winter months. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 17 REQUEST FOR PRODUCTION NO. 10: What are the advantages of using the 2028 Seasonal Monthly LOLE in Table 4 overusing the adjusted 2028 Monthly LOLE in Table 2 or the original 2028 Monthly LOLE in Table 1? RESPONSE TO REQUEST FOR PRODUCTION NO. 10: The advantage of utilizing the 2028 seasonal monthly LOLE weighted average values from Table 4 of Attachment 3 instead of the 2028 average monthly LOLE from Table 1 is that it accounts for a more accurate representation of Idaho Power's system over the defined future years through adjustment in the L&R buildout; for more information regarding the L&R buildout adjustments, please see the Company's Response to Request for Production No. 2. Please note that the total annual payment remains the same regardless of which LOLE distribution is utilized to inform the monthly payment. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 18 REQUEST FOR PRODUCTION NO. 11: Attachment No. 3 of the Application states that the Performance Ratio metric will be calculated based on the high LOLP hours from the timing of highest risk analysis published in the 2023 IRP. Please respond to the following: a. Please provide the LOLP profiles that contain the high LOLP hours and explain whether they are based on Year 2028; b. Please explain the relationship between the LOLP profiles in this request and the LOLP profiles used to smooth the summer period spread in Table 4 of Attachment No. 3 of the Application; and c. Please explain the relationship between the LOLP profiles in this request and the LOLP profiles used in the grouping step that generated the adjusted 2028 monthly LOLE in Table 2 of Attachment No. 3 of the Application. RESPONSE TO REQUEST FOR PRODUCTION NO. 11: a. The LOLP profiles in this request are based on 2028 L&R year, as described (and provided) in the Company's Response to Request for Production No. 5. The baseline for the identified high LOLP hours was published and acknowledged in Case No. IPC-E-23-23. The Company's timing of highest risk from the 2023 Integrated Resource Plan ("IRP") was utilized to inform the identified high LOLP hours as a guideline for representing Idaho Power's system capacity need while accurately measuring the project's performance. Because the Company's 2023 IRP timing of highest risk serves as a baseline analysis, Idaho Power expanded the seasons and hours to capture hours of higher irradiance when determining the identified high LOLP hours. As discussed in the meeting between Idaho Power IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 19 and Idaho Public Utilities Commission Staff virtually held on June 6, 2024, for Case No. IPC-E-24-01, "The ELCC calculation accounts for the hours of highest risk, whereas the performance ratio metric is a ratio of energy output and energy available. Having a wider range of hours (more data points) in the performance ratio metric mitigates potential errors when dealing with small generation numbers (late evening hours and winter hours) without impacting the ELCC calculation." Please see pages 10-13 of the file labeled "Response to Request for Production No. 1" for further information regarding the purpose of the identified high LOLP hours. b. The LOLP profiles used to smooth the summer period spread in Table 4 of Attachment No. 3 of the Application are based on the 2028 L&R buildout utilizing information available prior to the filing of this case. The timing of highest risk from Case. No IPC-E-23-23 was based on the 2025 L&R buildout utilizing information available prior to filing the 2023 IRP. Both analyses utilize the Company's RCAT to calculate LOLP values. c. The LOLP profiles used to produce the 2028 monthly LOLE weighted average in Table 2 are the same LOLP profiles utilized to derive the 2028 seasonal LOLE weighted average in Table 4 (both from Attachment No. 3 of the Application). Please refer to the response to part b of this request. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 20 REQUEST FOR PRODUCTION NO. 12: Attachment No. 3 of the Application states that "[t]he 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... ." Please respond to the following: a. Please explain how the Performance Ratio metric is calculated based on the high LOLP hours; b. Please illustrate the calculation mathematically; c. Please explain how monthly Performance Ratios are calculated, which will be used to calculate payment reductions; d. Please provide detailed justifications for why non-risk hours (3pm-5pm for summer and 3pm-4pm for winter) are added to the risk-hour timeframes; and e. Please explain whether ratepayers are harmed when capacity payment is paid when capacity is not needed by the Company. RESPONSE TO REQUEST FOR PRODUCTION NO. 12: a. The performance ratio can be defined as the ratio of measured output to the expected output for a given reporting period based on the system nameplate rating. Project generation and the plane of array irradiance are hourly vectors, so only data from the identified high LOLP hours is considered in the performance ratio calculation. b. Please see the file labeled "Response to Request for Production No. 12" for an example of the performance ratio calculation in the month of July for a theoretical project. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 21 c. Please see the response to part b of this request. d. As described in part a of the Company's Response to Request for Production No. 11, the identified high LOLP hours consider both Idaho Power's system needs while accurately measuring the project's performance. As stated in footnotes 4 and 5 of Attachment No. 3 of the Application, the seasons and hours were expanded to reduce the solar generation measurement variability. e. Customers are not harmed by the monthly payment analysis performed in Attachment No. 3 of the Application. As described in part a of the Company's Response to Request for Production No. 11 and in part d of this response, the identified high LOLP hours consider both Idaho Power's system need while accurately measuring the project's performance. The total payment is based on the project ELCC calculation, which reflects the Company's capacity needs; a monthly payment reduction is only present when a project does not perform as expected. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 22 REQUEST FOR PRODUCTION NO. 13: Please respond to the following regarding Figure 2 of Attachment No. 3 of the Application: a. Please provide the linear regression curve formula behind the relationship between Performance Ratio and Effective Load Carrying Capability used to calculate payment reduction rate; b. Please explain how the relationship is determined; c. Please explain what input data is used to determine the relationship; and d. Please explain what the dots in Figure 2 represent. RESPONSE TO REQUEST FOR PRODUCTION NO. 13: a. Please note that the linear trendline included in Figure 2 of Attachment No. 3 of the Application is provided for informational purposes only. When calculating the payment reduction, linear interpolation between the data points is utilized, not the equation of the best-fit straight line. See the table below for the requested linear trendline equation and data behind the points. Performance Ratio 1.0 0.9 0.8 0.7 0.6 0.5 (Solar Output) Percentage of 100.00% 93.46% 85.96% 78.69% 70.22% 60.29% Original ELCC Linear Trendline y = 0.78727084x + 0.22391329 Equation b. To generate the data shown in Figure 2 of Attachment No. 3 of the Application, the ELCC of the Blacks Creek project generation is first calculated assuming a performance ratio of 100%. Then every hour of the Blacks Creek project generation is reduced to 90% of its original output and the ELCC calculation is reperformed to value the impact of a 0.9 performance ratio. When the output is IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 23 reduced, the ELCC value declines. This process is repeated for the performance ratio range of 0.5 to 1.0 in increments of 0.1 and produces the percentage of original ELCC values. c. The calculation to determine the relationship between the performance ratio and ELCC is conducted in the Company's RCAT. Idaho Power's system load and existing and projected resources are inputted into the RCAT, as described in the December 8th, 2022, Integrated Resource Plan Advisory Council virtual meeting for the Reliability and Capacity Assessment topic (and available on Idaho Power's website under the 20-Year Plan Educational Resources). d. The points in Figure 2 of Attachment No. 3 of the Application represent the relationship between the performance ratio and the ELCC. The percentage of original ELCC was calculated for a performance ratio range of 0.5 to 1.0 in increments of 0.1. Please see the table provided in response to part a of this request for production for the data behind the points. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 24 REQUEST FOR PRODUCTION NO. 14: Given Section 4.3.2, please confirm that the final nameplate capacity of the Facility cannot be below MW or above■ MW. RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Yes. Paragraph 1 .114 defines Required Percentage as ninety percent. The response to this Request is sponsored by Donovan Walker, Legal Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 25 REQUEST FOR PRODUCTION NO. 15: Exhibit 3 of the Power Purchase Agreement ("PPA") states that Please respond to the following: a. What is the cost of the-? b. Who pays for the cost of the-? c. Who pays for the cost of Operations and Maintenance ("O&M") of the-? d. What is the O&M rate? e. How is the O&M rate determined? f. Please provide a copy of the Generator Interconnection Agreement. RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Idaho Power's Large Generation Interconnection Process ("LGIP") can be found here: at the below address: https://www.idahopower.com/about-us/doing-business-with-us/generator- interconnection/large-generation-interconnection-process/. Idaho Power must comply with the provisions under the Company's Open Access Transmission Tariff ("OATT"), filed with the Federal Energy Regulatory Commission ("FERC") to accommodate interconnection processes, procedures, and rules. In summary, an Interconnection Customer, as owner of a Large Generating Facility, makes application to Idaho Power, in this case the Transmission Provider, to request interconnection to the Transmission System. A Large Generator Interconnection Agreement ("LGIA") is executed defining the terms and conditions, the scope of infrastructure improvements, applicable costs and responsibilities, timelines, and other key operational parameters. A copy of the LGIA and the First Amendment to the LGIA are included as response to f. below. The Facility's Point of Delivery and Metering Point IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 26 as defined in the Power Purchase Agreement ("PPA") are synonymous with the LGIA definition of Point of Interconnection, where the Interconnection Facilities connect to the Transmission Provider's Transmission System. a) The substation and other facility upgrades are described in the First Amendment to the LGIA in Exhibit A and are comprised of numerous components, including: i. Transmission Provider's Interconnection Facilities are facilities and equipment owned, controlled, or operated by the Transmission Provider from the Point of Change of Ownership to the Point of Interconnection and are sole use facilities and do not include Network Upgrades. The costs of these facilities are estimated to be $1,454, 951 . ii. Distribution Upgrades are the additions, modifications, and upgrades to the Transmission Provider's Distribution System required at or beyond the Point of Interconnection. The costs of these facilities are estimated to be $1,145,212. iii. Network Upgrades are the additions, modifications, and upgrades to the Transmission Provider's Transmission System required at or beyond the Point of Interconnection. The costs of these facilities are estimated to be $11,370,745. b) Each component identified in the response to part a are funded by the Interconnection Customer. The Interconnection Customer is entitled to a cash repayment, equal to the total amount paid to the Transmission Provider for the Network Upgrades for the non-usage sensitive portion of transmission charges, as payments are made under Transmission Provider's Tariff for transmission services IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 27 with respect to the Large Generating Facility. c) Retail and wholesale customers cover the cost of operating and maintaining the substation. Once the substation is operational, it is integrated into the Company's plant and managed like all other substations. d) No O&M rate is established for non-Qualifying Facilities. As described above, these facilities are incorporated into the Company's plant and maintained. e) — No O&M rate is established for these facilities. f) See file labeled "Response to Request for Production No. 15 — Confidential Attachment 1" for the LGIA and "Response to Request for Production No. 15 — Confidential Attachment 2" for the First Amendment to the LGIA. The response to this Request is sponsored by Eric Hackett, Project and Resource Development Director, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 28 REQUEST FOR PRODUCTION NO. 16: Section 1.126 stated the Scheduled Commercial Operation Date is ; however, the Parties shall work in good faith to move such date to if the Generator Interconnection Agreement back feed power milestone and limited operation study indicate that , is feasible. Please explain whether the LOLE values used in determining avoided cost of capacity will be affected if the Commercial Operation Date is changed. Specifically, will the LOLE values of the period from June 1, 2027, through May 31, 2028, be used, instead of the period from January 1, 2028, through December 31, 2028? Or will the LOLE values for the period from January 1, 2028, through December 31, 2028, be locked in when the PPA is executed? RESPONSE TO REQUEST FOR PRODUCTION NO. 16: If the COD for the Blacks Creek project were to change, Idaho Power would recalculate LOLE values based on the relevant L&R year. As described in the Company's Response to Request for Production No. 3, if the Blacks Creek project were to contribute to the 2027 highest risk season (summer), a 2027 L&R would be utilized. Idaho Power would submit a compliance filing requesting Commission approval of the revised capacity value based on the earlier COD. The LOLE values used for avoided capacity are for a calendar year under Idaho Power's current methodology. For example, if the project's COD is June 1, 2027, the LOLE values from January 1, 2027, through December 31, 2027, would be utilized in the avoided capacity analysis; if the project's COD is post-summer 2027, then the LOLE values from January 1, 2028, through December 31, 2028, would be used to calculate avoided capacity. This example assumes that 2027 and 2028 have the highest risk IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 29 season of summer. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 30 REQUEST FOR PRODUCTION NO. 17: Please describe the competitive procurement process used to procure the PPA and provide all other proposals considered in the procurement process. In your response, please explain whether the procurement process was conducted by Brisbie or the Company. If it was conducted by the Company, please explain how the process for selecting resources for Brisbie will not hurt the Company's opportunities of selecting resources to meet system needs. RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Blacks Creek was identified as a resource by Brisbie and brought to Idaho Power. Brisbie has a dedicated renewable energy team with significant experience in working with developers across the country to identify projects that meet its goal of supporting 100 percent of its operations by adding new renewable resources. Idaho Power did not conduct a competitive solicitation for the Blacks Creek resource. However, it is Idaho Power's understanding that Brisbie conducted its own RFP process to evaluate potential renewable projects. The pricing mechanisms in Bribie's approved Special Contract assure that Brisbie is responsible for the cost of the Blacks Creek resource and that other customers are not harmed by the same. Per Article 7, specifically Section 7.1 : Solicitation of Projects, in the Brisbie Special Contract, either the customer or Idaho Power may bring renewable projects to the table for consideration and negotiation. In Blacks Creek's case, the customer brought forward this project. As such, the project was not considered in Idaho Power's RFP process as a low-cost resource for Idaho Power system needs. The response to this Request is sponsored by Donovan Walker, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 31 REQUEST FOR PRODUCTION NO. 18: The Contract between Brisbie and the Company required that _ Special Contract at 25. Please explain whether this requirement has been met for the Blacks Creek. RESPONSE TO REQUEST FOR PRODUCTION NO. 18: This requirement has been met for the Blacks Creek project. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 32 REQUEST FOR PRODUCTION NO. 19: In Case Nos. IPC-E-22-29 (Pleasant Valley Solar) and IPC-E-24-01 (Pleasant Valley Solar 2), the definition of Market Price Index referenced a price for energy that is not delivered to a final point of delivery in a balancing authority area located entirely in Washington, to avoid potential impacts of Washington's Climate Commitment Act ("CCA"). Please respond to the following: a. Please explain why such references are removed in the definition of Market Price Index in this case; and b. Please explain whether and how Washington's CCA affects this PPA. RESPONSE TO REQUEST FOR PRODUCTION NO. 19: As an initial matter, Washington's Climate Commitment Act ("CCA") has no identified direct effect on this Power Purchase Agreement. a. The starting template for PPAs utilized with the Brisbie special contract was agreed to by the parties and filed with the Commission along with Brisbie's special contract. That template does not have the referred-to language regarding the Washington CCA. The definition of the Market Price Index in this agreement resulted from the comprehensive negotiations between the parties, including Meta and the Seller, regarding and considering all terms and conditions at issue. Certain changes from prior agreements, such as this one, may have been altered given the other compromises being considered. Modifying the definition of the Market Price Index to reference the CCA did not come up in negotiations, particularly since it has no direct impact on this PPA, and the language was not changed like it was in Pleasant Valley. b. The CCA has no identified direct effect on this Power Purchase Agreement. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 33 The response to this Request is sponsored by Camille Christen, Resource Acquisition, Planning, and Coordination Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 34 REQUEST FOR PRODUCTION NO. 20: Please explain whether Order No. 36383 in Case No. IPC-E-24-23 affects this case. RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Tariff Schedule 33, Sheet No. 33-3, states: "Pricing elements that rely on the most recently filed IRP are effective December 1, 2024, pursuant to Order No. 36383 issued on November 8, 2024." This provision applies to existing projects and therefore would apply to the Blacks Creek project upon the Commission's approval and addition to tariff Schedule 33. The response to this Request is sponsored by Grant T. Anderson, Regulatory Consultant, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 35 Respectfully submitted this 26th day of December 2024. DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 36 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 26th day of December 2024, 1 served a true and correct copy of Idaho Power Company's Response to the First Production Request of the Commission Staff to Idaho Power upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Chris.Burdin(a-),puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 37 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY REQUEST NO. 1 ATTACHMENT or IPC-3-24-01 Pleasant Valley Solar 2 Renewable Capacity Payment Structure Meeting with Idaho Public Utilities Commission Staff June 2024 -�IQAFIO R� Historical Test Years 1.) Which historical years are used to calculate the average LOLE in Table 1? Why are these years selected? Is there a change in the selection of historical years from Case No. IPC-E-21-42? Month TY 1 TY 2 TY 3 TY 4 TY 5 TY 6 TY 7 Average 2017 2018 2019 2020 2021 2022 2023 LOLE Case No. January 0.0026 0.0001 0.0006 0.0003 0.0006 0.0004 0.0003 0.000711 Test Years 1 1 22 February 0.0020 0.0000 0.0005 0.0007 0.0005 0.0001 0.0001 0.000554 March 0.0002 0.0001 0.0000 0.0001 0.0002 0.0001 0.0004 0.000155 April 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.000031 May 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.000006 Case No. 1 June 0.0039 0.0081 0.0386 0.0051 0.0087 0.0050 0.0019 0.010193 July 0.0718 0.0547 0.0457 0.0446 0.0711 0.0749 0.0797 0.063225 YearsTest 11 23 August 0.0091 0.0069 0.0082 0.0187 0.0064 0.0161 0.0035 0.009844 September 0.0016 0.0025 0.0008 0.0004 0.0008 0.0003 0.0005 0.000994 October 0.0001 0.0004 0.0000 0.0001 0.0000 0.0000 0.0000 0.000099 November 0.0023 0.0116 0.0029 0.0037 0.0025 0.0014 0.0047 0.004159 December 0.0061 0.0150 0.0023 0.0256 0.0092 0.0008 0.0088 0.009680 Data that supports Table 1 of IPC-E-24-01 2 Resource StackChanges — Part 1 %6 Q§IQAO R. 2.) What does this statement mean? "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". Month 2023 2027 2027 Case • 1 . Average LOLE Average LOLE Weighted LOLE Idaho ' • • • liance Filing 12/23/2022 January 0.0011 0.2309 2.74% "Idaho Power is expecting a considerable shift in its February 0.0001 0.0148 0.18% March 0.0000 0.0004 0.00% load • - • captur April 0.0000 0.0000 0.00% changethis • ' ' a 2027 • to May 0.0000 0.0000 0.00% obtain the aver- ' " and weighted monthly LOL June 0.0167 0.5088 6.05% shownvalues as • - July 0.1113 2.9850 35.47% August 0.0258 1.0587 12.58% September 0.0034 0.1477 1.76% October 0.0001 0.0351 0.42% November 0.0042 1.3934 16.56% December 0.0062 2.0399 24.24% Combined Table 1 & Table 2 of IPC-E-22-06 Resource StackChanges — Part 2 %6 Q§IQAO R. 2.) What does this statement mean? "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". • . , Month 2026 2026 2026 Case N . Average LOLE Modified LOLE Weighted Average Idaho Power's • • January 0.000711 0.006920 6.17% "IdahoexpectingowerrampFebruary 0.000554 0.006920 6.17% load during 2026, meanexpected JanuaryMarch 0.000155 0.000155 0.14% 2026 is significantly lower • • expected in April - - _ December 2026. To annualize for . of May - - _ industrial . ramp, the average LOLE value of months June 0.010193 0.010193 9.09% November December _ d for January and July 0.063225 0.063225 56.36% February. 126 L&R with August 0.009844 0.009844 8.77% industrial load annualizing adjustment applied to January September 0.000994 0.000994 0.89% Februaryand weighted October 0.000099 0.000099 0.09% averages are listed in Table 2." November 0.004159 0.004159 3.71% December 0.009680 0.009680 8.63% Combined Table 1 & Table 2 of IPC-E-24-01 (with data supporting Table 2) PVS 2Online -�IQAHO R, Date 3.) Which month of 2026 is PVS 2 expected to come online? CommercialOperations Date _ mw��� Current COD: December 2026 Adjusted COD: June 2026 As Requested in Case No. IPC-E-24-20 2026 Load & Resource Year Q§IQAFIO POWER. 4.) In determining average LOLE in Table 2, why does the Company select 2026, where the first few months (before the first online date) do not have the generation of PVS 2? Why doesn't the Company select a later year such as 2027, where all months have the generation of PVS 2? Case • IPC-E-24-01 Expected L&R Year CEYW Project Idaho ' • wer's Compliance F Online for • • Idaho Power has utilized the in-service date as the load & resourcefor past 3 CEYW analyses IPC-E-22-06 Black Mesa Solar June 2023 2023 • The further out into the future, the more unknown resources there are IPC-E-21-42 Pleasant Valley Solar 1 March 2025 2025 IPC-E-24-01 Pleasant Valley Solar 2 June* 2026 2026 *Adjusted COD as requested in Case No. IPC-E-24-20 . -�IQAHO R. Inust ari I Load 5.) Why is it necessary to annualize for the impact of the industrial load ramp? What's the consequence of not annualizing it? IPC-E-21-42 IPC-E-21-42 IPC-E-24-01 IPC-E-24-01 04/05/2023 04/05/2023 03/07/2024 03/07/2024 Allows • • - reasonable Month 70th percentile Industrial Load 701h Percentile Industrial Load reflectionof • 2025 2025 2026 2026 contribution to LOLE calculationover January 2,567.07 56.52 2,621.94 73.31 contractthe 20-year period February 2,390.72 62.23 2,518.06 88.20 industrial load ramps are expecteV March 2,242.27 48.36 2,472.92 103.09 April 2,634.70 67.83 2,695.29 120.99 May 2,749.41 84.20 2,774.93 135.87 June 3,787.57 84.57 4,090.13 154.73 July 4,000.66 121.58 4,146.84 171.57 August 3,729.08 135.83 3,812.78 189.47 September 3,267.93 129.03 3,280.71 206.50 October 2,493.99 157.17 2,455.51 223.78 Load forecasts& corresponding industrial load ramp forecast utilized November 2,482.65 171.42 2,556.04 243.15 in IPC-E-21-42& IPC-E-24-01 (values in MW) December 2,656.47 171.37 2,813.49 267.22 -�IQAHO R® Annualization 6.) Why are only January and February selected for annualization? Why not March, April, May, etc.? 03/07/2024 03/07/2024 03/07/2024 03/07/2024 Month 70t" Percentile Industrial Load 70t" Percentile Industrial Load 2026 2026 2027 2027 January 2,621.94 73.31 2,863.66 286.58 monthsAnnualizing February 2,518.06 88.20 2,759.30 306.14 minimal risk contribution March 2,472.92 103.09 2,705.06 315.30 (March-May & • • April 2,695.29 120.99 2,917.77 327.48 October) ill produce May 2,774.93 135.87 3,001.21 339.79 significantlyJune 4,090.13 154.73 4,332.38 355.99 July 4,146.84 171.57 4,385.84 367.10 August 3,812.78 189.47 4,047.04 376.78 September 3,280.71 206.50 3,487.38 380.55 October 2,455.51 223.78 2,632.50 379.21 November 2,556.04 243.15 2,720.65 387.94 Load forecast& corresponding industrial load ramp forecast utilized in IPC-E-24-01 (values in MW) December 2,813.49 267.22 2,961.57 399.67 -�IQAHO R. CapacityContra ution 7.) The capacity contribution calculated at the time of contract execution (December 5, 2023) was 31.54%. How was the value determined? PVS 2 Nameplate: 125 MW Outage Table Test Year Base Add PVS 2 Hybrid Load Shape 2017 (194) MW (146) MW LOLE Threshold 2018 (135) MW (93) MW 2019 (231) MW (202) MW Perfect Generator I 2020 (158) MW (121) MW (PerfectResource ,—Perfect, , N 2021 (277) MW (231) MW Outage Table 2022 (384) MW (343) MW Hybrid Load Shape 2023 (286) MW (253) MW rim • Average (238) MW (198) MW E LCC Perfect Generator 2- 39.43 MW ELCC results by test year for IPC-E-24-01 utilizing Idaho Power's Reliability& Capacity Assessment Tool("RCAT") 31.54 HighLOLP Hours — Part 1 %6 Q§IQAHO POWER. 8.) "The Performance Ratio metric will be calculated based on the high LOLP hours from the timing of highest risk analysis published in the 2023 IRP." Does that mean the high LOLP hours from the 2026 L&R Year? If not, please explain why the method deviates from the method used in Case No. IPC-E-21-42? calculationCEYW Project High LOLP Hour The ELCC • for Black Mesa • No Company-filed highest-risk hours available hours of highest risk, whereas IPC-E-22-06 • High LOLP hours calculated specifically for performance - • - • of Solar Case No. IPC-E-22-06 via the Company's RCAT energy output and energy available. Having a wider • - of • (more Pleasant Valley • No Company-filed highest-risk hours available data points) - performance rati • IPC-E-21-42 Solar 1 ' High LOLP hours from Case No. IPC-E-22-06 utilized for Case No. IPC-E-21-42 metric mitigatespotential errors dealingwith smallgeneration numbers Pleasant Valley ' 2023 IRP publishes highest-risk hours - evening hours and winter hours) IPC-E-24-01 • 2023 IRP highest-risk hours implemented & without Solar 2 cting the ELCC calculation adjusted for Case No. IPC-E-24-01 • - 10 HighLOLP Hours — Part 2 %6 Q§IQAHO POWER. 8.) "The Performance Ratio metric will be calculated based on the high LOLP hours from the timing of highest risk analysis published in the 2023 IRP." Does that mean the high LOLP hours from the 2026 L&R Year? If not, please explain why the method deviates from the method used in Case No. IPC-E-21-42? Period High LOLP Hours Notes Summer 5:00 P M - 11:00 P M These are the highest risk hours as published in the 2023 IRP Wlnter(Morning-Peak) 6:OOAM - 12:OOPM First timestamp is hour beginning and second timestamp is hour ending. Wlrlter(Evening-Peak) 4:OOPM - 9:OOPM 4:OOPM - 9:OOPM is the period of time that starts at 4:OOPM and ends at 9:OOPM Period High LOLP Hours Notes Summer 3:OOPM - 11:00PM Include hours 3:00-5:OOPM for CEYW summer data analysis, September will use summer hours winter(Morning-Peak) 6:OOAM - 12:OOPM Winter hours not adjusted, some as 2023 IRP; March & October will use winter hours WI nter(Evening-Peak) 3:OOPM - 9:OOPM Include hours 3:00-4:OOPM for CEYW winter data analysis, March & October will use winter hours High LOLP hours for Case No. IPC-E-24-01 (summer includes June—September, winter includes November-February 11 HighLOLP Hours — Part 3 Q§IQAHO POWER. 8.) "The Performance Ratio metric will be calculated based on the high LOLP hours from the timing of highest risk analysis published in the 2023 IRP." Does that mean the high LOLP hours from the 2026 L&R Year? If not, please explain why the method deviates from the method used in Case No. IPC-E-21-42? N Period Months High LOLP Hours N Summer Jun - Jul - Aug - Sep 2:OOPM - 11:00PM W Wlrlter(Morning-Peak) Jan - Feb - Oct - Nov - Dec 6:OOAM - 11:00AM (, a_ Winter(Evening-Peak) Jan - Feb - Oct - Nov - Dec 5:OOPM - 10:OOPM r, Period High LOLP Hours 0 NSummer Jun - Jul - Aug - Sep 3:OOPM - 11:00PM W Winter(Morning-Peak) Jan - Feb - Mar - Oct - Nov - Dec 6:OOAM - 12:OOPM a — Winter(Evening-Peak) Jan - Feb - Mar - Oct - Nov - Dec 3:OOPM - 9:OOPM Comparison of high LOLP hours from Case No. IPC-E-21-42& Case No. IPC-E-24-01 12 Solar Measurement Variability N6 em IQAHO R. 9.) The footnotes of Table 8 explained how "solar generation measurement variability" is reduced. Please provide an example to illustrate the method. 1 0.9 0.8 a 0.7 O 0.6 ca 0 C/) 0.5 m 0.4 E Z 0.3 0.2 0.1 Hour of day reflects hour ending timestamps, i.e., hour 18 represents the hour from 5:OOPM—6:OOPM 0 2 4 6 8 10 12 14 16 18 20 22 24 Hour of Day 13 ELCC & Performance Ratio c@ IQAHO POWER, 10.) How is the relationship between PR value and percentage of original ELCC determined? Why is the relationship the same as the relationship in Case No. IPC-E-21-42? The relationship between the PIR IPC-E-21-24 IPC-E-24-01 percentagevalue & the of original Performance ELCC Performance ELCC reducingELCC is determined by Ratio (Out of Original) Ratio (Out of Original) solarthe • - . 1 hourly data) by _ specified percentage, 0.5 54.21% 0.5 53.26% recalculating the ELCC 0.6 64.26% 0.6 63.77% 0.7 73.84% 0.7 73.19% 0.8 82.96% 0.8 83.33 0.9 91.61% 0.9 92.03% 1.0 100.00% 1.0 100.00 Data supporting Figure 2. Relationship Between PR& ELCC for both IPC-E-21-42& IPC-E-24-01 Payment Reduction N6 Q§IQAO R. 11.) Is the "Payment Reduction" column in Table 9 the same as the ELCC reduction values in Figure 2? Case No. IPC-E-24-01 Idaho Power's Compliance "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 " value for • I PC-E-24-01 (Yi — APerformance Ratio ELCC (Out of Original) y = yo + (x — xo) x1 — xo 0.5 53.26% 0.6 63.77% 1.0 — 0.9203 0.7 73.19% y = 0.9203 + (0.98 — 0.9) = 98.4% 1.0 — 0.9 0.8 83.33% 0.9 92.03/o Payment Reduction = 100% — 98.4% = 1.6% 1.0 100.00% 15 ELCC & Performance Ratio Targets N6 Q§IQAHO POWER. 12.) Are the ELCC reduction values calculated by the difference between 100% and the actual PR's Y axis value for January through May and October through December, where PR Target is greater than 1.0? 13.) Are the ELCC reduction values calculated by the difference between 0.95 PR's Y axis value and the actual PR's Y axis value for June through September, where PR Target is greater than 0.95? Power'sCase No. IPC-E-24-01 Idaho - targetELCC reduction values are calculated in RCAT The PR • be LinearELCC reduction is only applied when the specified PR target is not met - • • • n is then utilized The summer target is lowered to account for temperature impact on solar generation 16 ELCC & Performance Ratio Targets %6 Q§IQAHO POWER, 13.) Are the ELCC reduction values calculated by the difference between 0.95 PR's Y axis value and the actual PR's Y axis value for June through September, where PR Target is greater than 0.95? IPC-E-24-01 Month Performance Payment Monthly Performance Ratio ELCC (Out of Original) Ratio Reduction Payment 0.9 92.03% January 1 .08 0.00% $324,271 1.0 100.00% February 1 .13 0.00% $324,271 March 1 .08 0.00% $17,294 Yi — Yo April - - - y = Yo + (x — xo) May - (Xj — xo June 0.94 0.8% $9521162 y 0.9203 + (0.95 — 0.9) 1.0 — 0.9203 � 96.0% July 1 .00 0.00% $1 ,919,682 = 1.0 - 0.9 August 0.99 0.00% $959,841 September 0.97 0.00% $17,294 y 0.9203 + (0.94 — 0.9) 1.0 — 0.9203 95.2 /o N o October 1 .01 0.00% $17,294 = � 1.0 - 0.9 November 1 .11 0.00% $324,271 December 0.98 1.60% $319,082 Payment Reduction = 96.0% — 95.2% = 0.8% Total $5,175,463 Payment Reduction Example 14.) Why is the Payment Reduction for December 1.6% in Table 9 in this case, whereas the value • The data in Table 9 only serves as an example 18 • 1.6% in IPC-E-24-01 was calculated based on the data in Figure 2 • 1.8% was calculated based on the Figure 2 data from IPC-E-22-06 & carried forward to IPC-E-21-42 since Table 9 is an example only -�IQAFIO R� Performance Ratio Adjustment 15.) Revised Exhibit 3.1 in Case No. IPC-E-21-42 defined "Performance Ratio Adjustment Factor" as the adjustment to be applied to the Monthly Unadjusted Renewable Capacity Credit and is determined at time of execution of the Renewable Resource PPA or the Parties' agreement to procure or construct the Idaho Power-owned renewable resource..." Please confirm that such "Performance Ratio Adjustment Factor" refers to the relationship between PR levels and ELCC reductions as described in Figure 2, not the specific payment reduction percentages which are determined by each month's actual performance. specificCase No. IPC-E-24-01 Idaho Power's Compliance The payment reductionpercentage will be determined each monthnot BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY REQUEST NO. 5 ATTACHMENT SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY REQUEST NO. 12 ATTACHMENT SEE ATTACHED SPREADSHEET BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 15 ATTACHMENT NO. 1 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 15 ATTACHMENT NO. 2