20250307APPLICATION - Redacted.pdf

HIQAW POWER,
DONOVAN WALKER RECEIVED
Lead Counsel March 7, 2025
dwalker(a)idaho power.corn Idaho Public
Utilities Commission
March 7, 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-25-08
Application for a Certificate of Public Convenience and Necessity for an
Ownership Interest in the Southwest Intertie Project — North 500-kV
Transmission Line and Approval of the Utilization of Capacity on the Line.
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's ("Idaho Power")
Application and the Direct Testimony of Jared Ellsworth and exhibits in the above matter.
A Word version of the Direct Testimony of Jared Ellsworth will be sent in a separate email
for the Reporter.
Also attached is a Protective Agreement. Due to the voluminous nature of
confidential and non-confidential information provided, the Company is posting the Direct
Testimony of Jared Ellsworth and exhibits to the secure FTP site to allow parties to view
the requested information remotely. Because certain attachments contain confidential
information, the FTP site is divided between confidential and non-confidential information.
The login information for the non-confidential portion of the FTP site will be provided to
all parties, while the login information for the confidential portion will only be provided to
those parties who have executed the Protective Agreement in this matter.
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

Commission Secretary
Idaho Public Utilities Commission
March 7, 2025
Page 2
If you have any questions about any of the aforementioned documents, please do
not hesitate to contact me.
Very truly yours,
Donovan E. Walker
DEW:sg
Enclosures

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-25-08
Idaho Power Company's Application for a Certificate of Public Convenience and
Necessity for an Ownership Interest in the Southwest Intertie Project— North 500-
KV Transmission Line and Approval of the Utilization of Capacity on the Line
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Application, Direct Testimony of Jared Ellsworth and Exhibit No. 5 to the
Direct Testimony of Jared Ellsworth dated March 7, 2025, contain information that Idaho
Power Company and a third party claims 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 7th day of March 2025.
Donovan E. Walker
Attorney 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: [phone]
Facsimile: [phone]
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 A ) CASE NO. IPC-E-25-08
CERTIFICATE OF PUBLIC )
CONVENIENCE AND NECESSITY FOR ) APPLICATION
AN OWNERSHIP INTEREST IN THE )
SOUTHWEST INTERTIE PROJECT - )
NORTH 500-KV TRANSMISSION LINE )
AND APPROVAL OF THE UTILIZATION )
OF CAPACITY ON THE LINE. )
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 RP 52, 112 and 201, hereby
respectfully makes application to the Idaho Public Utilities Commission ("Commission")
for an order (1) granting a Certificate of Public Convenience and Necessity ("CPCN" or
"Certificate") for Idaho Power's ownership interest in the Southwest Intertie Project —
North, 500-kilovolt ("kV")transmission line ("SWIP-North" or"Project"), including the rights
to 250 megawatts ("MW") of the northbound capacity, and (2) approving the Company's
utilization of an additional 250 MW of GBT Northbound, LLC's ("GBT Northbound") rights
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 1

to the northbound capacity, both via the SWIP-North agreements. In total, the Company
will gain 500 MW of south-to-north capacity on the total Southwest Intertie Project'
transmission line ("Total SWIP"), providing a cost-effective resource addition necessary
to meet identified capacity deficiencies.
Accompanying this Application is the Direct Testimony of Jared L. Ellsworth
presenting the need and justification for Idaho Power's participation in the Project and the
associated SWIP-North agreements the Company has entered in to, including (1) an
overview of the SWIP-North project and its load serving capacity, (2) the evaluation of the
Project as part of the Integrated Resource Planning process and identification as a
valuable component of Idaho Power's future resource portfolio, and (3) a description of
the unique attributes and other benefits offered by SWIP-North.
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.
II. THE SOUTHWEST INTERTIE PROJECT
2. SWIP-North is an approximately 285 mile, near shovel ready, 500-kV line
that will connect the Midpoint substation, near Shoshone, Idaho, to the Robinson Summit
Inclusive of SWIP-North and SWIP-South.
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 2

substation, near Ely, Nevada. SWIP-North will connect to the existing Southwest Intertie
Project—South 500-kV line ("SWIP-South"), an existing 231 mile 500-kV line that extends
between the Robinson Summit substation and the Harry Allen substation, northeast of
Las Vegas. When combined, SWIP-North and SWIP-South form the Total SWIP.
3. The ownership and capacity entitlements associated with SWIP-South, as
well as SWIP-North and Total SWIP once completed, are all governed by the Second
Amended and Restated Transmission Use and Capacity Exchange Agreement by and
among Nevada Power Company, Sierra Pacific Power Company, Great Basin
Transmission South, LLC, and Great Basin Transmission, LLC, dated as of June 30, 2020
("TUX),2 which is included as Exhibit No. 2 to Mr. Ellsworth's Direct Testimony. Under
the TUA, Great Basin Transmission South, LLC ("GBT South") and NV Energy agreed to
build SWIP-South, as the first phase of the project, which has been providing NV Energy
benefits over the prior decade.3 In addition, the TUA contemplated SWIP-North and the
Total SWIP as a whole and therefore contains definitive provisions for both.
4. Immediately following completion of SWIP-South, NV Energy owned 25
percent of SWIP-South, which was obtained through payment of 25 percent of the SWIP-
South costs. GBT South funded the remaining 75 percent of the costs but is receiving
recovery of those costs through TUA payments from NV Energy. Given NV Energy
customers are ultimately paying for all SWIP-South costs, all rights associated with SWIP-
2 Both Nevada Power Company and Sierra Pacific Power Company conduct business as NV Energy so
are collectively referred to as NV Energy.
3 In February 2011, Great Basin Transmission, LLC ("GBT") assigned all of its ownership interest in
SWIP-South to GBT South but retained its obligations under the original Transmission Use and Capacity
Agreement dated August 20, 2010, on a joint and several basis with GBT South.
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 3

South are currently allocated to NV Energy and NV Energy controls all capacity
associated with SWIP-South.
5. Under the provisions of the TUA, once SWIP-North is energized and the
resulting Total SWIP is entered in-service, NV Energy will continue to fund all costs
associated with SWIP-South through the TUA payments to GBT South and GBT South
will continue to own its share of SWIP-South assets. However, pursuant to the TUA, the
transmission capacity allocations across SWIP-South will change upon installation of
SWIP-North. As the owner and developer of SWIP-North, and an affiliate of GBT South,
GBT will receive a portion of the capacity across SWIP-South and NV Energy gains
capacity across SWIP-North. Following the addition of SWIP-North, the capacity
allocations are as follows:
SWIP-South SWIP-North
North-to- South-to- North-to- South-to-North
South North South
NV Energy 1,217.5 MW 1,172.5 MW 952.5 MW 847.5 MW
GBT 1,117.5 MW 1,072.5 MW 1,117.5 MW 1,072.5 MW
The capacity allocations prior to, and after SWIP-North energization, are detailed in
Exhibit No. 3 to Mr. Ellsworth's testimony.
III. SWIP-NORTH AND THE INTEGRATED RESOURCE PLAN
6. As part of the 2021 Integrated Resource Plan ("IRP"), the Company
evaluated a hypothetical SWIP-North scenario that identified potential benefits associated
with the Project. As a result, the 2021 IRP included an Action Plan item focused on
partnership opportunities related to SWIP-North. The Company began discussions with
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY-4

GBT and acquired sufficient information to perform a thorough and detailed analysis
coincident with the modeling of the 2023 IRP.
7. SWIP-North was analyzed as part of the 2023 IRP as providing a 500 MW
resource equivalent capacity, from the Desert Southwest ("DSW") market, in the winter
months beginning in 2028. Costs were modeled to reflect a 22.83 ownership interest for
Idaho Power.
8. The best way to identify a transmission project's financial benefits is to
consider the optimal portfolio of transmission and generation projects (i.e., the least-cost
and least-risk portfolio) both with the transmission project and without the transmission
project. Therefore, Idaho Power analyzed ten portfolio topologies without SWIP-North and
those same ten portfolio topologies with SWIP-North, utilizing a November 2028 in-
service date. The results indicated that a portfolio inclusive of SWIP-North was lower cost
than its complementary portfolio that excluded SWIP, an estimated lower
cost on a net present value basis.
IV. IDAHO POWER'S PARTICIPATION AND OWNERSHIP IN SWIP-NORTH
9. The SWIP-North is nearly construction ready and planned to be online in
2028. As such, GBT began negotiations to contract the additional capacity entitlements
gained along Total SWIP once SWIP-North is energized, including dedicating all its
capacity entitlements to California Independent System Operator ("CAISO") except for
500 MW of south-to-north capacity entitlements, which will be dedicated to Idaho Power.
10. The Company's participation in, and joint ownership of, SWIP-North has
been memorialized in the following agreements for which Idaho Power is requesting
approval in this case: (1) the Participation and Joint Ownership Agreement by and among
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 5

Great Basin Transmission, LLC, GBT Northbound, LLC and Idaho Power Company dated
as of February 13, 2025, (2) the Capacity Entitlement Agreement by and between GBT
Northbound, LLC and Idaho Power Company dated as of February 13, 2025 ("Capacity
Entitlement Agreement"), (3) the Purchase and Sale Agreement by and between GBT
Northbound, LLC and Idaho Power Company dated as of February 13, 2025, and (4) the
Purchase Option Agreement by and between GBT Northbound, LLC and Idaho Power
Company dated as of February 13, 2025 (collectively, the "Definitive Agreements"). The
Definitive Agreements are included as Confidential Exhibit No. 5 to Mr. Ellsworth's direct
testimony.
11. The Definitive Agreements address SWIP-North ownership, the Company's
entitlement rights to utilize SWIP-South capacity and transact across the Total SWIP,
conditions precedent to construction, rights during construction, and Project upgrade
rights, among other general contract provisions. Once energized, the Definitive
Agreements provide for Idaho Power's undivided ownership interest in approximately
11.4 percent, or 250 MW, of SWIP-North, fully funding the capital requirements of this
portion of the Project. GBT will own the remaining approximately 11.4 percent interest, or
the remaining 250 MW, in SWIP-North, providing the asset to Idaho Power to utilize via
the Capacity Entitlement Agreement. The Company will be given the entitlement right to
utilize the approximately 250 MW of capacity for 40 years, at which time Idaho Power will
have the option to purchase the asset from GBT Northbound. The Company's rights
associated with its ownership interest and capacity entitlement interest in the Project are
functionally equivalent.
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 6

V. CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
12. 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 additional resources to meet the identified capacity deficits on its system in order
to comply with its continuing obligation to serve customers and thus is requesting an order
from the Commission affirming that the public convenience and necessity requires the
same. The SWIP-North represents a cost-effective means of providing adequate and
reliable service to the customers in Idaho Power's certificated service territory.
13. 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.
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 7

14. A CPCN or Certificate represents the exercise by the Commission of its
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
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.).
15. 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
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 8

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.
VI. RATEMAKING TREATMENT FOR SWIP-NORTH OWNERSHIP
16. Idaho Power is not requesting binding ratemaking treatment 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
rights to approximately 11.4 percent of the northbound capacity of SWIP-North. The
Company will make a future filing to address the cost recovery associated with Idaho
Power's ownership interest in the Project.
VII. FINANCING THE SWIP-NORTH
17. 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 Baal, 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 February 28, 2025. 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
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 9

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. IDACORP sold an additional $92 million of its common stock
in the fourth quarter of 2024 through its at-the-market program under a forward sale
agreement which may be physically settled by delivering shares of stock in 2025. The
cash proceeds will be used primarily to infuse equity to Idaho Power. The Company
intends to finance its 250 MW ownership of the northbound capacity on SWIP-North with
a combination of available cash and operating cash flow, available credit facilities and
borrowing and debt issuances, and future equity infusions by IDACORP.
VIII. COMMUNICATIONS AND SERVICE OF PLEADINGS
18. 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
dwalker _idahopower.com ttatum _idahopower.com
dockets(o-)idahopower.com
IX. MODIFIED PROCEDURE
19. 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
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 10

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.
X. REQUEST FOR RELIEF
Idaho Power respectfully requests that the Commission issue an order (1) granting
a CPCN for Idaho Power's ownership interest participation in the SWIP-North 500-kV
transmission line, including the rights to 250 MW of the northbound capacity, and (2)
approving the Company's utilization of an additional 250 MW of GBT Northbound rights
to the northbound capacity, both via the SWIP-North agreements. In total, the Company
will gain 500 MW of south-to-north capacity on SWIP-North, providing a cost-effective
resource addition necessary to meet identified capacity deficiencies.
DATED at Boise, Idaho this 7t" day of March 2025.
DONOVAN E. WALKER
Attorney for Idaho Power Company
APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY- 11