20250430Direct Ellsworth.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY' S APPLICATION FOR ) CASE NO. IPC-E-24-44
APPROVAL OF SPECIAL CONTRACT AND )
TARIFF SCHEDULE 28 TO PROVIDE )
ELECTRIC SERVICE TO MICRON IDAHO )
SEMICONDUCTOR MANUFACTURING )
(TRITON) LLC . )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
JARED L. ELLSWORTH
Ellsworth, DI 1
Idaho Power Company

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

1 compliance standards . I transitioned into the Transmission
2 Policy and Development group with a similar role, and in
3 2013, I spent a year cross-training with the Company' s Load
4 Serving Operations group. In 2014, I was promoted to
5 Engineering Leader of the Transmission Policy and
6 Development department and assumed leadership of the System
7 Planning group in 2018 . In early 2020, I was promoted into
8 my current role as the Transmission, Distribution, and
9 Resource Planning Director. I am currently responsible for
10 the planning of the Company' s wires and resources to
11 continue to provide customers with cost-effective and
12 reliable electrical service.
13 Q. What is the purpose of your testimony?
14 A. My testimony supports Idaho Power' s
15 Application in Case No. IPC-E-24-44 by describing the
16 Company' s use of long-term capacity expansion modeling to
17 evaluate the effect of Micron FAB' s expected load on the
18 Company' s resource needs . Specifically, I explain how Idaho
19 Power used the AURORA Long-Term Capacity Expansion ("LTCE")
20 model to compare two resource portfolios : one that includes
21 the load associated with Micron FAB ("With Micron") , and
22 one that does not ("Without Micron") . I describe the
23 modeling framework, key assumptions, and differences in
24 LTCE resource selections between the two scenarios . I also
25 briefly describe how Idaho Power identified the incremental
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Idaho Power Company

1 distribution, transmission and substation investments
2 needed to interconnect the Micron FAB, which were the basis
3 for the Construction and Procurement Agreements .
4 My testimony does not address the development of
5 Micron' s pricing or the detailed results of the no-harm
6 analysis . Those topics are covered in the testimony of
7 Company witness Grant T. Anderson.
8 II . CAPACITY EXPANSION MODELING FRAMEWORK
9 A. Overview of AURORA LTCE Model
10 Q. What modeling platform did Idaho Power use to
11 evaluate long-term system planning scenarios?
12 A. Idaho Power used the AURORA modeling platform
13 developed by Energy Exemplar. AURORA is a commercially
14 available tool widely used by utilities for resource
15 planning and long-term system modeling. Specifically, Idaho
16 Power relies on the LICE functionality to evaluate system
17 buildouts over a multi-year planning horizon.
18 Q. How does the LTCE model support Idaho Power' s
19 planning process?
20 A. The LTCE model is used to identify the least-
21 cost and least-risk combination of supply-side and demand-
22 side resources that can meet forecasted customer demand
23 while maintaining system reliability. It simulates Idaho
24 Power' s system as a separate zone within the broader
25 Western Electricity Coordinating Council ("WECC") and
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Idaho Power Company

1 selects resources based on cost-effectiveness, reliability,
2 and operational feasibility. The model determines the type,
3 size, and timing of new resource additions and exits .
4 Q. How does the model determine which resources
5 to select?
6 A. The LTCE model uses a "selectable resource"
7 framework. This means the model can choose from a set of
8 eligible technologies—such as solar, wind, battery storage,
9 gas-fired generation, and demand response—based on their
10 cost and contribution to system needs . Resources are added
11 to help minimize total system costs and meet planning
12 reserve and reliability requirements . If a resource does
13 not improve portfolio performance, it will not be selected.
14 Q. How does Idaho Power evaluate resources in the
15 LTCE model?
16 A. Idaho Power evaluates resources based on their
17 costs to customers . For Company-owned supply-side
18 resources, this is done from a Total Resource Cost ("TRC")
19 perspective . For other resources, such as energy
20 efficiency, Power Purchase Agreements ("PPAs") , and Public
21 Utility Regulatory Policies Act of 1978 ("PURPA")
22 contracts, the cost reflects the specific investment or
23 contractual structure involved. To ensure a fair
24 comparison, the Company uses (1) a levelized cost approach
25 that incorporates : capital investments, fixed operations
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Idaho Power Company

1 and maintenance costs, and applicable taxes and tax
2 credits; plus (2) an annual cost calculation that
3 incorporates : variable operations and maintenance costs,
4 fuel costs, and incentives .
5 Q. How does Idaho Power account for differences
6 in resource types and economic life?
7 A. Each resource is modeled using assumptions
8 specific to its design life and technology type.
9 Depreciation of capital costs is calculated over the
10 economic life of the resource, allowing for a normalized
11 comparison across options . This enables a "like-for-like"
12 evaluation of resource alternatives to ensure that
13 selection decisions are in the best interest of customers .
14 Q. How does the LTCE model ensure system
15 reliability is maintained?
16 A. The LICE model ensures reliability by
17 requiring portfolios to meet a minimum Planning Reserve
18 Margin ("PRM") . To determine the minimum PRM, Idaho Power
19 utilizes its internal reliability standard which is the
20 probabilistic Loss of Load Expectation ("LOLE") metric with
21 a threshold of 0 . 1 event-days per year. The Company
22 translates the LOLE-based reliability results to PRM
23 targets for input into the LTCE model .
24 Q. How are PRM values and resource contributions
25 calculated?
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Idaho Power Company

1 A. Idaho Power utilizes its internally developed
2 Reliability & Capacity Assessment Tool ("RCAT") to
3 calculate Effective Load Carrying Capability ("ELCC")
4 values for Variable Energy Resources ("VERs") and Energy-
5 Limited Resources ("ELRs") . ELCC saturation curves were
6 developed for VERs and ELRs to capture the resource
7 capacity contribution as a function of penetration levels
8 in the LICE model . The RCAT also determines annual capacity
9 positions which can be used to calibrate the minimum PRM in
10 the LTCE model .
11 Q. Does Idaho Power coordinate modeling between
12 AURORA and RCAT?
13 A. Yes . Idaho Power has implemented a feedback
14 process between RCAT and AURORA to calculate ELCC
15 interactions and diversity benefits of the portfolios . The
16 initial process starts with RCAT providing PRM values and
17 ELCC saturation curves as an input to the LTCE model . Once
18 the LTCE model produces a portfolio, the corresponding
19 resource buildout is tested in RCAT to ensure that it meets
20 the Company' s reliability threshold. The RCAT results can
21 then be utilized to calibrate updated PRM values and ELCC
22 saturation curves for the LTCE model . The process continues
23 until the resulting LTCE model portfolio resource buildout
24 meets the reliability target for each year of the planning
25 horizon.
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Idaho Power Company

1 B. With and Without Scenario Development
2 Q. How did Idaho Power develop the "With Micron"
3 and "Without Micron" scenarios relied upon for the no-harm
4 analysis?
5 A. The Company' s 2023 IRP Preferred Portfolio was
6 relied on for the "With Micron" scenario. At the time the
7 2023 IRP was developed, Micron had executed a Construction
8 Agreement and Procurement Agreement to cover the costs
9 associated with facilities and equipment necessary to
10 interconnect the Micron FAB and therefore its load forecast
11 was included in the analysis relied on to develop the 2023
12 IRP preferred portfolio .
13 To evaluate the "Without Micron" scenario, a
14 counterfactual analysis was run that excluded Micron FAB' s
15 load and allowed the LTCE model to re-optimize the resource
16 portfolio accordingly. Other assumptions such as including
17 system load absent Micron, anticipated market and fuel
18 conditions, and resource cost assumptions remained
19 consistent with those relied upon in the 2023 IRP.
20 Comparing the results of the two runs allows the
21 Company to isolate the impact of Micron FAB on long-term
22 resource needs and costs .
23 C. Results and Application in No-Harm Analysis
24 Q. What outputs did the LTCE model provide in the
25 two scenarios Idaho Power analyzed?
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Idaho Power Company

1 A. The LTCE model produced optimized resource
2 portfolios for each scenario — one that included Micron
3 FAB' s forecasted load and one that did not. For each case,
4 the model identified the type, and quantity of new resource
5 additions required per year.
6 Q. What differences were observed in the
7 portfolios with and without Micron FAB?
8 A. The "With Micron" portfolio results in
9 additional natural gas, battery storage, and demand
10 response being selected throughout the planning timeframe
11 of 2024 to 2033 .
12 Q. Can you provide more detail on the resource
13 selections by year in the "With Micron" scenario?
14 A. Yes . Table 1 illustrates the modeled resource
15 selections for the "With Micron" portfolio by resource
16 type . The column labeled "DR" represents the amount of
17 Demand Response selected and the column labeled "EE"
18 represents energy efficiency.
19
20
21
22
23
24
25
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Idaho Power Company

1 Table 1 . LTCE Resource Selection "With Micron"
With Micron Scenario-Total Megawatts(MW)
Geothermal
Nuclear
Year Coal Gas/H2 Wind Solar Storage DR EE Biomass
2024 (357) 357 - 100 96 - 17 -
2025 - - - 200 227 - 18 -
2026 (134) 261 - 400 155 40 19 -
2027 - - 400 375 5 - 20 -
2028 - - 100 150 5 - 21 -
2029 - - 400 200 5 - 22 -
2030 (350) 350 400 - 5 - 21 -
2031 - - 400 500 55 - 21 -
2032 - - 100 - 5 20 20 -
2033 - - - - 55 40 20 -
2 Total (841) 968 1,800 1,925 613 100 199 -
3 Q. How does this compare to the resource
4 selections by year in the "Without Micron" scenario?
5 A. Table 4 similarly illustrates the modeled
6 resource selections for the "Without Micron" portfolio .
7 Table 2 . LTCE Resource Selection "Without Micron"
Without Micron Scenario-Total Megawatts(MW)
Geothermal
Nuclear
Year Coal Gas/H2 Wind Solar Storage DR EE Biomass
2024 (357) 357 - 100 96 - 17 -
2025 - - - 200 227 - 18 -
2026 (134) - - 300 - - 19 -
2027 - - 400 375 - - 20 -
2028 - - 200 150 - - 21 -
2029 - - 400 - 5 - 22 -
2030 (350) 350 300 300 - - 21 -
2031 - - 400 500 - - 21 -
2032 - - 100 - 5 - 20 -
2033 - - - - 5 - 20 -
8 Total (841) 707 1,800 1,925 338 - 199 -
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Idaho Power Company

1 Last, Table 3 represents the difference between the
2 "With Micron" and "Without Micron" resource selection by
3 resource type and year.
4 Table 3 . LTCE Resource Selection "With vs . Without Micron"
With Micron vs.Without Micron
Geothermal
Nuclear
Year Coal Gas/H2 Wind Solar Storage DR EE Biomass
2024 - - - - - - - -
2025 - - - - - - - -
2026 - 261 - 100 155 40 - -
2027 - - - - 5 - - -
2028 - - (100) - 5 - - -
2029 - - - 200 - - - -
2030 - - 100 (300) 5 - - -
2031 - - - - 55 - - -
2032 - - - - - 20 - -
2033 - - - - 50 40 - -
5 Total - 261 - - 275 100 - -
6 In summary, these tables demonstrate how the
7 system' s projected resources change and how Micron FAB' s
8 load affects the timing and scale of resource needs .
9 Q. What is the significance of the resource
10 selections in the "Without Micron" scenario?
11 A. The resource selections in the "Without
12 Micron" scenario confirms that new investments will be
13 needed, regardless of whether the Micron FAB facility is
14 served. In the absence of Micron, the full cost of those
15 investments would be borne by all other customers . By
16 contrast, when Micron FAB is included in the Preferred
17 Portfolio, the cost of needed capacity is partially offset
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Idaho Power Company

1 by an allocation of cost to the Micron FAB facility. As
2 described in Mr. Anderson' s testimony, the Company' s no-
3 harm analysis assumes Micron FAB is allocated its load-
4 ratio share of new generation and transmission investment -
5 reducing the burden on existing customers .
6 III . CUSTOMER DRIVEN UPGRADES
7 Q. Please explain how the Company evaluates
8 interconnection needs, including transmission and
9 substation facilities, for new large loads .
10 A. The Company' s Planning department conducts the
11 necessary transmission and interconnection studies . For
12 transmission requirements, the request is modeled in the
13 Company' s power flow software to assess potential thermal
14 and voltage violations . The results of this power flow
15 analysis - which in the case of Micron FAB demonstrated the
16 required transmission upgrades required to serve the
17 requested load - are communicated to the Company' s
18 Transmission & Distribution ("T&D") Projects team. The T&D
19 Projects team leverages the results from the power flow
20 study to scope out the required transmission upgrades,
21 including the estimated cost and timeline to construct
22 those upgrades .
23 Additionally, the T&D Projects team also works
24 closely with the assigned Planning Engineer to determine
25 what, if any, distribution substation upgrades are needed.
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Idaho Power Company

1 Those identified substation and distribution upgrades,
2 including the estimated cost and timeline to construct
3 those upgrades are ultimately communicated to the customer.
4 Q. Generally, what upgrades were identified for
5 the Micron FAB?
6 A. Through its studies, Idaho Power determined
7 there were several upgrades necessary to interconnect the
8 Micron FAB, including a new substation, distribution
9 equipment, and new transmission line segments to serve the
10 substation. Additionally, the project requires the
11 temporary or permanent relocation of certain existing
12 transmission and distribution lines .
13 Q. How are the costs associated with those
14 transmission and distribution upgrades only needed for the
15 Micron FAB recovered?
16 A. Idaho Power requires large load customers -
17 like Micron - to cover the full cost of all upgrades
18 required up-front through a Contribution in Aid of
19 Construction ("CIAC") based on an initial estimate of the
20 total project costs . The ultimate amount of the CIAC will
21 be determined based on reconciled costs once the project is
22 complete, meaning Micron is responsible for all actual
23 costs associated with the work. The terms associated with
24 Micron' s obligations for funding necessary upgrades are
25 contained in the Procurement and Construction Agreements,
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Idaho Power Company

1 which are filed as Attachments 3 and 4 to the Application,
2 respectively.
3 Q. Has the Company incurred or does it expect to
4 incur any transmission or substation costs not accounted
5 for in the Construction or Procurement Agreements?
6 A. No. All incremental transmission and
7 substation costs required to serve the customer will be
8 reconciled at project completion and recovered directly
9 from the customer.
10 IV. CONCLUSION
11 Q. Please summarize your testimony.
12 A. My testimony describes how Idaho Power used
13 the AURORA Long-Term Capacity Expansion model to evaluate
14 resource portfolio outcomes under two scenarios : one that
15 included the forecasted load from Micron FAB and one that
16 excluded it . The purpose of this analysis was to determine
17 how Micron FAB' s inclusion affects Idaho Power' s long-term
18 system planning and infrastructure requirements .
19 Q. What did the modeling reveal about the impact
20 of Micron FAB on Idaho Power' s resource needs?
21 A. The modeling showed that while Micron FAB' s
22 load does contribute to incremental resource needs, there
23 are still resources added to the system, absent Micron' s
24 load.
25 Q. Does this conclude your testimony?
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Idaho Power Company

1 A. Yes, it does .
2
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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 30th day of April 2025, at Boise, Idaho.
17
18 Signed:
19 Jared L. Ellsworth
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Idaho Power Company