20250708Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: YAO YIN, COMMISSION STAFF
ERIKA K. MELANSON,DEPUTY ATTORNEY GENERAL
DATE: DULY 8, 2025
RE: IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION
FOR APPROVAL OF A POWER PURCHASE AGREEMENT WITH
BLACKS CREEK ENERGY CENTER, LLC; CASE NO. IPC-E-24-42.
BACKGROUND
On April 24, 2025, the Idaho Public Utilities Commission ("Commission") issued Order
No. 36572, which required Idaho Power Company ("Company") to work with Staff on the
structure for calculating Brisbie LLC's("Brisbie")Renewable Capacity Credit("RCC")under the
Brisbie Special Contract and directed the Company to submit a compliance filing with the
proposed RCC and associated updates to Schedule 33 within 60 days of the order. Order No.
36572 at 3.
On May 19, 2025, and May 28, 2025, the Company and Staff met to discuss the
recommendations proposed in Staff s Comments. As a result of the meetings,the Company agreed
to all the recommendations in Staff s Comments, except for Recommendation 5 and
Recommendation 6b. The Company and Staff agreed to improved methods for these two items as
a result of the two meetings.
STAFF REVIEW
Staff reviewed the Company's compliance filing and believes that the compliance filing
has reflected the Staff s recommendations in its comments filed on February 27, 2025, except for
Recommendation 5 and Recommendation 6b, which are based on the improved methods agreed
by the Company and the Staff after the two meetings in May. Therefore, Staff believes that the
proposed RCC payment structure is reasonable and that the Company has complied with Order
DECISION MEMORANDUM - 1 - JULY 8, 2025

No. 36572. Therefore, Staff recommends that the Commission approve the compliance filing and
direct the Company to file an updated Schedule 33.'
Recommendation 5
Staff s original Recommendation 5 is that high-risk hours be determined based on the 2028
Loss of Load Probability profiles with no expansion of risk-hours. After the two meetings in May,
the Company and Staff agreed to include additional hours in the hour-risk timeframes, because
high-risk hours do not capture 100%of risk hours, and also because including additional hours can
reduce the solar generation measurement variability. The compliance filing has reflected this
improvement.
Recommendation 6b
Staff s original Recommendation 6b is that in establishing the relationship between
Performance Ratio and Effective Load Carrying Capability ("ELCC"), the Company a method of
the best-fit linear equation with constraints of 100% of the original ELCC at Performance Ratio of
1.0. After the two meetings in May, the Company and Staff agreed to an interpolation method of
connecting the two closest data points, because these datapoints are deterministically calculated
and each data point represents a percentage of the original ELCC at a specific Performance Ratio.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's compliance filing filed on
June 23, 2025, and direct the Company to file an updated Schedule 33.
COMMISSION DECISION
Does the Commission wish to approve the Company's compliance filing filed on June 23,
2025, and direct the Company to file an updated Schedule 33?
�4A
Yao Yin
Utilities Analyst II
I:\Uti1ity\UDMEM0S\IPC-E-24-42 Decision Memo.docx
' Schedule 33 cannot be filed until the Company approves the proposed RCC payment structure,because Schedule
33 references Commission orders that approve each project's RCC payment structure. See draft Schedule 33
contained in Attachment 2 of the compliance filing.
DECISION MEMORANDUM - 2 - JULY 8, 2025