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”) issue an order (1) 13
approving the 35-year Power Purchase Agreement (“PPA”) 14
between Jackalope Wind, LLC and Idaho Power Company 15
supplying approximately 300 megawatts (“MW”) to the 16
Company’s system (“Jackalope Wind PPA”), and (2) granting 17
Idaho Power a Certificate of Public Convenience and 18
Necessity (“CPCN”) to acquire ownership in a wind turbine 19
generator power plant providing approximately 300 MW of 20
generation. Both the Jackalope Wind PPA and ownership in 21
the wind turbine generator power plant (“Jackalope Wind 22
Project”), collectively, referred to as the “Jackalope 23
Project”, are necessary for the Company to continue to 24
provide safe, reliable electric service in 2027 and beyond. 25
ELLSWORTH, DI 3
Idaho Power Company
Q. What is the purpose of your testimony in this 1
case? 2
A. The purpose of my testimony is to inform the 3
Commission of the Company’s need for new resources to meet 4
an identified capacity deficit in 2027 as informed by a 5
Loss of Load Expectation (“LOLE”) methodology utilized in 6
the 2021 Integrated Resource Plan (“IRP”), again in the 7
2023 IRP, and subsequently further enhanced through system 8
reliability evaluations. I will describe the most recent 9
assessment of system reliability and its impact to the 10
capacity deficit identified in the previous system 11
reliability assessment. Finally, I will provide support for 12
the acquisition of resources to address the identified 13
near-term capacity needs. 14
Q. Is this the same assessment of system 15
reliability that was performed to support the Company’s 16
request in Case No. IPC-E-24-12, Idaho Power Company’s 17
Application for Approval of a Market Purchase Agreement 18
filed on March 18, 2024, and Case No. IPC-E-24-16, Idaho 19
Power Company’s Application for a Certificate of Public 20
Convenience and Necessity for the Boise Bench Battery 21
Storage Facility? 22
A. No. It is, however, the same system 23
reliability assessment performed to support the Company’s 24
request in Case No. IPC-E-24-45, Idaho Power Company’s 25
ELLSWORTH, DI 4
Idaho Power Company
Application for a Certificate of Public Convenience and 1
Necessity for Two Battery Storage Facilities, which is 2
currently pending with the Commission. Case No. IPC-E-24-45 3
is specific to the 2026 capacity deficiency while this case 4
presents the Company’s annual capacity position in 2027, 5
identifying a 2027 capacity deficit range of 298 MW to 320 6
MW. 7
I. BACKGROUND 8
Q. What is the goal of the IRP? 9
A. The goal of the IRP is to ensure: (1) Idaho 10
Power’s system has sufficient resources to reliably serve 11
customer demand and flexible capacity needs over a 20-year 12
planning period, (2) the selected resource portfolio 13
balances cost, risk, and environmental concerns, (3) 14
balanced treatment is given to both supply-side resources 15
and demand-side measures, and (4) the public is involved in 16
the planning process in a meaningful way. Idaho Power uses 17
Energy Exemplar’s AURORA’s Long-Term Capacity Expansion 18
(“LTCE”) modeling platform to develop portfolios, through 19
the selection of a variety of supply- and demand-side 20
resource options, that are least-cost for a variety of 21
alternative future scenarios while meeting reliability 22
criteria. To verify the top performing portfolios meet the 23
Company’s reliability requirements, Idaho Power utilizes a 24
LOLE methodology. 25
ELLSWORTH, DI 5
Idaho Power Company
Q. Please explain the Loss of Load Expectation. 1
A. The LOLE is a statistical measure of a 2
system’s resource adequacy, describing the expected number 3
of event-days per year that a system would be unable to 4
meet demand. As utilities continue to add more renewable 5
energy to the electric grid, analyzing the effect variable 6
energy resources have on system reliability has become more 7
critical. The LOLE methodology recognizes that the output 8
of variable energy resources, such as wind and solar, 9
change with time (with their hourly output being dependent 10
on a multitude of factors like weather and environmental 11
conditions); it is essential to capture and value that 12
variability. 13
Q. What inputs are derived from the LOLE 14
methodology that are utilized in the AURORA LTCE model? 15
A. Idaho Power implements the LOLE methodology 16
through an internally developed Reliability and Capacity 17
Assessment Tool (“RCAT”) which is capable of producing 18
inputs such as a Planning Reserve Margin (“PRM”) and 19
resource Effective Load Carrying Capability (“ELCC”) 20
values. The PRM metric can be defined as the percentage of 21
expected capacity resources above forecasted peak demand. 22
The ELCC calculation is a reliability-based metric used to 23
assess the capacity contribution of variable and energy-24
limited resources. The PRM and ELCC values that are 25
ELLSWORTH, DI 6
Idaho Power Company
calculated using the LOLE methodology are a direct input to 1
the AURORA LTCE model. 2
Q. How are the PRM and ELCC values utilized? 3
A. Because the AURORA LTCE model and the RCAT are 4
two separate tools, a translation is required between the 5
probabilistic LOLE analysis performed in RCAT and the 6
portfolios produced by the AURORA LTCE model. First, PRM 7
and ELCC values are calculated using the LOLE methodology, 8
which serve as direct inputs to the AURORA LTCE model. 9
After AURORA solves for and produces portfolios, select 10
resource buildouts and their corresponding data are 11
analyzed with the LOLE methodology and tested to ensure 12
they meet the pre-designated reliability hurdle through the 13
calculation of annual capacity positions. It is critical 14
when comparing future resource portfolios that each plan 15
achieves at least a base reliability threshold. Figure 1 16
below illustrates the model consolidation process. 17
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ELLSWORTH, DI 7
Idaho Power Company
Figure 1. Idaho Power’s Reliability Flowchart 1
2
Q. You indicated the RCAT and AURORA serve 3
different purposes in Idaho Power’s planning process, how 4
is the data exchanged between the two models translated 5
and aligned? 6
A. To better assess the dynamic diversity benefit 7
caused by a changing resource mix, and to synchronize the 8
models, beginning with the 2023 IRP a feedback process was 9
implemented between the AURORA LTCE model and the RCAT. 10
Under the feedback process, the annual capacity positions 11
for an AURORA LTCE main case portfolio buildout were 12
calculated using the RCAT. Once the annual capacity 13
positions were known, the PRM in the AURORA LTCE model was 14
modified in years that had significant resource changes so 15
that both models identified a similar annual capacity 16
position. The feedback loop continued until the main case 17
portfolio was reliable under the LOLE threshold. The 18
ELLSWORTH, DI 8
Idaho Power Company
resulting AURORA-produced optimized main case portfolios 1
provide the least-cost, least-risk future resource 2
buildouts. 3
II. ANNUAL CAPACITY POSITION 4
Q. You indicated the Company updated the system 5
reliability assessment following the procurement of 6
resources reviewed in Case Nos. IPC-E-24-12 and IPC-E-24-16 7
(“Approved 2026 Resources”). Why was the system reliability 8
assessment updated? 9
A. The Company recognizes that during the near-10
term resource decision-making phase, the annual capacity 11
positions can be very fluid. In addition, in the face of 12
growing loads, Idaho Power constantly monitors resource 13
needs and responds with added urgency, as evidenced by 14
Idaho Power’s consecutive requests for CPCNs to acquire 15
resources to be online in 2023, 2024, 2025 and 2026.1 The 16
most recent system reliability assessment, which (1) 17
assumes the online date for the Boardman to Hemingway 18
transmission line (“B2H”) is beyond summer of 2027, (2) 19
includes the procurement of the Approved 2026 Resources as 20
well as the resources for which Idaho Power has requested a 21
CPCN in Case No. IPC-E-24-45, and (3) reflects the 22
acceleration of the commercial operation date of the PVS 2, 23

1 Case Nos. IPC-E-22-13, IPC-E-23-05, IPC-E-23-20, IPC-E-24-12, IPC-E-
24-16, and IPC-E-24-45.
ELLSWORTH, DI 9
Idaho Power Company
LLC, solar facility,2 has identified a capacity deficit in 1
the range of 298 MW to 320 MW in 2027. 2
Q. What drove the changes to the annual capacity 3
positions for 2027 in the most recent system reliability 4
assessment? 5
A. Any time the system reliability evaluation is 6
performed, Idaho Power includes the most up-to-date load 7
and resource inputs. The modeling input updates that have 8
occurred are primarily related to 1) an updated load 9
forecast, 2) inclusion of a wildfire risk factor, and 3) an 10
updated generation unit outage schedule. 11
With the continued high load growth in the Company’s 12
service area, the load forecast is consistently monitored 13
and updated as new information becomes available. Idaho 14
Power has experienced numerous wildfire-related outages on 15
major tie lines used to import power. The Company is 16
fortunate to have some diversity in transmission lines, and 17
that diversity will continue to expand in the future with 18
additions to the transmission system. However, given the 19
prevalence of wildfires in the recent past, the Company has 20
incorporated an adjustment to the availability of certain 21
transmission facilities. Additionally, due to permitting 22

2 Order No. 36322 issued on September 13, 2024, in Case No. IPC-E-24-20,
Idaho Power’s Application for Approval of the First Amendment to the
Power Purchase Agreement with PVS 2, LLC, approved the change in the
Scheduled Commercial Operation Date contained in the Power Purchase
Agreement from December 31, 2026, to May 31, 2026.
ELLSWORTH, DI 10
Idaho Power Company
delays, planned maintenance of one of the Oxbow hydro units 1
has been shifted from 2026 to 2027, adding to the capacity 2
deficit in 2027. 3
Q. Why is the capacity deficit a range between 4
298 MW and 320 MW, rather than a single annual capacity 5
deficit as presented previously? 6
A. Idaho Power has been experiencing a 7
significant increase to its winter peak load, as evidenced 8
by the Company’s all-time winter peak load record of 2,719 9
MW on January 16, 2024, surpassing the previous record by 10
over 100 MW and causing an energy emergency alert as 11
discussed below. In light of this new winter peak load 12
record, and because of the greater winter peak-day 13
temperature variability, the Company recognized the need to 14
revise its peak winter load forecasting methodology. For 15
the purposes of making resource decisions while the load 16
forecast was being updated, the Company began assessing its 17
capacity position under a range which utilizes two versions 18
of the load forecast; first being the 70th percentile peak 19
load for all months as was done in the 2023 IRP, second 20
being the 70th percentile peak load for March through 21
October, but utilizing a 95th percentile peak load for 22
November through February, which better addresses peak load 23
variability due to winter temperatures. 24
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ELLSWORTH, DI 11
Idaho Power Company
III. MEETING THE CAPACITY DEFICIENCY 1
Q. How does the Company propose to address the 2
2027 capacity deficit presented in this case? 3
A. As described in the Direct Testimony of Mr. 4
Hackett, on October 29, 2024, Idaho Power executed 5
agreements associated with the Jackalope Project, which 6
consists of the Jackalope Wind PPA, supplying 7
approximately 300 MW to the Company’s system, and the 8
Idaho Power-owned Jackalope Wind Project, also supplying 9
approximately 300 MW of generation. 10
Q. How does the addition of the Jackalope Project 11
impact the capacity deficit in 2027? 12
A. Including the methodological changes to the 13
market purchase assumptions and the peak load forecasts, 14
and assuming all 2026 projects and the Jackalope Project 15
reach commercial operation on time, the addition of the 16
Jackalope Wind PPA and the Jackalope Wind Project would 17
reduce the 2027 capacity deficit of 298 MW to 320 MW to a 18
capacity deficit of 203 MW to 217 MW. The addition of the 19
Jackalope Project, the first of the 2027 final shortlist 20
projects procured as a result of the 2026 RFP, will 21
support continued safe, reliable operations in 2027 and 22
beyond. 23
Q. You have indicated a capacity deficit will 24
still exist in 2027 even with the Jackalope Project. Will 25
ELLSWORTH, DI 12
Idaho Power Company
Idaho Power need to procure more resources to meet the 1
identified 2027 need? 2
A. Yes. However, because there are time 3
constraints associated with the Jackalope Wind PPA and the 4
Jackalope Wind Project contracts, Idaho Power is only 5
filing a request for approval of the Jackalope Project 6
agreements at this time. 7
Q. Why do you believe there is sufficient support 8
for the procurement of the Jackalope Project? 9
A. The resource acquisitions presented in this 10
case were pursued and procured as a least-cost, least-risk 11
method of meeting the capacity deficits first identified 12
in the Company’s 2021 IRP, again in the 2023 IRP, and 13
subsequently with the results of the updated system 14
reliability evaluation. The fluidity of the capacity 15
deficit period, continued high load growth, and supply 16
chain disruptions and delays further support these 17
resource procurements which are necessary to adequately 18
address 2027 capacity deficits. 19
Q. Are there any additional benefits beyond the 20
Jackalope Project being a least-cost, least-risk resource 21
necessary for meeting Idaho Power’s capacity needs? 22
A. Yes. Even absent the Company’s capacity needs, 23
the results of the AURORA modeling show that the Jackalope 24
Project would save customers money over the project’s life 25
ELLSWORTH, DI 13
Idaho Power Company
because it will provide Idaho Power cost-effective energy, 1
allowing the Company to reduce its reliance on existing, 2
more expensive, energy resources. 3
This economic benefit is illustrated in London 4
Economic International LLC’s (“LEI”) Closing Report: 2026 5
All Source Request for Proposals for Peak Capacity and 6
Energy Resources dated December 1, 2023 (“December 2023 7
LEI Report”), provided as Confidential Exhibit No. 3 to 8
the Direct Testimony of Mr. Hackett. As can be seen in 9
Figure 32, a list of the portfolio sensitivities analyzed, 10
Portfolios 1 and 4 are nearly equivalent, the only 11
difference being the inclusion of the Jackalope Project in 12
Portfolio 1. While Portfolio 4 is insufficient at meeting 13
the Company’s 2027 resource needs, the intent of Portfolio 14
4 was to provide a portfolio cost basis absent resource 15
additions in 2027. With a cost of , Portfolio 16
1, which includes the Jackalope Project, is approximately 17
lower cost than Portfolio 4,3 illustrating the 18
robust economic value of the Jackalope Project. 19
Q. Did the Company evaluate any alternative 20
solutions for meeting the 2027 capacity deficiency to avoid 21
building a new resource? 22
A. Yes. As I discussed earlier in my testimony, 23
as part of the IRP process, the Company uses AURORA’s LTCE 24

3 December 2023 LEI Report, page 62.
ELLSWORTH, DI 14
Idaho Power Company
modeling platform to develop portfolios, through the 1
selection of a variety of supply- and demand-side resource 2
options, that are least-cost for a variety of alternative 3
future scenarios while meeting reliability criteria. The 4
future supply- and demand-side resources available to meet 5
identified capacity deficiencies, whose costs are generally 6
based on the 2022 Annual Technology Baseline report 7
released by the National Renewable Energy Laboratory,4 8
include new gas-fired resources, wind, solar, battery 9
storage, market purchases via available transmission 10
capacity, demand response and energy efficiency. The 11
Preferred Portfolio from the 2023 IRP, which included a 12
July 2026 online date for B2H, identified the conversion of 13
Valmy Units 1 and 2 to natural gas, the combined 14
procurement of 400 MW of wind, 375 MW of solar, and 5 MW of 15
battery storage as the most cost-effective resources for 16
meeting the identified capacity deficits in 2027 along with 17
20 MW of energy efficiency potential (identified in the 18
energy efficiency potential study). The results are 19
indicative of the Company’s need to procure resources to 20
continue to provide safe, reliable electric service to its 21
customers in 2027 and beyond. 22

4 atb.nrel.gov/.
ELLSWORTH, DI 15
Idaho Power Company
Q. What actions has Idaho Power taken to-date to 1
acquire least-cost, least-risk resources to ensure 2
continued safe, reliable electric service in 2027? 3
A. Under Idaho law, Idaho Power has an obligation 4
to provide adequate, efficient, just, and reasonable 5
service on a nondiscriminatory basis to all those that 6
request it within its certificated service area.5 Further, 7
as indicated by Order No. 35643, Idaho Power is responsible 8
for planning and managing its load and resource portfolio 9
and the Commission expects “the Company to closely monitor 10
its projected capacity needs going forward and to act 11
proactively to ensure a robust RFP process can be 12
completed.”6 Therefore, in order to meet its obligations to 13
reliably serve customers, on September 15, 2022, Idaho 14
Power filed an application with the Public Utility 15
Commission of Oregon (“OPUC”) to open an independent 16
evaluator selection docket to oversee the Request for 17
Proposals (“RFP”) process.7 The Company’s compliance with 18
the OPUC competitive bidding guidelines, which the 19
Commission directed Idaho Power to follow as well8 and is 20
discussed in greater detail in the direct testimony of Mr. 21
Hackett, ultimately led to a competitive solicitation 22

5 Idaho Code §§ 61-302, 61-315, 61-507.
6 Page 13.
7 Docket UM 2255.
8 Order No. 32745. Case No. IPC-E-10-03.
ELLSWORTH, DI 16
Idaho Power Company
through the issuance of the 2026 All-Source RFP, seeking a 1
combination of energy and capacity resources that provide a 2
minimum of approximately 350 MW of peak capacity and up to 3
1,100 MW of variable energy resources for 2026 and 2027 4
(“2026 RFP”). 5
Given the significant timeframe related to the RFP 6
process under the OPUC competitive bidding guidelines, 7
which spans nearly 15 months and is solely related to the 8
RFP process and diligence and excludes the time required 9
for contract negotiation and execution, material 10
procurement, and construction, which can add another two to 11
six years to the process, the 2026 RFP was responsive to 12
the resource needs identified in the Company’s 2021 IRP 13
filing, which included near-term preferred portfolio 14
additions of wind, solar, storage, cost-effective energy 15
efficiency measures, the conversion of coal units to 16
natural gas, incremental demand response, and B2H coming 17
online in 2026. The RFP needed to remain flexible to 18
account for the fluidity of the Company’s annual capacity 19
positions as well as any potential delays in the B2H online 20
date and other projects. Ultimately, the 2027 resources 21
selected through the RFP process were based on the 22
recently-identified capacity deficiency of 298 MW to 320 MW 23
in 2027. Note, this 298 MW to 320 MW deficit is perfect 24
capacity, so it requires Idaho Power to procure 25
ELLSWORTH, DI 17
Idaho Power Company
significantly more megawatts of nameplate capacity, 1
depending on the ELCC of each resource. 2
Through the Company’s robust competitive bidding 3
process, Idaho Power identified the most cost-effective 4
bids from the 2026 RFP evaluation as necessary to fill the 5
2027 capacity deficit. The first, most cost-effective bid 6
resulted in the execution of the Jackalope Wind PPA, 7
supplying Idaho Power’s system with approximately 300 MW of 8
generation and the Company-owned Jackalope Wind Project, 9
also providing approximately 300 MW of generation. 10
IV. CONCLUSION 11
Q. Please summarize your testimony. 12
A. Idaho Power’s most recent system reliability 13
evaluation has identified a capacity deficiency range of 14
298 MW to 320 MW in 2027. In response to this resource 15
need, the Company has identified the Jackalope Project, 16
providing a combined 600 MW of wind generation, as the 17
least-cost, least-risk resource for which Idaho Power is 18
requesting the Commission approve the Jackalope Wind PPA 19
and grant a CPCN for the Jackalope Wind Project at this 20
time. 21
Q. Does this complete your testimony? 22
A. Yes, it does. 23
ELLSWORTH, DI 18
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 employed 4
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 this 8
pre-filed direct testimony in this matter. 9
3. To the best of my knowledge, my pre-filed 10
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