Application.tif

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-24-45
Idaho Power Company’s Application for a Certificate of Public Convenience and
Necessity for Two Battery Storage Facilities
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Direct Testimony of Eric Hackett and Exhibits 2, 3, 4, and 5 of the
Direct Testimony of Eric Hackett dated December 27, 2024, contain information
that Idaho Power Company and a third party claim are trade secrets, business
records of a private enterprise require by law to be submitted to or inspected by a
public agency, and/or 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 27th day of December 2024.
Donovan E. Walker
Attorney for Idaho Power Company
APPLICATION - 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR TWO BATTERY
STORAGE FACILITIES.
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CASE NO. IPC-E-24-45

APPLICATION

Idaho Power Company (“Idaho Power” or “Company”), in accordance with Idaho
Code §§ 61-501, 61-502, 61-503, 61-508, 61-526; as well as Rule of Procedure (“RP”)
52, 112 and 201 hereby respectfully makes application to the Idaho Public Utilities
Commission (“Commission” or “IPUC”) for an order granting the Company a Certificate
of Public Convenience and Necessity (“CPCN” or “Certificate”) to acquire new
dispatchable energy storage providing a total of 100 megawatts (“MW”) of operating
capacity. Approval of this request is necessary to position Idaho Power to meet its
obligation to provide safe, reliable service to its customers.
APPLICATION - 2
Accompanying this Application are two sets of testimony. The Direct Testimony of
Jared L. Ellsworth presents the Company’s need for new resources to meet an identified
capacity deficit in 2026 as informed by the 2021 Integrated Resource Plan (“IRP”), again
in the 2023 IRP, and subsequently further enhanced through system reliability
evaluations. Mr. Ellsworth describes the most recent assessment of system reliability and
its impact to the capacity deficit identified in the 2023 IRP, which led to the solicitation
through a Request for Proposals (“RFP”) seeking to acquire energy and capacity
necessary to address the identified near-term capacity needs. The Direct Testimony of
Eric Hackett provides an overview of the competitive resource acquisition process
undertaken to meet Idaho Power’s identified capacity deficiency in 2026, and the resulting
fair and competitive RFP process that was fully compliant with the required Oregon
resource procurement rules, leading to the selection of least-cost, least-risk resources
necessary to meet the Company’s electric energy needs in 2026, including two alternative
resources for which Idaho Power is requesting the Commission grant a CPCN in this
proceeding.
I. CORPORATE STATUS
1. Idaho Power is a corporation incorporated under the laws of the state of
Idaho. Idaho Power is engaged in the business of generating, purchasing, transmitting,
and distributing electric energy and providing retail electric service in the states of Idaho
and Oregon. Idaho Power’s principal offices are situated in Boise, Idaho, and its address
is 1221 West Idaho Street, Boise, Idaho 83702. Copies of Idaho Power’s Articles of
Incorporation and Certificates of Convenience and Necessity are on file with the
Commission. Idaho Code § 61-528.
APPLICATION - 3
II. BACKGROUND
2. Idaho Power was generally resource-sufficient since the addition of the
Langley Gulch natural-gas fired power plant more than a decade ago until the filing of the
2021 IRP. That is, Idaho Power’s owned generation and transmission resources, along
with negotiated purchases under Power Purchase Agreements (“PPA”) and mandatory
purchases under the Public Utility Regulatory Policies Act of 1978, were sufficient to meet
the Company’s load growth over that time. However, as described more completely in the
Direct Testimony of Mr. Ellsworth, several dynamic and converging factors, including
third-party transmission capacity constraints, load growth, and a decline in the peak-
serving effectiveness of certain supply-side and demand-side resources led the Company
to file consecutive requests for CPCNs to acquire resources to be online in 2023,1 2024,2
2025,3 and 2026.4 Idaho Power expects to acquire additional resources each year
thereafter through (at least) 2028. See, OPUC Case No. UM 2317, In the Matter of Idaho
Power Company’s Application for Approval of 2028 All-Source Request for Proposals to
Meet 2028 Capacity Resource Need.
3. Under Idaho law, Idaho Power has an obligation to provide adequate,
efficient, just, and reasonable service on a nondiscriminatory basis to all those that
request it within its service area. Idaho Power has experienced and expects sustained
load growth, thereby requiring the addition of new resources. To meet its obligation to
reliably serve customer load and fill capacity deficiencies identified in 2026 and 2027, the
Company conducted a competitive solicitation through the issuance of an All-Source RFP

1 Case No. IPC-E-22-13.
2 Case Nos. IPC-E-23-05 and IPC-E-23-20.
3 Case No. IPC-E-23-20.
4 Case No. IPC-E-24-16.
APPLICATION - 4
seeking to acquire a combination of energy and capacity resources. Idaho Power did not
define the type of resource (i.e., wind, solar, gas, or battery storage) desired; however,
the Company outlined that the deficit could require as much as 1,100 megawatts (“MW”)
of variable energy resources and a minimum of 350 MW of peak capacity to help meet
Idaho Power’s previously identified capacity needs in 2026 and 2027 (“2026 RFP”). The
procurement process resulted in the identification of least-cost, least-risk resources
necessary to fill the identified 2026 capacity deficiency of 236 MW. The proposed
acquisitions, as described herein, are necessary and required in order to continue to
provide reliable and adequate electric service to Idaho Power’s customers starting in the
summer of 2026 and into the future.
III. OREGON PROCUREMENT RULES
4. The Commission, in Case No. IPC-E-10-03, initiated a case seeking to
establish competitive bidding guidelines for the RFP process. In 2013, the Commission
closed Case No. IPC-E-10-03 without establishing Idaho-specific resource procurement
guidelines, but rather directing Idaho Power to follow the RFP guidelines applicable to its
Oregon service territory. The Oregon RFP guidelines to which the Commission referred
were later codified into the administrative rules of the Public Utility Commission of Oregon
(“OPUC”) resource procurement rules.5 The OPUC resource procurement rules impose
competitive bidding requirements upon an electric utility for the “acquisition of a resource
or a contract for more than an aggregate of 80 MWs and five years in length,” among
other requirements.

5 Oregon Administrative Rule (“OAR”) 860-089-0010 et seq.
APPLICATION - 5
5. On September 15, 2022, Idaho Power filed an Application with the OPUC
initiating a rule compliant RFP process to acquire resources to be online in 2026 and
2027. Subsequently an independent evaluator was appointed, and the Company went
through all the required steps associated with issuance of the RFP, receipt and evaluation
of bids, and ultimately the approval of a final shortlist of prospective projects to meet the
2026 and 2027 deficits. The OPUC found that Idaho Power conducted a fair and
competitive resource acquisition procurement process in accordance with the OPUC
competitive bidding rules, which resulted in OPUC approval of a final shortlist of the least-
cost, least-risk resources. OPUC Order No. 24-055, Docket UM 2255, Feb. 22, 2024.
The Company used the results from that approved final shortlist, selecting two of the most
cost-effective projects identified through the extensive competitive bidding process but
was unable to contract from the final shortlist additional resources necessary to meet the
remaining 2026 capacity deficiency. As a result, Idaho Power procured two alternative
resources that will provide for the least-cost and least-risk resources necessary and
required to timely meet the Company’s resource needs and for which Idaho Power is
requesting the Commission grant a CPCN in this proceeding.
IV. RESOURCE PROCUREMENT PROCESS
6. On September 15, 2022, Idaho Power commenced the competitive bidding
process, filing a request with the OPUC to (1) open a docket for approval of the 2026
RFP, (2) appoint an Independent Evaluator (“IE”) to oversee the RFP process, and (3)
approve the proposed 2026 RFP scoring and modeling. On December 27, 2022, the
OPUC approved the selection of London Economics International, LLC (“LEI”) as the IE
for Idaho Power’s 2026 RFP and evaluation of 2026 RFP resources. The OPUC also
APPLICATION - 6
approved the concurrent discussion of both scoring and modeling methodologies and
preparation of the draft 2026 RFP.
7. The Company worked with OPUC Staff and stakeholders to finalize the draft
2026 RFP and on June 8, 2023, Idaho Power formally issued the 2026 RFP, soliciting
bids for (1) energy market purchases and (2) new or existing resources. The 2026 RFP
was well received with 192 bids from 31 different bidders across 47 resources sites,
summing to more than 15 gigawatts of resources. Approximately 40 percent of the bids
reflected a commercial operation date by June 1, 2026, the remaining 60 percent of the
bids reflected a projected commercial operation date after June 1, 2026. The bids
included a variety of ownership structures, including many bids that would result in bidder-
owned resources (i.e., PPA’s, and Battery Storage Agreements), as well as three
benchmark bids across three sites, submitted by Idaho Power’s Power Supply
department.
8. The direct testimony of Mr. Hackett details the bid evaluation process which
was consistent and prescriptive as described in the 2026 RFP, ultimately identifying the
final shortlist of projects, including six with commercial operation in 2026. Confidential
Exhibit No. 2 to Mr. Hackett’s Direct Testimony lists the 2026 projects identified on the
final shortlist. As required under the OPUC competitive bidding rules, the OPUC approved
Idaho Power’s final shortlist on February 22, 2024. Once the most cost-effective 2026
projects were identified, the Company began negotiations with developers for
procurement of the resources necessary to meet Idaho Power’s 2026 capacity deficit.

APPLICATION - 7
V. RESOURCE DESCRIPTIONS
9. The bid evaluation process of the project proposals submitted through the
2026 RFP is designed to identify the combination and size of the proposed resources that
will maximize customer benefits while ensuring the Company meets its energy and
capacity needs, ultimately resulting in the selection of three least-cost, least-risk projects
to meet the 2026 capacity deficiency of 236 MW: (1) a market purchase product with
Powerex Corp. (“Powerex”), (2) the Savion, LLC 200 MW solar photovoltaic (“PV”) plus
100 MW battery storage project, and (3) a benchmark resource, the Idaho Power-owned
battery storage facility providing up to 150 MW of operating capacity. Upon conclusion of
the approximately 15-month mandated competitive bidding rule-compliant process, the
Company immediately executed the Powerex agreement and subsequently filed a
request for Commission approval because of the contractual deadline within the
agreement.6 Idaho Power also immediately initiated the procurement process for the
Company-owned battery energy storage system (“BESS”) facility at the Boise Bench
station providing 150 MW of operating capacity and on April 3, 2024, filed a request for a
CPCN with the Commission. On August 29, 2024, the Commission issued Order No.
36309 approving the market purchase agreement and on November 8, 2024, the
Commission issued Order No. 36389 approving the request for a CPCN for the Boise
Bench battery storage facility.
10. Since identification on the final shortlist, the Company worked diligently with
Savion on both the PPA associated with the 200 MW solar PV facility as well as the
battery supply agreement associated with the 100 MW battery storage facility. But

6 Case No. IPC-E-24-12, Idaho Power’s Application for Approval of a Market Purchase Agreement filed
on March 18, 2024.
APPLICATION - 8
execution of the agreements stalled when, on July 30, 2024, Savion was denied a
Conditional Use Permit by Ada County, Idaho, for their Powers Butte Energy Center.
While Savion has intentions of continued siting efforts, they have indicated the June 1,
2026, commercial operation date is no longer feasible. During negotiations with Savion,
the Company was also working with the developer of the next most cost-effective project
on the final shortlist for the procurement of additional resources however, due to
transmission constraints, the final shortlist project cannot fill the remaining 2026 capacity
deficiency. In addition, the developer informed Idaho Power that the project could no
longer meet the June 1, 2026, commercial operation date. Only one potential final shortlist
project remained but unfortunately, when it became evident the Savion project was likely
delayed, the developer notified Idaho Power that they too would not be able to meet the
June 1, 2026, commercial operation date. The inability to contract 2026 resources
required Idaho Power to seek alternative resources: two battery storages facilities
providing a total of 100 MW of operating capacity.
VI. CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
11. Idaho Power has an obligation to provide adequate, efficient, just, and
reasonable service on a nondiscriminatory basis to all those that request it within its
certificated service territory. Idaho Code §§ 61-302, 61-315, 61-507. The Commission
must assure that the rates Idaho Power charges its customers and that the rules and
regulations by which it provides service are just, reasonable, nondiscriminatory, and non-
preferential. Idaho Code §§ 61-501, 61-502, 61-503, 61-507, 61-508. The Company
must acquire the additional dispatchable resources with 100 MW of operating capacity to
meet the identified capacity deficits on its system in order to comply with its continuing
APPLICATION - 9
obligation to serve customers, and thus is requesting an order from the Commission
affirming that the public convenience and necessity requires the same. The proposed
acquisition represents a cost-effective means of providing adequate and reliable service
to the customers in Idaho Power’s certificated service territory. The Commission has the
express authority to order a utility to build new structures, or to upgrade and/or improve
existing plant and structures, in order to secure adequate service or facilities.
Whenever the commission, after a hearing had upon its own
motion or upon complaint, shall find that additions,
extensions, repairs or improvements to or changes in the
existing plant, scales, equipment, apparatus, facilities or other
physical property of any public utility . . . ought reasonably to
be made, or that a new structure or structures should be
erected, to promote the security or convenience of its
employees or the public, or in any other way to secure
adequate service or facilities, the commission shall make and
serve an order directing such additions, extensions, repairs,
improvements, or changes be made or such structure or
structures be erected in the manner and within the time
specified in said order.

Idaho Code § 61-508.

12. A CPCN or Certificate represents the exercise by the Commission of
foundational authority and principles that are necessary in Idaho’s system of permitting
regulated, vertically integrated, public utilities to exist and to provide necessary services
to the public. Certificates have been utilized in various ways from the time that Idaho’s
statutory system of public utility regulation was enacted by the Legislature in 1913, Idaho
Code § 61-101, et seq., to the present time. After nearly 100 years of legislative
enactments, Commission orders, and Idaho Supreme Court reviews, the Certificate
remains the embodiment of the Commission’s fundamental power and authority to, at the
most basic level, authorize and direct a public utility to serve in the public interest. See
APPLICATION - 10
Idaho Power & Light Co. v. Blomquist et al., 26 Idaho 222, 141 P.1083 (1914); Idaho Op.
Atty. Gen. No. 87-2, 1987 WL 247587 (Idaho A.G.).
13. In the broadest sense, a Certificate allows a company that meets the
definition of a “public utility” pursuant to Idaho Code § 61-129 to exclusively provide its
service to the public in a specified geographic region, its service territory. It is a codified
part of the “regulatory compact” whereby the utility takes on the exclusive obligation/right
to serve all those requesting service within its service territory and, correspondingly,
submits itself to the rate and service quality regulation of the Commission. In a more literal
sense, a Certificate from the Commission is required for the construction or extension of
a line, plant, or system by any street, railroad, gas, electrical, telephone, or water
corporation. Idaho Code § 61-526. § 61-526 also provides that “if public convenience
and necessity does not require or will require such construction or extension [of a line,
plant, or system] the commission . . . may, after hearing, make such order and prescribe
such terms and conditions for the locating or type of line, plant or system affected as to it
may seem just and reasonable . . . .” A CPCN is required for the utility to construct a new
generation resource or plant but is not required to increase the capacity of existing
generating facilities. Id.
VII. RATEMAKING TREATMENT FOR THE TWO BATTERY STORAGE PROJECTS
14. Idaho Power is not requesting binding ratemaking treatment for the two
battery storage facilities providing 100 MW of operating capacity in this case. The
Company’s request in this case is that the Commission find Idaho Power has met the
requirements of Idaho Code § 61-526 and issue an order granting a CPCN to acquire the
energy storage with 100 MW of operating capacity necessary to meet the identified
APPLICATION - 11
capacity deficiency in 2026. The Company will make a future filing to address the cost
recovery associated with this project.
VIII. FINANCING THE TWO BATTERY STORAGE PROJECTS
15. Idaho Power maintains investment grade credit ratings with Standard &
Poor’s Ratings Services and Moody’s Investors Service, with a long-term issuer rating of
BBB and Baa1, respectively. The Company maintains ready access to the capital markets
and to instruments providing for its liquidity. Idaho Power has a $400 million revolving
credit facility with its banking syndicate, which may be increased to $600 million under
specified conditions, which matures on December 7, 2029. The Company has an option
to request an additional one-year extension of the agreement, subject to certain
conditions. Idaho Power also has authority from state regulatory commissions to issue up
to $1.2 billion in aggregate principal amount of debt securities, $900 million of which
remained available as of November 30, 2024. The Company also has access to
commercial paper markets, as well as a balance of cash and investments on its balance
sheet. Additionally, Idaho Power has access to capital and credit outside of existing
mechanisms and instruments, such as through term loans, letter of credit, and other
instruments. IDACORP, the parent entity of Idaho Power, sold 3,221,982 shares of
IDACORP common stock in November 2023 under a forward sale agreement which was
settled for cash at IDACORP in 2024 for approximately $292 million. Approximately $92
million of the proceeds remain at IDACORP, which will primarily be used to infuse equity
to Idaho Power as needed. The Company intends to finance the energy storage with 100
MW of operating capacity with a combination of available cash and operating cash flow,
APPLICATION - 12
available credit facilities and borrowing and debt issuances, and future equity infusions
by IDACORP.
IX. COMMUNICATIONS AND SERVICE OF PLEADINGS
16. Communications and service of pleadings with reference to this Application
should be sent to the following:
Donovan E. Walker Tim Tatum
Lead Counsel Vice President, Regulatory Affairs
Idaho Power Company Idaho Power Company
1221 West Idaho Street (83702) 1221 West Idaho Street (83702)
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
[e-mail] [e-mail]
[e-mail]

X. MODIFIED PROCEDURE
17. The Company believes that a hearing is not necessary to consider the
issues presented herein, and respectfully requests that this Application be processed
under Modified Procedure; i.e., by written submissions rather than by hearing. RP 201, et
seq. If, however, the Commission determines that a technical hearing is required, the
Company stands ready to present its testimony and support the Application in such
hearing.
XI. REQUEST FOR RELIEF
Idaho Power respectfully requests that the Commission issue an order granting
the Company a CPCN to acquire new dispatchable energy storage with 100 MW of
operating capacity. Because approval of this request is necessary to position Idaho Power
to meet its obligation to provide safe, reliable service to its customers, the Company
respectfully requests that the Commission issue an order as soon as practicable.

APPLICATION - 13
DATED at Boise, Idaho this 27th day of December 2024.
DONOVAN E. WALKER
Attorney for Idaho Power Company