20250313Direct Ellsworth.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY' S APPLICATION FOR ) CASE NO. IPC-E-25-10
APPROVAL OF A POWER PURCHASE )
AGREEMENT AND AN ENERGY STORAGE )
AGREEMENT WITH CRIMSON ORCHARD )
SOLAR LLC. )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
JARED L. ELLSWORTH

1 Q. Please state your name, business address, and
2 present position with Idaho Power Company ("Idaho Power" or
3 "Company") .
4 A. My name is Jared L. Ellsworth and my business
5 address is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power as the Transmission, Distribution &
7 Resource Planning Director for the Planning, Engineering &
8 Construction Department.
9 Q. Please describe your educational background.
10 A. I graduated in 2004 and 2010 from the
11 University of Idaho in Moscow, Idaho, receiving a Bachelor
12 of Science Degree and Master of Engineering Degree in
13 Electrical Engineering, respectively. I am a licensed
14 professional engineer in the State of Idaho.
15 Q. Please describe your work experience with
16 Idaho Power.
17 A. In 2004, I was hired as a Distribution
18 Planning engineer in the Company' s Delivery Planning
19 department. In 2007, I moved into the System Planning
20 department, where my principal responsibilities included
21 planning for bulk high-voltage transmission and substation
22 projects, generation interconnection projects, and North
23 American Electric Reliability Corporation' s reliability
24 compliance standards . I transitioned into the Transmission
25 Policy & Development group with a similar role, and in
ELLSWORTH, DI 1
Idaho Power Company

1 2013, I spent a year cross-training with the Company' s Load
2 Serving Operations group. In 2014, I was promoted to
3 Engineering Leader of the Transmission Policy & Development
4 department and assumed leadership of the System Planning
5 group in 2018 . In early 2020, I was promoted into my
6 current role as the Transmission, Distribution and Resource
7 Planning Director. I am currently responsible for the
8 planning of the Company' s wires and resources to continue
9 to provide customers with cost-effective and reliable
10 electrical service.
11 Q. What is the Company' s request in this case?
12 A. Idaho Power is requesting the Idaho Public
13 Utilities Commission ("Commission") issue an order (1)
14 approving the 20-year Power Purchase Agreement ("PPA")
15 between Crimson Orchard Solar LLC and Idaho Power Company
16 supplying the 100 megawatts ("MW") output to the Company
17 ("Crimson Orchard PPA") , (2) approving the 20-year Energy
18 Storage Agreement ("ESA") between Crimson Orchard Solar LLC
19 and Idaho Power for 100 MW of dispatchable energy storage
20 capacity ("Crimson Orchard ESA") , and (3) acknowledging the
21 lease accounting necessary to facilitate the transaction
22 and that the resulting expenses associated with both the
23 PPA and the ESA are prudently incurred for ratemaking
24 purposes . Both the Crimson Orchard PPA and the Crimson
25 Orchard ESA, collectively, referred to as the "Crimson
ELLSWORTH, DI 2
Idaho Power Company

1 Orchard Project", are necessary for the Company to continue
2 to provide safe, reliable electric service in 2027 and
3 beyond.
4 Q. What is the purpose of your testimony in this
5 case?
6 A. The purpose of my testimony is to inform the
7 Commission of the Company' s need for new resources to meet
8 an identified capacity deficit in 2027 as informed by a
9 Loss of Load Expectation ("LOLE") methodology utilized in
10 the 2021 Integrated Resource Plan ("IRP") , again in the
11 2023 IRP, and subsequently further enhanced through system
12 reliability evaluations . I will describe the most recent
13 assessment of system reliability and its impact to the
14 capacity deficit identified in the previous system
15 reliability assessment. Finally, I will provide support for
16 the acquisition of resources to address the identified
17 near-term capacity needs .
18 Q. Is this the same assessment of system
19 reliability that was performed to support the Company' s
20 request in Case No. IPC-E-24-46, Idaho Power Company's
21 Application for Approval of a Power Purchase Agreement with
22 Jackalope Wind, LLC, and for a Certificate of Public
23 Convenience and Necessity for the Jackalope Project
24 ("Jackalope Project") , which was also specific to 2027
25 capacity needs?
ELLSWORTH, DI 3
Idaho Power Company

1 A. No. The system reliability assessment
2 performed to support the Company' s request in this case
3 includes refreshed inputs and assumes the resources for
4 which Idaho Power seeks approval in Case No. IPC-E-24-46,
5 the Jackalope Project, are online by June 1, 2027 . The most
6 resent system reliability assessment identifies a 2027
7 capacity deficit of 123 MW.
8 I . BACKGROUND
9 Q. What is the goal of the IRP?
10 A. The goal of the IRP is to ensure : (1) Idaho
11 Power' s system has sufficient resources to reliably serve
12 customer demand and flexible capacity needs over a 20-year
13 planning period, (2) the selected resource portfolio
14 balances cost, risk, and environmental concerns, (3)
15 balanced treatment is given to both supply-side resources
16 and demand-side measures, and (4) the public is involved in
17 the planning process in a meaningful way. Idaho Power uses
18 Energy Exemplar' s AURORA' s Long-Term Capacity Expansion
19 ("LTCE") modeling platform to develop portfolios, through
20 the selection of a variety of supply- and demand-side
21 resource options, that are least-cost for a variety of
22 alternative future scenarios while meeting reliability
23 criteria . To verify the top performing portfolios meet the
24 Company' s reliability requirements, Idaho Power utilizes a
25 LOLE methodology.
ELLSWORTH, DI 4
Idaho Power Company

1 Q. Please explain the Loss of Load Expectation.
2 A. The LOLE is a statistical measure of a
3 system' s resource adequacy, describing the expected number
4 of event-days per year that a system would be unable to
5 meet demand. As utilities continue to add more renewable
6 energy to the electric grid, analyzing the effect variable
7 energy resources have on system reliability has become more
8 critical . The LOLE methodology recognizes that the output
9 of variable energy resources, such as wind and solar,
10 change with time (with their hourly output being dependent
11 on a multitude of factors like weather and environmental
12 conditions) ; it is essential to capture and value that
13 variability.
14 Q. What inputs are derived from the LOLE
15 methodology that are utilized in the AURORA LICE model?
16 A. Idaho Power implements the LOLE methodology
17 through an internally developed Reliability and Capacity
18 Assessment Tool ("RCAT") which is capable of producing
19 inputs such as a Planning Reserve Margin ("PRM") and
20 resource Effective Load Carrying Capability ("ELCC")
21 values . The PRM metric can be defined as the percentage of
22 expected capacity resources above forecasted peak demand.
23 The ELCC calculation is a reliability-based metric used to
24 assess the capacity contribution of variable and energy-
25 limited resources . The PRM and ELCC values that are
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Idaho Power Company

1 calculated using the LOLE methodology are a direct input to
2 the AURORA LTCE model .
3 Q. How are the PRM and ELCC values utilized?
4 A. Because the AURORA LTCE model and the RCAT are
5 two separate tools, a translation is required between the
6 probabilistic LOLE analysis performed in RCAT and the
7 portfolios produced by the AURORA LTCE model . First, PRM
8 and ELCC values are calculated using the LOLE methodology,
9 which serve as direct inputs to the AURORA LTCE model .
10 After AURORA solves for and produces portfolios, select
11 resource buildouts and their corresponding data are
12 analyzed with the LOLE methodology and tested to ensure
13 they meet the pre-designated reliability hurdle through the
14 calculation of annual capacity positions . It is critical
15 when comparing future resource portfolios that each plan
16 achieves at least a base reliability threshold. Figure 1
17 below illustrates the model consolidation process .
18
19
20
21
22
23
24
25
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Idaho Power Company

1 Figure 1 . Idaho Power' s Reliability Flowchart
UG.Ttl.. ELCC
uhar.eutacr�oaeary I
•
RCAT LOLE LTCE
LOLE Portfolio
RNiaoibty a OpMrty tots (Iola PapactAIM LON-TWM C*-tyE�pinfion
n�T� MT- Reliability Hurdle
PRM L&R
Load
Manning Reurve Margin Gp—ty P—t-
2
3 Q. You indicated the RCAT and AURORA serve
4 different purposes in Idaho Power' s planning process, how
5 is the data exchanged between the two models translated
6 and aligned?
7 A. To better assess the dynamic diversity benefit
8 caused by a changing resource mix, and to synchronize the
9 models, beginning with the 2023 IRP a feedback process was
10 implemented between the AURORA LTCE model and the RCAT.
11 Under the feedback process, the annual capacity positions
12 for an AURORA LTCE main case portfolio buildout were
13 calculated using the RCAT. Once the annual capacity
14 positions were known, the PRM in the AURORA LTCE model was
15 modified in years that had significant resource changes so
16 that both models identified a similar annual capacity
17 position. The feedback loop continued until the main case
18 portfolio was reliable as measured by the annual capacity
ELLSWORTH, DI 7
Idaho Power Company

1 position to meet the LOLE threshold. The resulting AURORA-
2 produced optimized main case portfolios provide the least-
3 cost, least-risk future resource buildouts .
4 II . ANNUAL CAPACITY POSITION
5 Q. You indicated the Company updated the system
6 reliability assessment following the filing of the
7 Company' s request for approval of the Jackalope Project.
8 Why was the system reliability 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, 2026 and 2027 . 1
16 The most recent system reliability assessment has
17 identified a capacity deficit of 123 MW in 2027 .
18 Q. What drove the changes to the annual capacity
19 positions for 2027 in the most recent system reliability
20 assessment?
21 A. Any time the system reliability evaluation is
22 performed, Idaho Power includes the most up-to-date load
23 and resource inputs . The modeling input updates are
1 Case Nos. IPC-E-22-13, IPC-E-23-05, IPC-E-23-20, IPC-E-24-12, IPC-E-
24-16, IPC-E-24-45, and IPC-E-24-46.
ELLSWORTH, DI 8
Idaho Power Company

1 primarily related to 1) inclusion of a wildfire risk
2 factor, 2) a revised generation unit outage schedule, and
3 3) an updated load forecast. Note, the modeling input
4 updates associated with the inclusion of a wildfire risk
5 factor has not changed since the Company' s filing of the
6 request for approval of the Jackalope Project and the
7 update to the generation unit outage schedule has not
8 materially change the results . The load forecast however
9 has been updated since the request for approval of the
10 Jackalope Project was filed and therefore has been
11 incorporated in the system reliability evaluation performed
12 for this case .
13 Q. Why is the Company incorporating a wildfire
14 risk factor into the system reliability assessment?
15 A. Idaho Power has experienced numerous wildfire-
16 related outages on major tie lines used to import power.
17 The Company is fortunate to have some diversity in
18 transmission lines, and that diversity will continue to
19 expand in the future with additions to the transmission
20 system. However, given the prevalence of wildfires in the
21 recent past and the increase in proactive de-energization
22 of transmission lines when wildfire encroachment occurs,
23 the Company has incorporated an adjustment to the
24 availability of certain transmission facilities .
ELLSWORTH, DI 9
Idaho Power Company

1 Q. You indicated the most recent load forecast
2 was incorporated into the system reliability evaluation.
3 Were there any changes to the development of the load
4 forecast?
5 A. Yes . With the continued high load growth in
6 the Company' s service area, the load forecast is
7 consistently monitored and updated as new information
8 becomes available. 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.
13 Considering this new winter peak load record, and
14 because of the greater winter peak-day temperature
15 variability, the Company recognized the need to revise its
16 peak winter load forecasting methodology. The revised peak
17 winter load forecasting methodology better addresses peak
18 load variability due to winter temperatures, and has been
19 incorporated into the most recent load forecast. With this
20 update, the Company no longer needs to assess the range of
21 peak load forecast percentiles that were discussed in the
22 Company' s request for approval of the Jackalope project,
23 the 70th percentile peak load for March through October and
24 95th percentile peak load for November through February, and
25 instead now utilizes the 70th percentile peak load forecast
ELLSWORTH, DI 10
Idaho Power Company

1 for all months . This same revised methodology is utilized
2 for the load forecast included in the 2025 IRP.
3 III . MEETING THE CAPACITY DEFICIENCY
4 Q. How does the Company propose to address the
5 2027 capacity deficit presented in this case?
6 A. As described in the Direct Testimony of Mr.
7 Hackett, on February 7, 2025, Idaho Power executed
8 agreements associated with the Crimson Orchard Project,
9 which consists of (1) the Crimson Orchard PPA, supplying
10 the 100 MW output to the Company, and (2) the Crimson
11 Orchard ESA, the battery storage facility supplying 100 MW
12 of nameplate capacity to Idaho Power.
13 Q. How does the addition of the Crimson Orchard
14 Project impact the capacity deficit in 2027?
15 A. Including the most up-to-date load and
16 resource inputs, market purchase assumptions and the
17 methodological changes to the peak load forecasts, and
18 assuming all 2026 projects, the Jackalope Project, and the
19 Crimson Orchard Project reach commercial operation on
20 time, the addition of the Crimson Orchard PPA and the
21 Crimson Orchard ESA would reduce the 2027 capacity deficit
22 of 123 MW to a capacity deficit of 57 MW. The addition of
23 the Crimson Orchard Project, one of the final shortlist
24 projects procured as a result of the 2026 RFP, will
25 support continued safe, reliable operations in 2027 and
ELLSWORTH, DI 11
Idaho Power Company

1 beyond.
2 Q. You have indicated a capacity deficit will
3 still exist in 2027 even with the Crimson Orchard Project.
4 What steps is Idaho Power taking to reduce that deficit?
5 A. The Company continues negotiations with
6 developers and energy suppliers for additional 2027
7 resources necessary to meet the remaining capacity
8 deficiency. In addition, as discussed earlier in my
9 testimony, the Company continually monitors resource
10 needs, evaluating the changing load and resource
11 assumptions utilized in the reliability analysis and the
12 potential impact on the capacity deficit . Therefore,
13 because there are time constraints associated with the
14 Crimson Orchard PPA and the Crimson Orchard ESA, Idaho
15 Power is only filing a request for approval of the Crimson
16 Orchard Project agreements at this time .
17 Q. Why do you believe there is sufficient support
18 for the procurement of the Crimson Orchard Project?
19 A. The resource acquisitions presented in this
20 case were pursued and procured as a least-cost, least-risk
21 method of meeting the capacity deficits first identified
22 in the Company' s 2021 IRP, again in the 2023 IRP, and
23 subsequently with the results of the updated system
24 reliability evaluation. The fluidity of the capacity
25 deficit period, continued high load growth, and supply
ELLSWORTH, DI 12
Idaho Power Company

1 chain disruptions and delays further support these
2 resource procurements which are necessary to adequately
3 address 2027 capacity deficits .
4 Q. Are there any additional benefits beyond the
5 Crimson Orchard Project being a least-cost, least-risk
6 resource necessary for meeting Idaho Power' s capacity
7 needs?
8 A. Yes . As evidenced by the annual capacity
9 positions presented in the 2023 IRP, incremental capacity
10 deficits were expected beginning in 2026 and continuing
11 annually through the remainder of the planning period. As
12 detailed in the table below, the most recent system
13 reliability assessment shows a near-term incremental
14 capacity deficit even larger than previously expected:
15 Table 1 . Annual Capacity Position 2028-2030
Year 2023 IRP2 Most Recent3
Capacity Position Capacity Position
2028 (138) MW (181) MW
2029 (142) MW (378) MW
2030 (369) MW (493) MW
16 Q. How does the addition of the Crimson Orchard
17 Project impact the annual capacity positions between 2028
18 and 2030?
2 2023 IRP, Table 11.15.
3 Assumes a B2H online date and Four Corners capacity availability of November
2027. Assumes the Jackalope 600 MW Wind Project online June 2027 and Blacks
Creek solar online December 2027.
ELLSWORTH, DI 13
Idaho Power Company

1 A. In addition to helping meet the capacity
2 deficit of 123 MW in 2027, the Crimson Orchard Project will
3 reduce the incremental capacity needs beyond 2027 as shown
4 in Table 2 below.
5 Table 2 . Annual Capacity Position with Crimson Orchard
6 2027-2030
Year Most Recent Most Recent w/Crimson Orchard4
Capacity Position Capacity Position
2027 (123) MW (57) MW
2028 (181) MW (106) MW
2029 (378) MW (298) MW
2030 (493) MW (412) MW
7 A delay of resource procurements in 2027 will only
8 exaggerate the capacity deficiencies in 2028 and beyond.
9 Q. Did the Company evaluate any alternative
10 solutions for meeting the 2027 capacity deficiency to avoid
11 building a new resource?
12 A. Yes . As I discussed earlier in my testimony,
13 as part of the IRP process, the Company uses AURORA' s LTCE
14 modeling platform to develop portfolios, through the
15 selection of a variety of supply- and demand-side resource
16 options, that are least-cost for a variety of alternative
17 future scenarios while meeting reliability criteria. The
18 future supply- and demand-side resources available to meet
19 identified capacity deficiencies, whose costs are generally
4 Assumes a B2H online date and Four Corners capacity availability of November
2027. Assumes the Jackalope 600 MW Wind Project online June 2027 and Blacks
Creek solar online December 2027.
ELLSWORTH, DI 14
Idaho Power Company

1 based on the 2022 Annual Technology Baseline report
2 released by the National Renewable Energy Laboratory, 5
3 include new gas-fired resources, wind, solar, battery
4 storage, market purchases via available transmission
5 capacity, demand response and energy efficiency. The
6 Preferred Portfolio from the 2023 IRP, which included a
7 July 2026 online date for B2H, identified the conversion of
8 Valmy Units 1 and 2 to natural gas, the combined
9 procurement of 400 MW of wind, 375 MW of solar, and 5 MW of
10 battery storage as the most cost-effective resources for
11 meeting the identified capacity deficits in 2027 along with
12 20 MW of energy efficiency potential (identified in the
13 energy efficiency potential study) . The results are
14 indicative of the Company' s need to procure resources to
15 continue to provide safe, reliable electric service to its
16 customers in 2027 and beyond.
17 Q. What actions has Idaho Power taken to-date to
18 acquire least-cost, least-risk resources to ensure
19 continued safe, reliable electric service in 2027?
20 A. Under Idaho law, Idaho Power has an obligation
21 to provide adequate, efficient, just, and reasonable
22 service on a nondiscriminatory basis to all those that
23 request it within its certificated service area. 6 Further,
5 atb.nrel.gov/.
6 Idaho Code §§ 61-302, 61-315, 61-507.
ELLSWORTH, DI 15
Idaho Power Company

I as indicated by Order No. 35643, Idaho Power is responsible
2 for planning and managing its load and resource portfolio
3 and the Commission expects "the Company to closely monitor
4 its projected capacity needs going forward and to act
5 proactively to ensure a robust RFP process can be
6 completed. "7 Therefore, in order to meet its obligations to
7 reliably serve customers, on September 15, 2022, Idaho
8 Power filed an application with the Public Utility
9 Commission of Oregon ("OPUC") to open an independent
10 evaluator selection docket to oversee the Request for
11 Proposals ("RFP") process . 8 The Company' s compliance with
12 the OPUC competitive bidding guidelines, which the
13 Commission directed Idaho Power to follow as well9 and is
14 discussed in greater detail in the direct testimony of Mr.
15 Hackett, ultimately led to a competitive solicitation
16 through the issuance of the 2026 All-Source RFP, seeking a
17 combination of energy and capacity resources that provide a
18 minimum of approximately 350 MW of peak capacity and up to
19 1, 100 MW of variable energy resources for 2026 and 2027
20 ("2026 RFP") .
21 Given the significant timeframe related to the RFP
22 process under the competitive bidding guidelines, which
23 spans nearly 15 months and is solely related to the RFP
7 Page 13.
8 Docket UM 2255.
9 Order No. 32745. Case No. IPC-E-10-03.
ELLSWORTH, DI 16
Idaho Power Company

1 process and diligence and excludes the time required for
2 contract negotiation and execution, material procurement,
3 and construction, which can add another two to six years to
4 the process, the 2026 RFP was responsive to the resource
5 needs identified in the Company' s 2021 IRP filing, which
6 included near-term preferred portfolio additions of wind,
7 solar, storage, cost-effective energy efficiency measures,
8 the conversion of coal units to natural gas, incremental
9 demand response, and B2H coming online in 2026 . The RFP
10 needed to remain flexible to account for the fluidity of
11 the Company' s annual capacity positions as well as any
12 potential delays in the B2H online date and other projects .
13 Ultimately, the resources selected through the 2026 RFP
14 process were based on the recently-identified capacity
15 deficiency of 123 MW in 2027 . Note, this 123 MW deficit is
16 perfect capacity, so it requires Idaho Power to procure
17 more megawatts of nameplate capacity, depending on the ELCC
18 of each resource.
19 Through the Company' s robust competitive bidding
20 process, Idaho Power identified the most cost-effective
21 bids from the 2026 RFP evaluation as necessary to fill the
22 2027 capacity deficit. One of the cost-effective bids
23 resulted in the execution of the Crimson Orchard PPA,
24 supplying Idaho Power with 100 MW of solar generation and
25 the Crimson Orchard ESA, providing the Company with 100 MW
ELLSWORTH, DI 17
Idaho Power Company

1 of nameplate capacity.
2 IV. CONCLUSION
3 Q. Please summarize your testimony.
4 A. Idaho Power' s most recent system reliability
5 evaluation has identified a capacity deficiency of 123 MW
6 in 2027 . In response to this resource need, the Company has
7 identified the Crimson Orchard Project, providing a total
8 output of 100 MW of solar generation and/or battery storage
9 capacity, as the least-cost, least-risk resource for which
10 Idaho Power is requesting the Commission approve the
11 Crimson Orchard PPA and the Crimson Orchard ESA at this
12 time .
13 Q. Does this complete your testimony?
14 A. Yes, it does .
15
ELLSWORTH, DI 18
Idaho Power Company

1 DECLARATION OF JARED L. ELLSWORTH
2 I, Jared L. Ellsworth, declare under penalty of
3 perjury under the laws of the state of Idaho:
4 1 . My name is Jared L. Ellsworth. I am employed
5 by Idaho Power Company as the Transmission, Distribution &
6 Resource Planning Director for the Planning, Engineering &
7 Construction Department.
8 2 . On behalf of Idaho Power, I present this
9 pre-filed direct testimony in this matter.
10 3 . To the best of my knowledge, my pre-filed
11 direct testimony is true and accurate.
12 I hereby declare that the above statement is true to
13 the best of my knowledge and belief, and that I understand
14 it is made for use as evidence before the Idaho Public
15 Utilities Commission and is subject to penalty for perjury.
16 SIGNED this 13th day of March 2025, at Boise, Idaho.
17
18 Signed:
19 Jared L. Ellsworth
20
ELLSWORTH, DI 19
Idaho Power Company