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HomeMy WebLinkAbout20250129IPC to Staff 21-30.pdf 0-10RHO POWER. DONOVAN WALKER RECEIVED Lead Counsel 25 dwalker(cDidahopower.com Wednesday, January 20 IDAHO PUBLIC UTILITIES COMMISSION January 29, 2025 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 Second Production Request of the Commission Staff to Idaho Power Company in the above matter. The confidential attachment 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 the Attachment to Response to Request No. 21 to Idaho Power Company's Response to the Second Production Request of the Commission Staff to Idaho Power, contains 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 29th day of January 2025. 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(o-)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 SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Second Production Request of the Commission Staff ("Commission" or "Staff") to Idaho Power Company dated January 15, 2025, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 1 REQUEST FOR PRODUCTION NO. 21: Please respond to the following regarding Loss of Load Expectation ("LOLE") reliability analyses for "Year 2028 before any adjustments" and "Year 2028 with adjustments of two Request for Proposal ("RFP") projects and industrial customers' load ramps". a. Please explain when these two analyses mentioned above were conducted. b. Please explain when the LOLE reliability analysis for the 2023 Integrated Resource Plan ("IRP") was conducted. c. Please provide the application status of the two RFP projects. d. Please explain whether these two RFP projects have been approved by the Commission. If not, please explain why these two RFP projects should be added as an adjustment to Year 2028. e. Please list all the projects that have not been approved by the Commission in the LOLE reliability analysis for Year 2028 and explain why they should be added in the analysis. f. Among all the projects that have not been approved, please specify the projects from previous RFPs. g. Please list all the industrial customers that will have load ramps in 2028. h. Please provide evidence that these industrial customers' load will ramp in 2028. i. Please explain the methodology used to annualize the impact of the industrial load ramp. j. Please provide the workpapers of the annualization process with formulas intact. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 2 RESPONSE TO REQUEST FOR PRODUCTION NO. 21: a. The two referenced analyses were performed in quarter four of 2024, prior to the Company filing the Application for Case No. IPC-E-24-42. b. Please note that a multitude of Loss of Load Expectation ("LOLE") reliability analyses were performed in the development of the Idaho Power's 2023 Integrated Resource Plan ("IRP"). The Company interprets this question to reference the identified high Loss of Load Probability ("LOLP") hours from the timing of highest risk analysis published in the 2023 IRP. Idaho Power's timing of highest risk analysis was developed for Case No. IPC-E-23-11 in quarters one and two of 2023; this analysis was reviewed and refined in quarter three of 2023 for inclusion in the Company's 2023 IRP (Case No. IPC-E-23-23). c. Idaho Power submitted the Application for approval of a Power Purchase Agreement ("PPA") with Jackalope Wind, LLC and a Certificate of Public Convenience and Necessity ("CPCN") for the Jackalope Wind project in Case No. IPC-E-24-46 at the end of quarter four of 2024; the current application status is "Notice Received." The other Request for Proposal ("RFP") project is still under contract negotiations. d. The two RFP projects referenced have not been approved by the Commission. Please note that the two RFP projects and industrial load ramp adjustments are not included in the Effective Load Carrying Capability ("ELCC") calculation; only existing and contracted resources at the time of the Blacks Creek project contract execution were included to determine the annual payment. The 2028 LOLE reliability analysis that includes the industrial load ramp and RFP resource IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 3 adjustments is only utilized to inform the monthly distribution of the annual payment. As Idaho Power is still in the process of contracting resources to fill the capacity need identified in the 2027 RFP and 2028 RFP, utilizing the most likely 2028 load and resource buildout allows for a better distribution of monthly capacity payments. e. As stated in part d of this response, existing and contracted resources at the time of the Blacks Creek project contract execution were included to determine the annual payment. Since establishing the capacity credit payment structure methodology in Case No. IPC-E-22-06 (and subsequent filings Case No. IPC-E- 22-29 and Case No. IPC-E-24-01), all contracted resources at the time of the specified project's contract execution are included in the annual payment calculation. For the Blacks Creek project 2028 LOLE reliability analyses, the battery storage facility specified in Case No. IPC-E-24-16 was included; this resource was contracted prior to the Blacks Creek project but was approved by the Commission after the Blacks Creek project contract execution. The two battery storage facilities specified in Case No. IPC-E-24-45 were also included in the Blacks Creek project 2028 reliability analyses; these resources are not yet approved by the Commission but were contracted prior to the Blacks Creek project. Please see parts c. and d. of this response for a description of the two RFP projects not yet approved by the Commission that were added to inform the monthly payment distribution of the 2028 LOLE reliability analysis with adjustments. In preparing this response, the Company found that one of the two battery storage projects from Case No. IPC-E-24-45 was not contracted prior to the Blacks IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY-4 Creek project. As a result, 50 MW of 4-hour Battery Energy Storage System ("BESS") was included in the ELCC calculation of Blacks Creek when it should have been excluded. The Company will submit revised tariff sheets in a future compliance filing but has answered the remainder of these responses based on the values submitted in the original Application. f. The two battery storage facilities specified in Case No. IPC-E-24-45 were identified to fill the capacity need in the 2026 RFP. The Jackalope Wind project from Case No. IPC-E-24-46 and the other RFP project still under contract negotiations were identified to fill the capacity need in the 2027 RFP. g. For the 2028 LOLE reliability analysis with adjustments, the industrial load ramps considered for modification were from customers Meta and Micron. h. Please see the file labeled "Confidential Attachment — Response to Staff Request No. 21" for the 2028 industrial load ramps. i. The difference in the January through February and November through December industrial load ramps was calculated to be approximately 70 megawatts ("MW"). The approximate 70 MW was then added as a resource available in November and December to annualize the impact of the industrial load ramp. j. Please see the file labeled "Confidential Attachment - Response to Staff Request No. 21"for the differences in the winter industrial load ramps. The differences were approximated to be 70 MW. A value of 70 MW was then added as a resource available in November and December to reduce the impact of the industrial load ramp; this was completed in the Company's Reliability and Capacity Assessment Tool ("RCAT"). The resulting monthly LOLE values were then calculated and IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 5 utilized to produce 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 SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 6 REQUEST FOR PRODUCTION NO. 22: Please explain whether the capacity contribution of 18.44% is determined in the LOLE reliability analysis for Year 2028 with adjustments for the two RFP projects and industrial customers' load ramps. RESPONSE TO REQUEST FOR PRODUCTION NO. 22: The capacity contribution calculation of 18.44% was determined using the LOLE reliability analysis for year 2028 that does not have any resource or load adjustments. Only contracted resources and the published load forecast available at the time of the Blacks Creek project contract execution were utilized to determine the ELCC. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 7 REQUEST FOR PRODUCTION NO. 23: Response to Production Request No. 11(a) states that the identified high Loss of Load Probability ("LOLP") hours started with a baseline from the 2023 Integrated Resource Plan ("IRP") and expanded hours to capture hours of higher irradiance. Please respond to the following. a. Please explain why the Company used high LOLP hours from the 2023 IRP as a baseline, which was based on the Year 2025. b. Please explain why the Company did not directly determine high LOLP hours based on the LOLP profiles of Year 2028 with adjustments of two RFP projects and industrial customers' load ramps. c. Please provide the identified high LOLP hours based on the LOLP profiles of Year 2028 with adjustments of two RFP projects and industrial customers' load ramps. d. When the Company added expanded hours to the baseline from the 2023 IRP, please explain how the expanded hours were determined. e. What does "irradiance" mean? Does it mean Plane of Array ("PDX) Irradiance? f. Please provide the definition of POA and explain whether it represents the expected output of a solar facility. g. Please explain why the identified high LOLP hours should consider the timing of higher irradiance, instead of focusing on the system's high LOLP hours alone. h. Please explain the impact if the timing of higher irradiance is not considered. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 8 RESPONSE TO REQUEST FOR PRODUCTION NO. 23: a. The timing of highest risk published in the 2023 IRP is the latest available update and represents Idaho Power's currently identified hours and months of capacity need, regardless of the analysis year. The Company will publish an update to the timing of highest risk analysis in the 2025 IRP. b. As stated in the Company's Response to Request for Production No. 11, the Blacks Creek project ELCC calculation accounts for the 2028 high LOLP hours. The timing of highest risk published in the 2023 IRP represents Idaho Power's currently identified hours and months of capacity need; therefore, an update is not necessary. Please note that the high LOLP hours from the 2023 IRP timing of highest risk analysis are only utilized as a baseline to inform the performance ratio calculation; the high LOLP hours are included to ensure the Company's timing of capacity need is considered and expanded upon to create a wider range of hours to mitigate measurement variability. c. Please see the responses to parts a and b of this response for an explanation as to why a timing of highest risk analysis was not performed outside of the IRP filing. However, the Company provided the hourly LOLP values for the 2028 year with adjustments in the file labeled "Response to Request for Production No. 5". d. The expanded hours were based upon the solar energy production patterns and typical sun path for the state of Idaho during the summer and winter months. Please note that the hours were expanded solely to reduce the solar generation measurement variability (by including more data points from the sunlight hours) to accurately assess whether a facility is operating as expected. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 9 e. Irradiance is a measure of the power of electromagnetic radiation per unit area incident on a surface. It is typically expressed in watts per square meter. For the Company's Response to Request for Production No. 11, yes, "irradiance" refers to the Plane of Array ("POA") irradiance which is utilized in the performance ratio calculation. f. The POA irradiance refers to the amount of solar energy per unit area that is incident on the surface of a solar array (i.e., the "plane" that the array lies on) over a specific period of time. It is dependent on several factors, including the time of day, season, geographical location, weather conditions, and the orientation and tilt of the panels. The POA irradiance is given by: GPOA = Gb + Gd + Gr Where Gb is the direct irradiance on the tilted plane, Gd is the diffuse irradiance on the tilted plane, and Gr is the reflected irradiance on the tilted plane. The direct irradiance on the tilted plane (Gb) is given by: Gb = DNI • COS (0) Where DNI is the direct normal irradiance and 0 is the angle of incidence between the direct beam and the normal to the array surface. The angle of incidence depends on the position of the sun in the sky and the orientation of the panel; it is given by: COS (0) = COS(OZ) COS(0T) + sin(OZ) sin (sin(OT) COS (OA — Oarray)) Where OA and OZ are the solar azimuth and zenith angles and OT and 0array are the tilt and azimuth angles of the array. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 10 The diffuse irradiance on the tilted plane (Gd) is given by: Gd = DHI C1 + cos (BT)) 2 Where DHI is the diffuse horizontal irradiance. The reflected irradiance on the tilted plane (Gr) is given by: C )G,- _ (DNI • sin (a) • DHI) • p • 1 — Cos (BT)2 Where a is the solar altitude angle and p is the ground reflectance (albedo). The POA irradiance would represent the expected output of a solar plant under standard test conditions. However, the expected output of a solar facility (or its power generation) depends on how efficiently the solar panels can convert the POA irradiance into usable electricity, which is influenced by panel efficiency, system losses and environmental factors. This means the generation output of a solar photovoltaic panel is directly proportional to the amount of irradiance it receives, the efficiency of the panel, and the surface area of the panel. g. As stated in the Company's Response to Request for Production No. 11, having a wider range of hours (more data points) in the performance ratio calculation mitigates potential errors when dealing with small generation numbers (late evening hours and winter hours). If the high LOLP hours were utilized with no expansion to account for hours of higher irradiance, the performance ratio calculation could suggest that a solar plant that is actually performing as expected is performing poorly due to poor data selection. The performance ratio is calculated based on the plant output and the solar irradiance; if there is no solar output or no irradiance in the high LOLP hours, the performance ratio cannot be accurately IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 11 assessed. h. Please see the response to part g. of this response. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 12 REQUEST FOR PRODUCTION NO. 24: The footnote of Attachment No. 3 of the Application states that the expanded hours were added to reduce the solar generation measurement variability. Please explain why the variability needs to be reduced and provide an example to illustrate how the variability can be reduced by adding the expanded hours. RESPONSE TO REQUEST FOR PRODUCTION NO. 24: Please see the Company's Response to Request for Production No. 23, part g. Reducing the solar generation measurement variability is important to increase the accuracy of the performance ratio calculation. Please see the file labeled "Attachment- Response to Staff Request No. 24" for the requested example. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 13 REQUEST FOR PRODUCTION NO. 25: Response to Production Request No. 11(a) states that "[h]aving 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." Does the statement mean if the expanded hours are not added, the data points for calculated each month's performance ratio will be too limited and thus the result will be inaccurate? If not, please explain in detail what the statement means. RESPONSE TO REQUEST FOR PRODUCTION NO. 25: Yes, this statement implies that if the expanded hours are not included, the data points for calculating each month's performance ratio may be too limited, which could result in potential inaccuracies. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 14 REQUEST FOR PRODUCTION NO. 26: Response to Production Request No. 15 (b) stated that "[t]he 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..." Please explain what "the Network Upgrades for the non-usage sensitive portion of transmission charges" means. RESPONSE TO REQUEST FOR PRODUCTION NO. 26: The non-usage sensitive portion of transmission charges refers to charges that do not depend on the actual usage of the transmission system. Essentially, these are charges that are not based on the actual amount of energy transmitted but rather are based on the transmission that would be required to be reserved on the system under Idaho Power's Open Access Transmission Tariff ("OATT") for this generation to move beyond the interconnection point. The transmission service rate associated with transmission reservations are specified under Schedule 7, Schedule 8, or Schedule 9 of the GATT. These schedules outline the transmission service rate a customer must pay for which represents the investment and operational and administrative costs associated with providing transmission service under either a point-to-point transmission service or network transmission service agreement, one of which is required under the OATT to move any energy beyond the generator interconnection point. The rates charged under the rate schedules mentioned are determined by Idaho Power's FERC filed formula rate methodology and costs and investments feeding the rate calculation updated with FERC in an annual filing. The non-usage sensitive portion of transmission charges does not include costs or charges that are calculated based on the actual use of the transmission system. Usage- IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 15 sensitive charges are separate OATT schedules and are designed to recover costs directly associated with the delivery of the Generating Facility's actual output. Items considered usage-sensitive and not included in the non-usage sensitive portion include but are not limited to line losses, generator imbalance energy charges, other Energy Imbalance Market ("EIM") charges, and ancillary services. The response to this Request is sponsored by Kathy Anderson, Transmission and Markets Senior Manager, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 16 REQUEST FOR PRODUCTION NO. 27: Response to Production Request No. 13 shows a data point of 100% Effective Load Carrying Capability ("ELCC") at 1.0 Performance Ratio. Please respond to the following. a. Please explain why the Company assumes ELCC should be 100% at 1.0 Performance Ratio. b. Under what circumstances is an ELCC typically assumed to be greater than 100% at 1.0 Performance Ratio? c. Under what circumstances is an ELCC typically assumed to be less than 100% at 1.0 Performance Ratio? d. The linear trendline equation included in Response No. 13 (a) will result in an ELCC greater than 100% at a 1.0 Performance Ratio. Please explain how it is possible to have an ELCC greater than 100% at a 1.0 Performance Ratio. RESPONSE TO REQUEST FOR PRODUCTION NO. 27: a. The Company does not assume the ELCC should be 100% at a performance ratio of 1.0. The Company assumes that when the performance ratio is 1.0, the Blacks Creek project ELCC should receive no decrement. Please note that the y-axis of Figure 2 in Attachment 3 of the Application is the percentage of original ELCC, meaning at a 1.0 performance ratio 100% of the originally calculated ELCC is 18.44%. b. There is no circumstance where the Blacks Creek ELCC would be greater than 100% at a 1.0 performance ratio. If the resulting performance ratio is calculated to be 1.0 or above (or 0.95 or above for the summer months), the Blacks Creek project ELCC would receive no adjustment and would remain at 18.44%. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 17 c. The Blacks Creek project ELCC was calculated to be 18.44%; therefore, there is no scenario where the ELCC would be greater than 18.44%. If the resulting performance ratio is calculated to be below 1.0 (or below 0.95 for the summer months), which means the solar photovoltaic facility is not operating as expected, the ELCC of 18.44% would be decreased. For example, if the performance ratio was calculated to be 0.8, the resulting ELCC would be 85.96% of the original ELCC; this means the ELCC of 18.44% would decrease to 15.85% when representing the monthly payment reduction. d. As stated in part a of the Company's Response to Request for Production No. 13, when calculating the payment reduction, linear interpolation between the data points is utilized, not the equation of the best-fit straight line. Please see 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 SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 18 REQUEST FOR PRODUCTION NO. 28: Response to Production Request No. 13 states that "linear interpolation between the data points is utilized, not the equation of the best-fit straight line." Please explain why linear interpolation between the data points is utilized, instead of the best-fit straight line. RESPONSE TO REQUEST FOR PRODUCTION NO. 28: While linear interpolation and the best-fit linear equation (or least squares regression) are both methods of estimating values between data points, they have different purposes and applications. Linear interpolation connects the calculated data points with straight lines, ensuring that the value at each data point is exactly reproduced; it does not introduce any error in between the points. The best-fit linear equation does not guarantee that the line will pass through any of the calculated data points; this can introduce small errors for each individual point. Because linear interpolation respects the original ELCC calculations values and point-to-point relationship, it provides a better representation than the best-fit linear equation. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 19 REQUEST FOR PRODUCTION NO. 29: In reference to Response to Production Request No. 13, please compare these three methods below for payment reduction rate calculation and explain the advantages and disadvantages of each method. 1. Using linear interpolation between the data points. 2. Using best-fit straight line. 3. Using best-fit straight line with constraint of 100% ELCC at a 1.0 Performance Ratio. RESPONSE TO REQUEST FOR PRODUCTION NO. 29: Please see the Company's Response to Request for Production No. 28 for an explanation as to why the linear interpolation method is a better approach for representing the relationship between the percentage of original ELCC and the performance ratio as compared to the best-fit linear equation method. Referencing Table 9 from Attachment 3 of the Application, the example performance ratio of 0.98 for December produces a payment reduction of: 1. 1.31% using the linear interpolation method. 2. 0.46% when using the best-fit linear equation method. 3. Constraining the best-fit linear equation to 100% of the original ELCC at a performance ratio of 1.0 has no impact; please see the Company's Response to Request for Production No. 27. The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 20 REQUEST FOR PRODUCTION NO. 30: Please explain how to derive payment reduction rate from June through September with an example, when the performance ratio target is at least 0.95. RESPONSE TO REQUEST FOR PRODUCTION NO. 30: As explained in the Company's Response to Request for Production No. 27, if the resulting performance ratio is calculated to be 0.95 or above for the summer months, the Blacks Creek project monthly payment would receive no reduction. When the performance ratio is below the 0.95 threshold for the summer months, please reference the example discussed in the meeting between Idaho Power and Idaho Public Utilities Commission Staff on June 6, 2024, for Case No. IPC-E-24-01. ELCC & Performance Ratio Targets ��N� POMR 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 .00 U.00 $324,271 1.0 100.00% February 1.13 0.00%b $324,271 March 1.08 0.00% $17,294 Yi-A April (xl-xo Y=Yo+(x-xo) ) May - - - June 0.94 0.8% $962,162 1.0-0.9203 July 1.00 0.00% $1,919,682 y=0.9203+(0.95-0.9) 96.0% 1.0-0.9 August 0.99 0.00% $959,841 September 0.97 0.00% $17,294 1.0-0.9203 o October 1.01 0.00% $17,294 y=0.9203+(0.94-0.9) 95.2/o 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 The response to this Request is sponsored by Andres Valdepena Delgado, System Consulting Engineer, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY-21 Respectfully submitted this 29th day of January 2025. DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY- 22 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 29th day of January 2025, 1 served a true and correct copy of Idaho Power Company's Response to the Second 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(c�puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Stacy Gust Regulatory Administrative Assistant IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE COMMISION STAFF TO IDAHO POWER COMPANY-23 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY CONFIDENTIAL REQUEST NO. 21 ATTACHMENT BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-24-42 IDAHO POWER COMPANY REQUEST NO. 24 ATTACHMENT SEE ATTACHED SPREADSHEET