Direct J. Ellsworth.tif

ELLSWORTH, DI 1
Idaho Power Company
Q. Please state your name, business address, and 1
present position with Idaho Power Company (“Idaho Power” or 2
“Company”). 3
A. My name is Jared L. Ellsworth and my business 4
address is 1221 West Idaho Street, Boise, Idaho 83702. I am 5
employed by Idaho Power as the Transmission, Distribution & 6
Resource Planning Director for the Planning, Engineering & 7
Construction Department. 8
Q. Please describe your educational background. 9
A. I graduated in 2004 and 2010 from the 10
University of Idaho in Moscow, Idaho, receiving a Bachelor 11
of Science Degree and Master of Engineering Degree in 12
Electrical Engineering, respectively. I am a licensed 13
professional engineer in the State of Idaho. 14
Q. Please describe your work experience with 15
Idaho Power. 16
A. In 2004, I was hired as a Distribution 17
Planning engineer in the Company’s Delivery Planning 18
department. In 2007, I moved into the System Planning 19
department, where my principal responsibilities included 20
planning for bulk high-voltage transmission and substation 21
projects, generation interconnection projects, and North 22
American Electric Reliability Corporation’s reliability 23
compliance standards. I transitioned into the Transmission 24
Policy & Development group with a similar role, and in 25
ELLSWORTH, DI 2
Idaho Power Company
2013, I spent a year cross-training with the Company’s Load 1
Serving Operations group. In 2014, I was promoted to 2
Engineering Leader of the Transmission Policy & Development 3
department and assumed leadership of the System Planning 4
group in 2018. In early 2020, I was promoted into my 5
current role as the Transmission, Distribution and Resource 6
Planning Director. I am currently responsible for the 7
planning of the Company’s wires and resources to continue 8
to provide customers with cost-effective and reliable 9
electrical service. 10
Q. What is the Company’s request in this case? 11
A. Idaho Power is requesting the Idaho Public 12
Utilities Commission (“Commission”) grant the Company a 13
Certificate of Public Convenience and Necessity (“CPCN”) to 14
acquire new dispatchable energy storage with 100 megawatts 15
(“MW”) of operating capacity and necessary to meet the 16
identified capacity deficiency in 2026. 17
Q. What is the purpose of your testimony in this 18
case? 19
A. The purpose of my testimony is to inform the 20
Commission of the Company’s need for new resources to meet 21
an identified capacity deficit in 2026 as informed by a 22
Loss of Load Expectation (“LOLE”) methodology utilized in 23
the 2021 Integrated Resource Plan (“IRP”), again in the 24
2023 IRP, and subsequently further enhanced through system 25
ELLSWORTH, DI 3
Idaho Power Company
reliability evaluations. I will describe the most recent 1
assessment of system reliability and its impact to the 2
capacity deficit identified in the annual capacity position 3
utilized in the 2023 IRP. Finally, I will provide support 4
for the acquisition of resources to address the identified 5
near-term capacity needs. 6
Q. Is this the same assessment of system 7
reliability that was performed to support the Company’s 8
request in Case No. IPC-E-24-12, Idaho Power Company’s 9
Application for Approval of a Market Purchase Agreement 10
filed on March 18, 2024, and Case No. IPC-E-24-16, Idaho 11
Power Company’s Application for a Certificate of Public 12
Convenience and Necessity for the Boise Bench Battery 13
Storage Facility? 14
A. No, it is not. The Company has performed an 15
updated assessment of system reliability since Case Nos. 16
IPC-E-24-12 and IPC-E-24-16 were filed that identifies a 17
2026 capacity deficit range of 41 MW to 61 MW with 18
continued growth in that deficit in 2027 and beyond. 19
I. BACKGROUND 20
Q. What is the goal of the IRP? 21
A. The goal of the IRP is to ensure: (1) Idaho 22
Power’s system has sufficient resources to reliably serve 23
customer demand and flexible capacity needs over a 20-year 24
planning period, (2) the selected resource portfolio 25
ELLSWORTH, DI 4
Idaho Power Company
balances cost, risk, and environmental concerns, (3) 1
balanced treatment is given to both supply-side resources 2
and demand-side measures, and (4) the public is involved in 3
the planning process in a meaningful way. Idaho Power uses 4
Energy Exemplar’s AURORA’s Long-Term Capacity Expansion 5
(“LTCE”) modeling platform to develop portfolios, through 6
the selection of a variety of supply- and demand-side 7
resource options, that are least-cost for a variety of 8
alternative future scenarios while meeting reliability 9
criteria. To verify the top performing portfolios meet the 10
Company’s reliability requirements, Idaho Power utilizes a 11
LOLE methodology. 12
Q. Please explain the Loss of Load Expectation. 13
A. The LOLE is a statistical measure of a 14
system’s resource adequacy, describing the expected number 15
of event-days per year that a system would be unable to 16
meet demand. As utilities continue to add more renewable 17
energy to the electric grid, analyzing the effect variable 18
energy resources have on system reliability has become more 19
critical. The LOLE methodology recognizes that the output 20
of variable energy resources, such as wind and solar, 21
change with time (with their hourly output being dependent 22
on a multitude of factors like weather and environmental 23
conditions); it is essential to capture and value that 24
variability. 25
ELLSWORTH, DI 5
Idaho Power Company
Q. What inputs are derived from the LOLE 1
methodology that are utilized in the AURORA LTCE model? 2
A. Idaho Power implements the LOLE methodology 3
through an internally developed Reliability and Capacity 4
Assessment Tool (“RCAT”) which is capable of producing 5
inputs such as a Planning Reserve Margin (“PRM”) and 6
resource Effective Load Carrying Capability (“ELCC”) 7
values. The PRM metric can be defined as the percentage of 8
expected capacity resources above forecasted peak demand. 9
The ELCC calculation is a reliability-based metric used to 10
assess the capacity contribution of variable and energy-11
limited resources. The PRM and ELCC values that are 12
calculated using the LOLE methodology are a direct input to 13
the AURORA LTCE model. 14
Q. How are the PRM and ELCC values utilized? 15
A. Because the AURORA LTCE model and the RCAT are 16
two separate tools, a translation is required between the 17
probabilistic LOLE analysis performed in RCAT and the 18
portfolios produced by the AURORA LTCE model. First, PRM 19
and ELCC values are calculated using the LOLE methodology, 20
which serve as direct inputs to the AURORA LTCE model. 21
After AURORA solves for and produces portfolios, select 22
resource buildouts and their corresponding data are 23
analyzed with the LOLE methodology and tested to ensure 24
they meet the pre-designated reliability hurdle through the 25
ELLSWORTH, DI 6
Idaho Power Company
calculation of annual capacity positions. It is critical 1
when comparing future resource portfolios that each plan 2
achieves at least a base reliability threshold. Figure 1 3
below illustrates the model consolidation process. 4
Figure 1. Idaho Power’s Reliability Flowchart 5
6
Q. Have the LOLE-derived annual capacity 7
positions replaced the previously utilized load and 8
resource balance? 9
A. Yes. While they serve the same purpose, to 10
determine capacity deficiencies, the annual capacity 11
position calculation is a 2023 IRP methodology improvement 12
that replaced the load and resource balance process 13
performed in prior IRP filings. The load and resource 14
balance was a tabulated plan that helped visually ensure 15
Idaho Power had sufficient resources to meet projected 16
customer demand including a margin to account for extreme 17
conditions, reserves, and resource outages, identifying 18
ELLSWORTH, DI 7
Idaho Power Company
resource deficiencies during the 20-year IRP planning 1
horizon. Beginning with the 2023 IRP, to better align with 2
and represent the probabilistic reliability analyses 3
utilized and to be consistent with best practices in the 4
industry, the RCAT was utilized to calculate annual 5
capacity positions in place of the deterministic load and 6
resource balance. The LOLE-derived annual capacity position 7
calculation is a better indication of resource reliability 8
as compared to the previously utilized load and resource 9
balance. The goal is the same under both processes: 10
identification of the timing of the Company’s first 11
resource need, or the point at which Idaho Power’s 12
reliability requirements may not be met. 13
Q. If the goal of both processes is the same, how 14
is the LOLE-derived annual capacity position calculation an 15
IRP methodology improvement? 16
A. In the 2021 IRP, the Company derived static 17
PRM and resource ELCC values that were held constant 18
throughout the 20-year planning horizon. As the RCAT and 19
AURORA serve different purposes in Idaho Power’s planning 20
process, the Company recognized that further efforts were 21
needed to translate and align the data exchanged between 22
the two models. Historically, the PRM was based on the peak 23
load of a given year plus some additional amount to account 24
for abnormal weather events or equipment outages. This 25
ELLSWORTH, DI 8
Idaho Power Company
method worked well to ensure reliability for Idaho Power as 1
a summer peaking utility with mostly flexible generation 2
resources. However, as the wider industry, and the Company, 3
experience increased reliance on variable energy resources, 4
whose hour-to-hour and season-to-season generation changes, 5
it is no longer viable to only contemplate peak hour 6
requirements. 7
To ensure that AURORA would recognize similar 8
capacity needs as identified by the RCAT, the Company 9
developed seasonal PRM values for years in the planning 10
horizon that experience significant changes in the resource 11
buildout, better representing the seasonal resource needs. 12
Historically, when a portfolio added predominantly flexible 13
generation resources it was also sufficient to give these 14
resources a static peak capacity contribution as it was 15
harmonious with a static PRM. As variable energy resource 16
and energy limited resource additions increase, static 17
values no longer account for the reduced peak capacity 18
contribution due to saturation nor do they capture the 19
diversity benefit (positive or negative) of a mix of 20
different types of variable energy resources and energy 21
limited resources. 22
Q. Were any changes made to the use of resource 23
ELCC values as well? 24
A. Yes. The ELCC of future variable energy 25
ELLSWORTH, DI 9
Idaho Power Company
resources and energy limited resources are dependent upon 1
the resources built before them, making the ELCC 2
calculation of future resources challenging. Idaho Power 3
implemented seasonal resource specific ELCC saturation 4
curves for variable energy resources and energy limited 5
resources in the AURORA LTCE model for the 2023 IRP. 6
Q. Please explain the synchronization of the RCAT 7
and the AURORA LTCE model. 8
A. To better assess the dynamic diversity benefit 9
caused by a changing resource mix, a feedback process was 10
implemented between the AURORA LTCE model and the RCAT for 11
the 2023 IRP. Under the feedback process, the annual 12
capacity positions for an AURORA LTCE main case portfolio 13
buildout were calculated using the RCAT. Once the annual 14
capacity positions were known, the PRM in the AURORA LTCE 15
model was modified in years that had significant resource 16
changes so that both models identified a similar annual 17
capacity position. The feedback loop continued until the 18
main case portfolio was reliable under the LOLE threshold. 19
The resulting AURORA-produced optimized main case 20
portfolios provide the least-cost, least-risk future 21
resource buildouts. 22
// 23
// 24
// 25
ELLSWORTH, DI 10
Idaho Power Company
II. ANNUAL CAPACITY POSITION 1
Q. How has Idaho Power’s capacity needs changed 2
since the system reliability assessment was performed for 3
Case Nos. IPC-E-24-12 and IPC-E-24-16? 4
A. The system reliability assessment for which 5
the capacity need identified in Case Nos. IPC-E-24-12 and 6
IPC-E-24-16 was based, which assumed the online date for 7
Boardman to Hemingway (“B2H”) is beyond summer of 2026, 8
identified a capacity deficit of 236 MW in 2026. With the 9
Commission’s approval of the market purchase agreement in 10
Case No. IPC-E-24-12,1 and issuance of a CPCN in Case No. 11
IPC-E-24-16 for the Boise Bench battery storage facility, 12
the 2026 capacity deficit decreased to 122 MW. 13
Q. Has the Company updated the system reliability 14
assessment since identification of the 122 MW capacity 15
deficit in 2026 following the procurement of resources 16
reviewed in Case Nos. IPC-E-24-12 and IPC-E-24-16? 17
A. Yes. The Company recognizes that during the 18
near-term resource decision-making phase, the annual 19
capacity positions can be very fluid. In addition, in the 20
face of growing loads, Idaho Power constantly monitors 21
resource needs and responds with added urgency, as 22
evidenced by Idaho Power’s consecutive requests for CPCNs 23
to acquire resources to be online in 2023, 2024, 2025 and 24

1 Order No. 36309.
ELLSWORTH, DI 11
Idaho Power Company
2026.2 The most recent system reliability assessment, which 1
assumes the online date for B2H is beyond summer of 2026, 2
and includes the procurement of resources in Case Nos. IPC-3
E-24-12 and IPC-E-24-16, has identified a capacity deficit 4
in the range of 41 MW to 61 MW in 2026. 5
Q. What drove the changes to the annual capacity 6
positions for 2026 in the most recent system reliability 7
assessment? 8
A. Any time the system reliability evaluation is 9
performed, Idaho Power includes the most up-to-date load 10
and resource inputs. The modeling input updates that have 11
occurred since identification of the 122 MW deficit that 12
remained after considering the additional resources 13
addressed in Case Nos. IPC-E-24-12 and IPC-E-24-16 are 14
primarily related to: (1) an updated load forecast, (2) 15
inclusion of a wildfire risk factor, (3) an updated 16
generation unit outage schedule, and (4) the acceleration 17
of the commercial operation date of the PVS 2, LLC, solar 18
facility. 19
With the continued high load growth in the Company’s 20
service area, the load forecast is consistently monitored 21
and updated as new information becomes available. Idaho 22
Power has experienced numerous wildfire-related outages on 23

2 Case Nos. IPC-E-22-13, IPC-E-23-05, IPC-E-23-20, IPC-E-24-12, and IPC-
E-24-16.
ELLSWORTH, DI 12
Idaho Power Company
major tie lines used to import power. The Company is 1
fortunate to have some diversity in transmission lines, and 2
that diversity will continue to expand in the future with 3
additions to the transmission system. However, given the 4
prevalence of wildfires in the recent past, the Company has 5
incorporated a small adjustment to the availability of 6
certain transmission facilities. Additionally, due to 7
permitting delays, planned maintenance of one of the Oxbow 8
hydro units has been shifted from 2026 to 2027, providing 9
some additional capacity in 2026. Permitting delays have 10
become more common over the past five years due to 11
increased permitting requirements, reduced government 12
staffing, and greater public opposition to projects. This 13
has driven Idaho Power to consider and plan for the impact 14
of potential and actual project delays. 15
Q. Are there any other near-term known changes, 16
operational enhancements, limitations, or constraints on 17
the existing system, that would inform the Company’s 18
resource needs today? 19
A. Yes. Order No. 36322 issued on September 13, 20
2024, in Case No. IPC-E-24-20, Idaho Power’s Application 21
for Approval of the First Amendment to the Power Purchase 22
Agreement with PVS 2, LLC, approved the change in the 23
Scheduled Commercial Operation Date contained in the Power 24
Purchase Agreement from December 31, 2026, to May 31, 2026, 25
ELLSWORTH, DI 13
Idaho Power Company
further reducing the 2026 capacity deficit. Assuming the 1
project meets it commercial operation date, the addition of 2
the solar does not fully address the Company’s capacity 3
deficit but will reduce the capacity deficit to the range 4
of 41 MW to 61 MW in 2026. 5
Q. Why is the capacity deficit a range between 41 6
MW and 61 MW, rather than a single capacity deficit as 7
presented previously? 8
A. Idaho Power has been experiencing a 9
significant increase to its winter peak load, as evidenced 10
by the Company’s all-time winter peak load record of 2,719 11
MW on January 16, 2024, surpassing the previous record by 12
over 100 MW and causing an energy emergency alert as 13
discussed below. In light of this new winter peak load 14
record, and because of the greater winter peak-day 15
temperature variability, the Company recognized the need to 16
revise its peak winter load forecasting methodology. For 17
the purposes of making resource decisions while the load 18
forecast was being updated, the Company began assessing its 19
capacity position under a range which utilizes two versions 20
of the load forecast; first being the 70th percentile peak 21
load for all months as was done in the 2023 IRP, second 22
being the 70th percentile peak load for March through 23
October, but utilizes a 95th percentile peak load for 24
ELLSWORTH, DI 14
Idaho Power Company
November through February, which better addresses peak load 1
variability due to winter temperatures. 2
III. MEETING THE CAPACITY DEFICIENCY 3
Q. How does the Company propose to address the 4
2026 capacity deficit presented in this case? 5
A. First, in August 2024, an opportunity arose 6
for Idaho Power to purchase 50 MW of firm energy delivered 7
to its border, for the months of June 2026 through August 8
2026, around the clock, seven days a week. While this 9
short-term purchase will reduce the projected capacity 10
deficit identified for 2026, it only has the effect of 11
deferring, not eliminating, Idaho Power’s resource needs 12
in future years. 13
Q. Is the Company procuring any additional 14
resources to address the remaining deficit? 15
A. Yes. As described in the Direct Testimony of 16
Mr. Hackett, Idaho Power was not able to execute an 17
agreement for a third project submittal with a June 1, 18
2026, commercial operation date resulting from the 2026 19
RFP, and therefore has procured alternative resources, two 20
Company-owned battery storage facilities that will each 21
provide 50 MW of operating capacity. The additional 100 MW 22
of operating capacity provided by the battery storage 23
facilities will ensure Idaho Power continues to provide 24
safe, reliable electric service in 2026 and beyond. 25
ELLSWORTH, DI 15
Idaho Power Company
Q. How does the addition of the 50 MW summer 2026 1
market purchase and procurement of the two alternative 2
resources, the two battery storage facilities providing 3
100 MW of operating capacity, impact that capacity deficit 4
in 2026? 5
A. Absent the methodological changes to the 6
market purchase assumptions and the peak load forecasts, 7
and assuming all projects reach commercial operation on 8
time, the addition of the 50 MW summer 2026 market 9
purchase and two battery storage facilities providing 100 10
MW of operating capacity would reduce the 2026 capacity 11
deficit of 41 MW) to 61 MW to a sufficient capacity length 12
position of 7 MW to 44 MW. Although it could be argued 13
that more capacity length is justifiable should Idaho 14
Power experience unforeseen project delays or longer-term 15
resource outages, the Company believes this sufficiency 16
range is acceptable and reflects prudent resource planning 17
in light of increasing resource costs and growing annual 18
capacity deficiencies. The addition of the battery storage 19
facilities will support continued safe, reliable 20
operations in 2026 and beyond. 21
Q. Why do you believe there is sufficient support 22
for the procurement of the Idaho Power-owned battery 23
storage facilities providing a combined 100 MW of 24
operating capacity? 25
ELLSWORTH, DI 16
Idaho Power Company
A. The resource acquisitions presented in this 1
case were pursued and procured as a least-cost, least-risk 2
method of meeting the capacity deficits first identified 3
in the Company’s 2021 IRP, again in the 2023 IRP, and 4
subsequently with the results of the updated system 5
reliability evaluation. The fluidity of the capacity 6
deficit period, and continued high load growth, and supply 7
chain disruptions and delays further supports these 8
resource procurements which combined are necessary to 9
adequately address 2026 capacity deficits. 10
Q. Are there any additional operational 11
considerations that support the resource procurements 12
presented in this case? 13
A. Yes. In addition, the battery storage 14
providing a combined 100 MW of operating capacity will 15
provide support during energy emergencies; Idaho Power has 16
experienced two energy emergencies in the recent past. The 17
first energy emergency occurred on September 6, 2022, 18
during a hot summer day. The second energy emergency 19
occurred on January 13, 2024, during a cold winter 20
morning. Prior to these recent energy emergencies, the 21
Company had not been in an energy emergency for over a 22
decade. 23
Q. How does the combined 100 MW of additional 24
battery storage capacity fit within the Company’s future 25
ELLSWORTH, DI 17
Idaho Power Company
needs? 1
A. With the additional 100 MW of battery storage2
and considering the 50 MW market purchase is for 2026 3
only, the Company is forecasting a 298 MW to 320 MW 4
capacity deficit in 2027. This large deficit is driven 5
substantially by load growth between 2026 and 2027. The 6
large deficit just one year after acquisition of the 7
additional 100 MW of battery storage illustrates the need 8
for the investment. 9
Q. Are there any financial considerations between10
acquiring additional resources in 2026 as compared to 11
2027? 12
A. Yes. As explained in more detail in Mr.13
Hackett’s testimony, the Company expects battery storage 14
costs to increase for projects being placed in-service 15
after 2026 due to increases in tariffs associated with 16
materials from Asia, further supporting the time-limited 17
nature of this cost-effective acquisition. 18
Q. Did the Company evaluate any alternative19
solutions for meeting the 2026 capacity deficiency to avoid 20
building a new resource? 21
A. Yes. As I discussed earlier in my testimony,22
as part of the IRP process, the Company uses AURORA’s LTCE 23
modeling platform to develop portfolios, through the 24
selection of a variety of supply- and demand-side resource 25
ELLSWORTH, DI 18
Idaho Power Company
options, that are least-cost for a variety of alternative 1
future scenarios while meeting reliability criteria. The 2
future supply- and demand-side resources available to meet 3
identified capacity deficiencies, whose costs are generally 4
based on the 2022 Annual Technology Baseline report 5
released by the National Renewable Energy Laboratory,3 6
include new gas-fired resources, wind, solar, battery 7
storage, market purchases via available transmission 8
capacity, demand response and energy efficiency. The 9
Preferred Portfolio from the 2023 IRP, which included a 10
July 2026 online date for B2H, identified the conversion of 11
Valmy Units 1 and 2 to natural gas, the procurement of 100 12
MW of solar as the most cost-effective resources for 13
meeting the identified capacity deficits in 2026 along with 14
19 MW of energy efficiency potential (identified in the 15
energy efficiency potential study). In addition, as part of 16
the 2023 IRP modeling, the Company evaluated an alternative 17
B2H online date beyond July 2026 should there be a delay in 18
receiving permits, supply chain constraints, or other 19
unforeseen events, assuming an online date for B2H of 20
November 2026. This evaluation is identifying the most 21
cost-effective alternative for meeting the identified 22
capacity deficit should the B2H online date be delayed to 23
November 2026. 24

3 atb.nrel.gov/.
ELLSWORTH, DI 19
Idaho Power Company
Q. What additional resources were selected as 1
cost-effective alternatives for meeting the capacity 2
deficiency under a scenario with a November 2026 B2H online 3
date and the conversion of both Valmy units to natural gas? 4
A. When compared to the 2023 IRP Preferred 5
Portfolio, in 2026 an additional 300 MW of solar was 6
selected, 400 MW in total, as well as 155 MW of battery 7
storage and 40 MW of demand response, indicative of the 8
Company’s need to procure resources to continue to provide 9
safe, reliable electric service to its customers in 2026 10
and beyond. 11
Q. What actions has Idaho Power taken to-date to 12
acquire resources to ensure continued safe, reliable 13
electric service in 2026? 14
A. Under Idaho law, Idaho Power has an obligation 15
to provide adequate, efficient, just, and reasonable 16
service on a nondiscriminatory basis to all those that 17
request it within its certificated service area.4 Further, 18
as indicated by Order No. 35643, Idaho Power is responsible 19
for planning and managing its load and resource portfolio 20
and the Commission expects “the Company to closely monitor 21
its projected capacity needs going forward and to act 22
proactively to ensure a robust RFP process can be 23

4 Idaho Code §§ 61-302, 61-315, 61-507.
ELLSWORTH, DI 20
Idaho Power Company
completed.”5 Therefore, in order to meet its obligations to 1
reliably serve customers, on September 15, 2022, Idaho 2
Power filed an application with the Public Utility 3
Commission of Oregon (“OPUC”) to open an independent 4
evaluator selection docket to oversee the Request for 5
Proposals (“RFP”) process.6 The Company’s compliance with 6
the OPUC competitive bidding guidelines, which the 7
Commission directed Idaho Power to follow as well7 and is 8
discussed in greater detail in the direct testimony of Mr. 9
Hackett, ultimately led to a competitive solicitation 10
through the issuance of the 2026 All-Source RFP, seeking a 11
combination of energy and capacity resources that provide a 12
minimum of approximately 350 MW of peak capacity and up to 13
1,100 MW of variable energy resources for 2026 and 2027 14
(“2026 RFP”). 15
Given the significant timeframe related to the RFP 16
process under the OPUC competitive bidding guidelines, 17
which spans nearly 15 months and is solely related to the 18
RFP process and diligence and excludes the time required 19
for contract negotiation and execution, material 20
procurement, and construction, which can add another two to 21
six years to the process, the 2026 RFP was responsive to 22
the resource needs identified in the Company’s 2021 IRP 23

5 Page 13.
6 Docket UM 2255.
7 Order No. 32745. Case No. IPC-E-10-03.
ELLSWORTH, DI 21
Idaho Power Company
filing, which included near-term preferred portfolio 1
additions of wind, solar, storage, cost-effective energy 2
efficiency measures, the conversion of coal units to 3
natural gas, incremental demand response, and B2H coming 4
online in 2026. The RFP needed to remain flexible to 5
account for the fluidity of the Company’s annual capacity 6
positions as well as any potential delays in the B2H online 7
date and other projects. Ultimately, the 2026 resources 8
selected through the RFP process were based on the then-9
identified capacity deficiency of 236 MW in 2026. Note, 10
this 236 MW deficit is perfect capacity, so it requires 11
Idaho Power to procure significantly more megawatts of 12
nameplate capacity, depending on the ELCC of each resource. 13
Through the Company’s robust competitive bidding 14
process, Idaho Power identified the most cost-effective 15
bids from the 2026 RFP evaluation as necessary to fill the 16
2026 capacity deficit. The first bid resulted in the 17
execution of a 200 MW contract with Powerex for a capacity-18
based product and firm energy contract effective June 2026, 19
for which the Company received approval in Case No. IPC-E-20
24-12 with Order No. 36309. The second bid selected was a21
benchmark resource, the Idaho Power-owned 4-hour battery 22
storage facility providing up to 150 MW of operating 23
capacity, and the resource the Company requested the 24
Commission grant a CPCN in Case No. IPC-E-24-16, which was 25
ELLSWORTH, DI 22
Idaho Power Company
approved with Order No. 36386. With the inclusion of these 1
two resources, plus the accelerated commercial operation 2
date of the PVS 2, LLC solar facility, the most recent 3
system reliability assessment has identified that a 4
capacity deficit range of 41 MW to 61 MW in 2026 remains, 5
assuming all projects meet the scheduled commercial 6
operation date (e.g., all 2025 resources, the Boise Bench 7
battery storage systems, PVS 1 and PVS 2, and the Valmy 8
Units 1 and 2 natural gas conversions). 9
IV. CONCLUSION10
Q. Please summarize your testimony.11
A. Idaho Power’s most recent system reliability12
evaluation has identified a capacity deficiency range of 41 13
MW to 61 MW in 2026. In response to this resource need, the 14
Company has identified Idaho Power-owned battery storage 15
facilities providing 100 MW of operating capacity as least-16
cost, least-risk resources for which Idaho Power is 17
requesting the Commission grant a CPCN at this time. 18
Q. Does this complete your testimony?19
A. Yes, it does.20
ELLSWORTH, DI 23
Idaho Power Company
DECLARATION OF JARED L. ELLSWORTH 1
I, Jared L. Ellsworth, declare under penalty of 2
perjury under the laws of the state of Idaho: 3
1. My name is Jared L. Ellsworth. I am employed4
by Idaho Power Company as the Transmission, Distribution & 5
Resource Planning Director for the Planning, Engineering & 6
Construction Department. 7
2. On behalf of Idaho Power, I present this8
pre-filed direct testimony in this matter. 9
3. To the best of my knowledge, my pre-filed10
direct testimony is true and accurate. 11
I hereby declare that the above statement is true to 12
the best of my knowledge and belief, and that I understand 13
it is made for use as evidence before the Idaho Public 14
Utilities Commission and is subject to penalty for perjury. 15
SIGNED this 27th day of December 2024, at Boise, 16
Idaho. 17
18
Signed: ___________________ 19
20