HomeMy WebLinkAbout20250730Rebuttal Testimony.pdf "4%6h-0IQAHO POWER.
RECEIVED
July 30, 2025
IDAHO PUBLIC
MEGAN GOICOECHEA ALLEN UTILITIES COMMISSION
Corporate Counsel
mgoicoecheaallenC&_idahopower.com
July 30, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-24-44
Idaho Power Company's Application for Approval of a Special Contract and
Tariff Schedule 28 to Provide Electric Service to Micron Idaho Semiconductor
Manufacturing (Triton) LLC
Dear Commission Secretary:
Attached for electronic filing, please find Idaho Power Company's Rebuttal
Testimonies and exhibit of Grant T. Anderson and Jared L. Ellsworth.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
Awr
TII
Megan Goicoechea Allen
MGA:sg
Attachments
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707
CERTIFICATE OF SERVICE
HEREBY CERTIFY that on the 30t" day of July 2025, 1 served a true and correct
copy of Idaho Power Company's Rebuttal Testimonies of Grant T. Anderson and Jared
L. Ellsworth 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
PO Box 83720 Chris.Burdin(a)-puc.idaho.gov
Boise, ID 83720-0074
Industrial Customers of Idaho Power Hand Delivered
c/o Peter J. Richardson U.S. Mail
Richardson Adams, PLLC Overnight Mail
515 N. 27' Street FAX
Boise, Idaho 83702 FTP Site
X Email
peter richardsonadams.com
Dr. Don Reading Hand Delivered
280 S. Silverwood Way U.S. Mail
Eagle, Idaho 83716 Overnight Mail
FAX
FTP Site
X Email
dreading(aD_mindspring.com
Idaho Irrigation Pumpers Association, Hand Delivered
Inc. U.S. Mail
Eric L. Olsen Overnight Mail
Echo Hawk & Olsen, PLLC FAX
505 Pershing Ave., Ste. 100 FTP Site
P.O. Box 6119 X Email
Pocatello, Idaho 83205 elo(a)-echohawk.com
Lance Kaufman, Ph.D. Hand Delivered
2623 NW Bluebell Place U.S. Mail
Corvallis, OR 97330 Overnight Mail
FAX
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X Email Iance(a)aegisinsight.com
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Austin W. Jensen FAX
Kristine A.K. Roach FTP Site
Holland & Hart LLP X Email
555 17' Street, Suite 3200 darueschhoff(a�hol land hart.com
Denver, CO 80202 tnelson _hol land hart.com
awiensen(a)hol land hart.com
karoach hollandhart.com
aclee(c)hollandhart.com
Clean Energy Opportunities for Idaho Hand Delivered
Kelsey Jae U.S. Mail
Law for Conscious Leadership Overnight Mail
920 N. Clover Dr. FAX
Boise, ID 83703 FTP Site
X Email
kelsey(a)kelseyjae.com
Courtney White Hand Delivered
Mike Heckler U.S. Mail
3778 Plantation River Drive, Suite 102 Overnight Mail
Boise, ID 83703 FAX
FTP Site
X Email
courtney(a)cleanenergyopportunities.com
mike a(�.cleanenergyopportunities.com
Stacy Gust
Regulatory Administrative Assistant
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
REBUTTAL TESTIMONY
OF
GRANT T . ANDERSON
1 Q. Please state your name .
2 A. My name is Grant T. Anderson.
3 Q. Are you the same Grant T. Anderson who
4 submitted direct testimony in this proceeding on behalf of
5 Idaho Power Company ("Idaho Power" or "Company") ?
6 A. Yes .
7 Q. Have you had the opportunity to review the
8 pre-filed testimony of Idaho Public Utilities Commission
9 Staff ("Staff") witness Mr. Michael Eldred, Idaho
10 Irrigation Pumpers Association ("IIPA") witness Dr. Lance
11 Kaufman, and Clean Energy Opportunities for Idaho ("CEO")
12 witness Ms . Courtney White?
13 A. Yes, I have .
14 Q. What is the scope of your rebuttal testimony
15 in this proceeding?
16 A. My rebuttal testimony addresses several
17 aspects of the direct testimony submitted by intervenors in
18 this case . Specifically, I respond to their positions and
19 recommendations related to the proposed pricing structure
20 for the Micron FAB special contract, the marginal cost-
21 based Energy Charge, the design of demand charges, and the
22 Company' s no-harm analysis .
23 Q. Does the fact that you do not address every
24 issue raised in the direct testimony of other parties mean
ANDERSON, DI-REB 2
Idaho Power Company
1 that you agree with other parties' testimony on those
2 issues?
3 A. No . It merely reflects that I chose not to
4 address all those issues . It should not be read as an
5 endorsement of, or agreement with, any unaddressed issues .
6 Q. Please summarize your recommendations .
7 A. I recommend that the Commission:
8 (i) Approve the Special Contract and Tariff Schedule 28
9 as a reasonable foundation for serving the Micron
10 FAB, pursuant to compliance filing consistent with
11 my recommendations to ii and iii;
12 (ii) Approve the proposed marginal cost-based Energy
13 Charge, direct the Company to submit a compliance
14 filing aligning the initial Energy Charge with the
15 pricing approved in IPC-E-25-17, and support annual
16 updates through the same docket used for other
17 marginal cost-based pricing;
18 (iii) Approve the methodology used to derive the proposed
19 demand charges and direct the Company to submit a
20 compliance filing to reflect demand charge updates
21 consistent with changes approved in IPC-E-24-07;
22 (iv) Acknowledge the no-harm analysis as a directional
23 tool based on a defined set of assumptions, not a
24 pricing mechanism, and recognize that appropriate
ANDERSON, DI-REB 3
Idaho Power Company
1 cost allocation will be addressed in future general
2 rate cases using measurable data .
3 I . PRICING STRUCTURE AND COST ALLOCATION
4 Q. Please summarize your understanding of the
5 intervenor positions regarding Idaho Power' s proposed
6 pricing structure .
7 A. Staff, through Mr. Eldred, generally supports
8 Idaho Power' s proposed pricing structure and recommends
9 clarifying language around future updates and cost
10 allocation treatment in general rate cases . Dr. Kaufman,
11 testifying on behalf of IIPA, asserts that the proposed
12 pricing under-recovers costs and presents a shortfall based
13 on a flawed comparison between two resource portfolios in
14 the Company' s Integrated Resource Plan ("IRP") ; he appears
15 to incorrectly assume that Micron' s prices will remain
16 static and calculates cost differences using this
17 assumption. Ms . White, representing CEO, recommends a time-
18 varying energy pricing structure with the goal of aligning
19 with the hourly variation in system costs; she further
20 proposes recovering capacity costs through volumetric
21 charges aligned with high-risk hours instead of demand
22 charges .
23 Q. Do you agree with Mr. Eldred' s recommendation
24 to evaluate cost allocation and pricing in the next general
25 rate case?
ANDERSON, DI-REB 4
Idaho Power Company
1 A. Yes . The embedded demand methodology presented
2 in this case is a reasonable basis for initially deriving
3 pricing for the Micron FAB special contract. Mr. Eldred
4 notes in his direct testimony that the proposed pricing is
5 adequate to allow the Company to recover the costs that
6 Micron' s load will cause to the system if billing
7 determinants, costs, and benefits are matched to the proper
8 test year. However, the appropriate time to conduct that
9 matching is in a future general rate case after an
10 application is filed to include plant additions and other
11 costs attributable to Micron' s incremental load. These
12 costs are not reflected in the Company' s current base rates
13 nor in its pending general rate case, IPC-E-25-16 . This
14 approach ensures that Micron is allocated costs in
15 proportion to its impact on the system and that other
16 customers are protected from potential cost shifts .
17 Q. Does Mr. Eldred propose a specific cost
18 allocation methodology to be applied in a future general
19 rate case?
20 A. No. Mr. Eldred does not propose a specific
21 methodology. Instead, he recommends that Idaho Power
22 identify and apply an appropriate method in the applicable
23 general rate case, at the time the Company seeks recovery
24 of plant additions and other costs related to Micron' s
25 incremental load. This ensures that cost causation is
ANDERSON, DI-REB 5
Idaho Power Company
1 addressed using actual data and system conditions,
2 protecting other customers from potential cost shifts .
3 Q. What conclusions did Mr. Eldred reach
4 regarding the Company' s pricing approach for capacity-
5 related costs?
6 A. Mr. Eldred concluded that the input
7 assumptions and evaluation of risk variables used by Idaho
8 Power were reasonable and concludes that cost allocation
9 must be addressed in a future general rate case when
10 assigning costs to Micron.
11 Q. How do you respond to Mr. Eldred' s conclusion?
12 A. I agree with Mr. Eldred' s conclusion and
13 believe the no-harm analysis should be treated as one data
14 point among many in the Commission' s overall evaluation. I
15 discuss the no-harm analysis specifically in more detail
16 later in my rebuttal testimony.
17 Q. What does Dr. Kaufman state regarding the cost
18 to serve the special contract?
19 A. Dr. Kaufman claims that the cost to serve
20 Micron is approximately $186 per megawatt-hour ("MWh") ,
21 presenting this figure as if it is derived directly from
22 Idaho Power' s IRP. His calculation attempts to reflect the
23 difference in levelized cost between two planning
24 portfolios . He suggests that the special contract customer
25 should always pay a cost that is greater or equal to this .
ANDERSON, DI-REB 6
Idaho Power Company
1 Q. How do you respond to Dr. Kaufman' s use of the
2 IRP to assess Micron' s cost responsibility?
3 A. Presenting this figure as a definitive cost to
4 serve Micron is misleading and misrepresents the function
5 and purpose of the IRP. As described by Company witness Mr.
6 Ellsworth, Dr. Kaufman' s calculations are flawed in
7 multiple respects . Mr. Ellsworth explains that Dr.
8 Kaufman' s analysis results in double counting of resource
9 costs and fails to acknowledge that the IRP preferred
10 portfolio already includes Micron' s anticipated load.
11 Even if Dr. Kaufman had selected the correct
12 portfolios and avoided the double-counting error, his
13 recommendation to price Micron based on a 20-year IRP
14 portfolio cost differential is fundamentally flawed. It
15 disregards actual test year costs and relies on long-term
16 planning assumptions that do not determine future rates or
17 reflect used-and-useful principles . This methodology is
18 inconsistent with standard ratemaking practices and should
19 not be used to establish pricing for Micron.
20 Given these flaws, Dr. Kaufman' s analysis and
21 resulting conclusions are not reliable. The methodology
22 used deviates from accepted ratemaking practices,
23 incorporates inaccurate assumptions, and fails to reflect
24 how pricing decisions are made through general rate cases .
ANDERSON, DI-REB 7
Idaho Power Company
1 For these reasons, I recommend that the Commission
2 disregard Dr. Kaufman' s analysis in this proceeding.
3 Q. How does Dr. Kaufman use his calculated $186
4 per MWh to compare against the pricing initially filed by
5 Idaho Power in this docket?
6 A. Dr. Kaufman applies the initial proposed
7 pricing to 500 megawatts ("MW") of load at a 90 percent
8 load factor. He then compares the implied average revenue
9 from the special contract to his $186 per MWh figure, which
10 he presents as a floor or minimum cost to serve Micron. He
11 then concludes that the proposed pricing is inadequate and
12 suggests that the revenue shortfall would be spread to
13 other customers .
14 Q. Do you agree with Dr. Kaufman ' s calculations
15 and comparison?
16 A. No. This approach fails to acknowledge that
17 the $186 per MWh is not an established cost to serve, and a
18 miscalculated IRP portfolio comparison. There is no
19 recognition for the underlying basis, or billing
20 determinants and test year used, to derive the initial
21 pricing. It also ignores the dynamic nature of pricing
22 updates through general rate cases and compliance filings,
23 where actual cost allocation will occur as Micron' s load
24 increases .
ANDERSON, DI-REB 8
Idaho Power Company
1 Q. Please expand on the flaws you identify with
2 Dr. Kaufman' s approach.
3 A. The initial pricing was developed based on
4 Micron' s forecasted load during the initial ramp - not the
5 facility' s forecasted 500 MW at the end of the ramping
6 period. At the time the Company files its next general rate
7 case, it would include Micron in the test year billing
8 determinants to provide an accurate representation of
9 Micron' s allocation of total system investment at that
10 time . As Idaho Power files future general rate cases and
11 includes plant additions needed in part to serve the Micron
12 FAB, Micron" s cost allocation will increase accordingly.
13 Q. Do you agree with Dr. Kaufman' s argument that
14 the difference between the special contract average revenue
15 per MWh and an IRP-derived incremental cost figure results
16 in a revenue shortfall?
17 A. No. Setting aside the flawed assumptions and
18 double - counting errors previously discussed, I do not
19 agree with Dr. Kaufman' s conclusion. His comparison is
20 based on a 20-year IRP portfolio that includes forecasted
21 long-term resource costs—many of which Idaho Power does not
22 have certainty will occur at the time or cost forecasted.
23 He then compares this 20-year planning portfolio average
24 cost to revenues from the initial Micron FAB pricing - but
25 assuming 500 MW - which was designed for Micron' s initial
ANDERSON, DI-REB 9
Idaho Power Company
1 ramp, not its full buildout . This mismatch in both the cost
2 basis and load level leads to inaccurate results .
3 Even if one assumes the IRP had perfect foresight,
4 it would still be inappropriate to base prices on a 20-year
5 average cost . Basing prices on modeled portfolio costs
6 intended to inform long-term planning decisions would
7 bypass the regulatory process that ensures fair and
8 equitable cost allocation. Additionally, a 20-year average
9 ignores the timing of both resource investment and load
10 development, which are critical to aligning costs with cost
11 causation. For these reasons, Dr. Kaufman' s comparison
12 should not be used to evaluate the proposed pricing.
13 Q. Do you agree with Dr. Kaufman ' s argument that
14 the proposed pricing would result in a revenue shortfall
15 borne by other customers?
16 A. No. The premise of his argument is based on
17 the initial pricing for the special contract. In addition
18 to the problems with his approach that I already addressed,
19 Kaufman assumes that the pricing for the special contract
20 would not change in any future rate case over the next 20
21 years and all future increases would be fully borne by
22 other customers . This is not what has been proposed in the
23 special contract and the application in this docket, and I
24 believe it is unreasonable to suggest this outcome would
25 occur.
ANDERSON, DI-REB 10
Idaho Power Company
1 II . MARGINAL COST-BASED ENERGY CHARGE
2 Q. Please summarize your understanding of the
3 intervenor positions regarding Idaho Power' s proposed
4 marginal cost-based Energy Charge.
5 A. Mr. Eldred supports the Company' s proposed
6 methodology for establishing the Energy Charge and
7 recommends certain clarifications, including updating the
8 methodology through annual compliance filings and ensuring
9 Commission oversight . He suggests modifying the special
10 contract language in Section 7 . 2 to allow for the Energy
11 Charge methodology to change in the future, and to include
12 a requirement for Commission approval and justification if
13 the pricing basis moves from marginal to embedded or
14 another cost basis .
15 Dr. Kaufman, in contrast, is critical of the
16 proposed marginal cost-based Energy Charge methodology. He
17 argues it only reflects short-run marginal energy costs and
18 recommends incorporating a true-up mechanism or using long-
19 run marginal costs, such as those associated with power
20 purchase agreements or utility-owned resources .
21 Ms . White supports a time-varying rate structure and
22 proposes shifting capacity cost recovery into energy
23 charges during defined high-risk periods to send stronger
24 price signals and better reflect system conditions . These
25 perspectives raise distinct questions about both the
ANDERSON, DI-REB 11
Idaho Power Company
1 pricing method itself and how future pricing updates or
2 changes should be managed. I will address these in this
3 section of my testimony.
4 Q. How does the Company respond to Mr. Eldred' s
5 recommendation related to the Energy Charge?
6 A. The Company does not oppose Mr. Eldred' s
7 recommendation. However, the Company' s Application and my
8 direct testimony describe the marginal energy charge
9 methodology most recently approved by the Commission in
10 IPC-E-25-17, which is consistent with the methodology
11 initially presented for the Energy Charge in this case. It
12 is my opinion that the special contract already allows for
13 future changes to the methodology to occur as approved by
14 the Commission - the method itself is not explicitly
15 defined. Additionally, I believe it is inherent in the
16 structure of a Commission-approved special contract that
17 any changes to pricing are subject to Commission approval
18 prior to becoming effective. While I do not oppose Mr.
19 Eldred' s suggestion to be more explicit in the contract
20 language, I do not believe such a clarification is
21 necessary. Lastly, I agree - and it was the Company' s
22 intent - that the Energy Charge should be updated through a
23 compliance filing to align with the marginal energy prices
24 approved by the Commission in IPC-E-25-17 . Going forward,
25 the Energy Charge applicable to the Micron FAB will be
ANDERSON, DI-REB 12
Idaho Power Company
1 updated annually as part of the same filing in which Idaho
2 Power updates marginal cost-based energy pricing for all
3 other customers who rely on that methodology.
4 Q. How does the Company respond to Dr. Kaufman' s
5 critique of the marginal cost-based Energy Charge?
6 A. Dr. Kaufman contends that Idaho Power' s
7 proposed marginal cost-based Energy Charge only captures
8 short-run marginal energy costs and recommends instead that
9 the Company incorporate long-run marginal costs or
10 implement a true-up mechanism to address forecast error.
11 The Company acknowledges that the methodology relies on
12 short-run marginal energy costs, consistent with the
13 approach proposed in IPC-E-25-17 . This short-run approach
14 provides actionable, time-sensitive price signals based on
15 near-term market conditions, system operations, and updated
16 expectations for hydro, fuel, and system dispatch.
17 In contrast, long-run marginal costs are based on
18 projected future investments — such as those associated
19 with power purchase agreements or utility-owned resource
20 additions — and are not directly tied to short-term
21 operational realities . Because of this disconnect, long-run
22 marginal cost estimates are more speculative, less
23 transparent to customers and regulators, and difficult to
24 validate . Customers cannot easily discern how their usage
25 affects those long-run projections, and regulators may face
ANDERSON, DI-REB 13
Idaho Power Company
1 challenges confirming the assumptions that underlie the
2 figures . Relying on long-run costs would therefore reduce
3 pricing clarity and weaken the link between customer
4 behavior and cost causation.
5 While Idaho Power supports the continued refinement
6 of its marginal cost methodology over time, it believes
7 that any major changes — such as the use of long-run
8 marginal costs or the implementation of a true-up — should
9 be addressed holistically through the annual update process
10 which provides the appropriate forum for evaluating
11 technical and policy considerations and for applying any
12 changes uniformly to all customers subject to marginal
13 cost-based pricing.
14 Q. What is the Company' s response to Dr.
15 Kaufman' s recommendation to implement a true-up mechanism
16 for Micron' s marginal cost-based Energy Charge?
17 A. The Company recognizes Dr. Kaufman' s concern
18 regarding potential forecast error. One of the primary
19 challenges with implementing a true-up is the difficulty in
20 defining and isolating a clear benchmark for "actual"
21 marginal energy costs, given the dependence on real-time
22 market dynamics, dispatch order, hydro conditions, and fuel
23 costs . These variables are inherently dynamic and difficult
24 to reconcile with forecasted pricing in a consistent,
25 administrable manner.
ANDERSON, DI-REB 14
Idaho Power Company
1 The Commission recently addressed this issue in IPC-
2 E-25-17, and in Order No . 36619 directed the Company to
3 work with Commission Staff to evaluate methods to verify
4 current marginal cost forecasting against actual marginal
5 costs prior to the next annual update. Idaho Power
6 recommends that any potential changes to the marginal cost-
7 based energy methodology - including whether a true-up
8 mechanism is appropriate - be considered holistically
9 within the scope of that docket and applied uniformly to
10 all customers that rely on marginal cost-based energy
11 pricing.
12 Q. Does the Company support implementing time-of-
13 use ("TOU") energy pricing for Micron?
14 A. Idaho Power is not opposed to implementing TOU
15 pricing in concept. However, there is no singular approach
16 that must apply to all customers . A uniform marginal energy
17 pricing structure, such as the one currently proposed, is a
18 reasonable starting point for a large customer with a high
19 and consistent load factor. That said, the Company would
20 not be opposed to a TOU structure, so long as the same
21 underlying data relied upon for the proposed Energy Charge
22 was used to calculate a weighted average by time period for
23 the time periods which are consistent with all other
24 industrial load pursuant to tariff Schedule 19 .
ANDERSON, DI-REB 15
Idaho Power Company
1 Q. How does the Company respond to Ms . White' s
2 proposal to shift generation and transmission cost recovery
3 into volumetric Energy Charges?
4 A. The Company does not support this
5 recommendation. Ms . White proposes shifting fixed capacity
6 cost recovery into the Energy Charge applied during high-
7 risk hours . While this approach attempts to reflect hourly
8 cost dynamics, Idaho Power believes it introduces
9 misalignment with cost causation principles . Moreover, it
10 would effectively penalize high-load factor customers -
11 those with steady and predictable usage patterns - by
12 making them pay disproportionately more relative to their
13 contribution to system peaks and/or high-risk hours . The
14 Company opposes Ms . White' s proposal because it would
15 eliminate the fixed-cost recovery safeguards built into the
16 special contract, including the Contract and Minimum
17 Billing Demands . Replacing these safeguards with a
18 volumetric rate - especially if Micron responds to peak
19 price signals - could lead to under-recovery of fixed
20 generation and transmission costs, ultimately shifting
21 those costs to other customers .
22 Q. What do you mean when you say Ms . White' s
23 recommendation would move risk to other customers?
24 A. Much of the generation and transmission-
25 related cost recovery under the proposed special contract
ANDERSON, DI-REB 16
Idaho Power Company
1 is structured to mitigate cost shifting through the
2 Contract Demand and Minimum Billing Demand provisions .
3 These provisions ensure that Micron pays for the capacity
4 and infrastructure required to serve its load, regardless
5 of monthly or hourly usage fluctuations or delays in
6 meeting its forecasted ramp schedule . Ms . White' s
7 recommendation would eliminate these safeguards by moving
8 those costs into a volumetric charge. If Micron responded
9 to price signals by reducing usage during peak periods
10 and/or high-risk hours, it would result in under collection
11 of fixed costs and shift that cost burden to other
12 customers .
13 Q. Can you explain this concern in greater
14 detail?
15 A. Penalizing high load factor customers is
16 problematic for several reasons . It could misalign prices
17 with actual cost causation by disconnecting pricing from
18 how system costs are incurred. It could also encourage
19 inefficient peaks and higher system costs by weakening
20 incentives for steady usage . It also has the potential to
21 create unfair burdens on lower-usage customers who may pay
22 disproportionately more per unit. Finally, discouraging
23 high load factor usage can suppress innovation in
24 electrification and grid optimization by penalizing
25 consistent and predictable usage profiles that are
ANDERSON, DI-REB 17
Idaho Power Company
1 otherwise beneficial to system planning and operational
2 efficiency.
3 III . DEMAND CHARGE PRICING
4 Q. Please summarize your understanding of the
5 intervenor positions regarding Idaho Power' s proposed
6 demand charges .
7 A. Mr. Eldred supports Idaho Power' s use of
8 embedded cost-based demand charges and recommends updating
9 them through a compliance filing to reflect authorized
10 revenue changes . He also emphasizes the importance of
11 reviewing load and cost allocation in the next general rate
12 case to ensure appropriate cost recovery. Dr. Kaufman
13 argues that the proposed demand charges as insufficient to
14 cover Micron' s cost responsibility, relying on his IRP-
15 based analysis that assumes no future price updates . Ms .
16 White, on the other hand, recommends eliminating demand
17 charges entirely and recovering all generation and
18 transmission costs through the volumetric Energy Charge.
19 Q. What is the Company' s position on Mr. Eldred' s
20 recommendation?
21 A. Idaho Power agrees with Mr. Eldred. The
22 Company has proposed three demand charges - Contract
23 Demand, Billing Demand, and Daily Excess Demand - each
24 based on cost causation principles and consistent with
25 prior special contracts . Idaho Power also supports updating
ANDERSON, DI-REB 18
Idaho Power Company
1 these charges through compliance filings, as needed, to
2 reflect revenue requirement changes and intends to evaluate
3 cost allocation in the next general rate case.
4 Q. How does the Company respond to Dr. Kaufman' s
5 position on demand-related pricing?
6 A. Dr. Kaufman does not propose specific levels
7 for demand charges but contends that the Company' s proposal
8 under-recovers Micron' s cost responsibility. His argument
9 is based on the flawed IRP comparison discussed earlier and
10 assumes that Micron' s pricing remains unchanged over time.
11 This assumption is inaccurate and ignores the role of
12 general rate cases in revisiting and updating pricing based
13 on actual cost allocation. The Company' s proposed demand
14 charges are intended to recover Micron' s fair share of
15 fixed system costs and help protect other customers from
16 bearing those costs .
17 Q. How does the Company respond to Ms . White' s
18 position on demand pricing?
19 A. As discussed previously in response to Ms .
20 White ' s energy pricing recommendations, eliminating the
21 demand charge structure would further disconnect prices
22 from cost causation. The Company recommends that the
23 Commission reject her proposal to eliminate demand charges .
24 Removing the demand charge structure would move further
25 away from pricing that reflects cost causation and increase
ANDERSON, DI-REB 19
Idaho Power Company
1 the risk that Idaho Power would not fully recover the costs
2 to serve Micron, ultimately resulting in other customers
3 subsidizing Micron' s load. The contractual protections in
4 the special contract — such as the Minimum Billing Demand
5 and Contract Demand — are designed to ensure that fixed
6 generation and transmission costs are recovered regardless
7 of load variability. Eliminating these elements would
8 undermine those safeguards and create a higher risk of cost
9 shift to other customers .
10 IV. NO-HARM ANALYSIS
11 Q. Please summarize your understanding of the
12 intervenor positions regarding the Company' s no-harm
13 analysis .
14 A. Mr. Eldred reviewed the Company' s no-harm
15 analysis and concluded that the input assumptions and
16 evaluation of risk variables were reasonable based on the
17 information available at the time. He clarified that he did
18 not rely exclusively on the no-harm analysis because it is
19 a multivariable analysis with many interdependent
20 assumptions . Instead, he recommends that cost allocation be
21 addressed in a future general rate case. Dr. Kaufman relies
22 on his own interpretation of the no-harm analysis to argue
23 that the proposed pricing under-recovers Micron' s costs and
24 would result in cost shifts to other customers .
ANDERSON, DI-REB 20
Idaho Power Company
1 Q. What role did the no-harm analysis play in
2 Idaho Power' s Application?
3 A. The no-harm analysis was provided as a
4 directional tool to help evaluate whether the proposed
5 initial pricing structure could reasonably mitigate cost
6 shifting. It was not used to directly set prices or
7 allocate costs . Rather, it was intended to support the
8 proposed framework and validate that it aligns with cost
9 causation and protects other customers .
10 Q. Do you believe the no-harm analysis should be
11 used to set pricing?
12 A. No. The no-harm analysis is not intended to
13 function as a pricing mechanism. It is a directional
14 evaluation performed at a specific point in time, based on
15 a defined set of assumptions that the Company believes were
16 reasonable when the analysis was conducted. While parties
17 may argue for alternative assumptions or scenarios, the
18 analysis is meant to show that — under reasonable
19 conditions — Micron' s initial pricing can avoid cost shifts
20 to other customers . The appropriate way to assign actual
21 costs is through future general rate cases, where real
22 system conditions and cost data are available.
23 Q. Have any of the assumptions used in the no-
24 harm analysis changed since it was completed?
ANDERSON, DI-REB 21
Idaho Power Company
1 A. Yes . Several assumptions used in the no-harm
2 analysis have changed, including Micron' s expected load
3 shape and ramp timing, which Micron most recently updated
4 in December 2024 consistent with the terms of the ESA, and
5 resource costs . Additionally, after the no-harm was
6 conducted, the ESA was executed, and the application in the
7 instant case was filed, Idaho Power filed its 2025 IRP -
8 Case No . IPC-E-25-23 - on June 27, 2025 . These changes
9 demonstrate the limitations of relying on any single
10 snapshot in time for ratemaking purposes . It further
11 underscores the importance of updating Micron' s pricing
12 through future general rate cases as costs become known and
13 measurable .
14 Q. How do you respond to Dr. Kaufman' s
15 interpretation of the no-harm analysis?
16 A. Dr. Kaufman uses the no-harm analysis in a
17 manner that was not intended. He draws absolute
18 conclusions, assumes the inputs are static over time, and
19 introduces his own oversimplified incremental portfolio
20 analysis - using flawed comparisons - to claim that the
21 proposed pricing results in a revenue shortfall . This
22 approach ignores the actual purpose of the no-harm analysis
23 and overlooks the role of future general rate cases and
24 compliance filings to allocate costs as they materialize.
ANDERSON, DI-REB 22
Idaho Power Company
1 Q. What is your recommendation regarding how the
2 Commission should treat the no-harm analysis?
3 A. I recommend that the Commission consider the
4 no-harm analysis as one data point among many in evaluating
5 the reasonableness of the initial pricing proposal .
6 Specifically, that an embedded approach for deriving
7 demand-related pricing ensures that Micron is covering its
8 share of all systems resources . It provides directional
9 support that embedded pricing can, based on proper
10 allocation of both embedded and new resource costs,
11 mitigate cost shift to other customers . However, ongoing
12 cost allocation and pricing must be continually addressed
13 through the general rate case process, as Mr. Eldred also
14 recommends . Idaho Power' s overall approach - including
15 demand-based pricing, marginal Energy Charge updates, and
16 contractual mechanisms such as the Contract Demand and
17 Minimum Billing Demand provisions - ensures Micron' s costs
18 are recovered fairly over time without shifting costs to
19 other customers .
20 V. CONCLUSION
21 Q. Do you have any final comments for the
22 Commission?
23 A. Yes . I recommend that the Commission:
24 (i) Approve the Special Contract and Tariff Schedule 28
25 as a reasonable foundation for serving the Micron
ANDERSON, DI-REB 23
Idaho Power Company
1 FAB, pursuant to compliance filing consistent with
2 my recommendations to ii and iii;
3 (ii) Approve the proposed marginal cost-based Energy
4 Charge, direct the Company to submit a compliance
5 filing aligning the initial Energy Charge with the
6 pricing approved in IPC-E-25-17, and support annual
7 updates through the same docket used for other
8 marginal cost-based pricing;
9 (iii) Approve the methodology used to derive the proposed
10 demand charges and direct the Company to submit a
11 compliance filing to reflect demand charge updates
12 consistent with changes approved in IPC-E-24-07;
13 (iv) Acknowledge the no-harm analysis as a directional
14 tool based on a defined set of assumptions, not a
15 pricing mechanism, and recognize that appropriate
16 cost allocation will be addressed in future general
17 rate cases using measurable data.
18 This approach ensures that Micron' s costs are recovered
19 fairly and consistently with cost causation principles,
20 while protecting other customers from potential cost shifts
21 as Micron' s load grows over time.
22 Q. Does this conclude your testimony?
23 A. Yes, it does .
24
ANDERSON, DI-REB 24
Idaho Power Company
1 DECLARATION OF GRANT T. ANDERSON
2 I, Grant T . Anderson, declare under penalty of
3 perjury under the laws of the state of Idaho:
4 1 . My name is Grant T. Anderson. I am employed
5 by Idaho Power Company as the Pricing & Tariff Manager in
6 the Regulatory Affairs Department.
7 2 . On behalf of Idaho Power, I present this
8 pre-filed rebuttal testimony in this matter.
9 3 . To the best of my knowledge, my pre-filed
10 rebuttal testimony is true and accurate.
11 I hereby declare that the above statement is true to
12 the best of my knowledge and belief, and that I understand
13 it is made for use as evidence before the Idaho Public
14 Utilities Commission and is subject to penalty for perjury.
15 SIGNED this 30th day of July 2025, at Boise, Idaho.
16 �
17 Signed: �. '44"IL
18 RANT T. ANDERSON
19
20
21
22
23
ANDERSON, DI-REB 25
Idaho Power Company
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
REBUTTAL TESTIMONY
OF
JARED L. ELLSWORTH
1 Q. Please state your name .
2 A. My name is Jared L. Ellsworth.
3 Q. Are you the same Jared L. Ellsworth who
4 submitted direct testimony in this proceeding on behalf of
5 Idaho Power Company ("Idaho Power" or "Company") ?
6 A. Yes .
7 Q. What is the purpose of your rebuttal
8 testimony?
9 A. My rebuttal testimony responds to claims
10 made by Dr. Lance Kaufman on behalf of the Idaho Irrigation
11 Pumpers Association ("IIPA") regarding Idaho Power' s long-
12 term resource planning assumptions and modeling. I
13 specifically address Dr. Kaufman' s mischaracterization of
14 the Company' s Integrated Resource Plan ("IRP") outputs, his
15 incorrect assignment of incremental costs to serve Micron,
16 and his misunderstanding of Idaho Power' s system
17 reliability and import assumptions . I also respond to
18 allegations concerning transmission costs associated with
19 serving Micron. My testimony explains how Idaho Power' s IRP
20 modeling and planning framework appropriately evaluates
21 system resource needs and reliability, while pricing and
22 cost allocation are addressed through separate ratemaking
23 processes .
24 Q. Does the fact that you do not address every
25 issue raised in the direct testimony of other parties mean
ELLSWORTH, DI-REB 2
Idaho Power Company
1 that you agree with other parties' testimony on those
2 issues?
3 A. No . It merely reflects that I chose not to
4 address all those issues . It should not be read as an
5 endorsement of, or agreement with, any unaddressed issues .
6 I . COST TO SERVE AND IRP MISCHARACTERIZATION
7 Q. Dr. Kaufman claims that the incremental cost
8 to serve Micron is $186 per megawatts-hour ("MWh") based on
9 the 2025 IRP. Do you agree?
10 A. No. Dr. Kaufman ' s calculation is flawed both
11 in methodology and execution. The $186 per MWh figure is
12 derived from a comparison between the preferred portfolio -
13 which already includes Micron' s load - and a separate IRP
14 run that adds 500 megawatts ("MW") of generic high load
15 factor incremental load and identifies a new optimized
16 portfolio . Using the difference in levelized cost between
17 these two portfolios to retroactively assign a cost to
18 Micron is circular and inappropriate, as it assumes Micron
19 is not included in the base portfolio .
20 Moreover, Dr. Kaufman' s Exhibit 203 contains a
21 miscalculation that doubles the resource cost,
22 significantly inflating the result. My Exhibit No. 2
23 illustrates and corrects this error. Additionally, the $186
24 per MWh figure does not pass a basic reasonableness check.
25 For example, based on the 2025 IRP data, a reciprocating
ELLSWORTH, DI-REB 3
Idaho Power Company
1 engine operating at a 90 percent capacity factor has a cost
2 of less than $70 per MWh - further illustrating that Dr.
3 Kaufman' s estimate is not representative of the cost to
4 serve Micron.
5 Q. Are there other issues with the interpretation
6 or use of the IRP data that you would like to clarify?
7 A. Yes . The portfolio cost shown in Idaho Power' s
8 IRP is a levelized revenue requirement, representing the
9 net present value of costs over the entire planning period.
10 These are planning metrics - not ratemaking tools - and
11 should not be interpreted as a declining revenue
12 requirement .
13 Q. Can you elaborate on how IRP modeling is
14 utilized?
15 A. IRP modeling is used to identify the least-
16 cost, least-risk long-term resource portfolio for the
17 entire system. It operates on system-level planning
18 assumptions such as levelized costs, resource diversity and
19 corresponding system contribution, market access and
20 conditions, and planning reserve margins . The assumptions
21 and methods used in IRP modeling are not intended for
22 setting prices for individual customers
23 Q. On page 5 of his direct testimony, Dr. Kaufman
24 compares the $186 per MWh cost figure to a derived cost per
25 MWh presented in recent Idaho Power Certificate of Public
ELLSWORTH, DI-REB 4
Idaho Power Company
1 Convenience and Necessity ("CPCN") filings . Do you agree
2 with that comparison?
3 A. No. Even setting aside the erroneous $186 per
4 MWh figure, Dr. Kaufman' s comparison mischaracterizes how
5 Idaho Power plans for and procures new resources . The
6 referenced costs in recent resource procurement filings
7 result from competitive procurement processes intended to
8 address system-wide capacity and energy needs - not to
9 serve an individual customer. Dr. Kaufman attempts to
10 translate a single resource' s cost into an average cost to
11 serve continuous load, assuming a 24/7 obligation met by
12 only one resource. This ignores how Idaho Power' s resources
13 are integrated and dispatched as part of a diverse system
14 portfolio .
15 Idaho Power acquires least-cost, least-risk
16 resources to address identified capacity and energy
17 shortfalls during specific high-need periods - not to
18 address all hours of the day. These recently procured
19 resources optimally fit into Idaho Power' s existing
20 resource stack and work cohesively to cost effectively
21 serve growing customer demand - as more thoroughly
22 described in the referenced resource procurement dockets .
23 Dr. Kaufman' s cost comparison calculations do not
24 include the overall system benefits of the referenced
25 resources . For example, storage resources can be charged
ELLSWORTH, DI-REB 5
Idaho Power Company
1 using low- or negative-cost energy during high solar output
2 hours and then discharged during high-demand/high-cost
3 hours later in the evening. This storage discharge energy
4 can decrease Idaho Power' s reliance on more expensive
5 market purchases or thermal fuel-based resources . The
6 referenced Jackalope wind project provides output that can
7 displace higher cost market purchase energy or thermal
8 fuel-based energy. The project can also decrease system
9 reliance on Idaho Power' s flexible hydro system during
10 lower demand parts of the day, freeing the flexible hydro
11 system to better serve higher demand/higher cost hours in
12 the evening.
13 II . INCREMENTAL RESOURCE COMPARISON
14 Q. Dr. Kaufman claims the resources selected in
15 the "With Micron" scenario are insufficient to meet
16 Micron' s full capacity requirement . Do you agree?
17 A. No. Dr. Kaufman ' s analysis overlooks the
18 fundamental principle of least-cost, least-risk resource
19 planning. The Aurora Long-Term Capacity Expansion ("LTCE")
20 model used by Idaho Power selects the optimal resource
21 portfolio needed to meet the system load and reliability
22 requirements . His claim that the scenario falls 60 MW short
23 is based on a deterministic Load and Resource ("L&R")
24 balance that does not reflect Idaho Power' s probabilistic
25 reliability planning.
ELLSWORTH, DI-REB 6
Idaho Power Company
1 Q. How did Dr. Kaufman develop his L&R balance
2 analysis?
3 A. In his "Confidential Table 2 : Portfolios
4 Underlying IPC' s No-Harm Analysis, " Dr. Kaufman
5 individually assessed the new resource additions selected
6 in both the "With Micron" and "Without Micron" scenarios
7 for years 2024 through 2033, specifically highlighting the
8 nameplate amounts of solar, wind, storage, and gas
9 resources . Dr. Kaufman then multiplied the resource
10 nameplate capacities by their corresponding Effective Load
11 Carrying Capability ("ELCC") to determine the capacity
12 contribution. However, Dr. Kaufman misapplied the ELCC
13 values and made assumptions inconsistent with Idaho Power' s
14 reliability methodology. Specifically, the analysis was
15 inconsistent with ELCCs published in Appendix C: Technical
16 Report of the 2023 IRP ("Appendix C") to solar, wind, and
17 battery resources; for gas, Dr. Kaufman assumed an ELCC of
18 one hundred percent . Dr. Kaufman then compares the
19 resulting capacity contribution values to the "With Micron"
20 scenario incremental demand.
21 Q. Do you agree with the capacity contribution
22 results of Dr. Kaufman' s L&R balance analysis?
23 A. No. Dr. Kaufman' s capacity contribution
24 calculation is fundamentally flawed. First, Idaho Power
25 states in the "Effective Load-Carrying Capability Results"
ELLSWORTH, DI-REB 7
Idaho Power Company
1 section of Appendix C that seasonal saturation ELCC curves
2 were implemented into the portfolio analysis, and the ELCC
3 values published there - referenced in Appendix C and
4 utilized by Dr. Kaufman - were solely for informational
5 purposes . Second, those values were derived using the last-
6 in ELCC method for a single load and resource year. This
7 means the ELCC values represent the capacity contribution
8 of the final resource added to the portfolio in a
9 particular year and are not intended to represent total
10 portfolio contribution across years or resource types .
11 Applying these informational values across multiple years
12 and resource classes, as Dr. Kaufman did, does not reflect
13 the diversity benefits inherent in Idaho Power' s resource
14 portfolio, nor captures the year-to-year change of the
15 ELCCs . Additionally, Dr. Kaufman assigns the full nameplate
16 capacity to gas resources without accounting for derates
17 due to forced outage rates, which overstates their
18 contribution to reliability. As a result, his capacity
19 balance assessment does not reflect the probabilistic
20 approach used by Idaho Power.
21 Q. Does Dr. Kaufman' s L&R balance analysis
22 reflect how Idaho Power performs its capacity position
23 calculation?
24 A. No. Idaho Power uses probabilistic reliability
25 analyses to calculate annual capacity positions, not the
ELLSWORTH, DI-REB 8
Idaho Power Company
1 over-simplified deterministic L&R balance Dr. Kaufman used.
2 ELCC is an output, not an input, in Idaho Power' s
3 reliability model . Dr. Kaufman' s deterministic approach
4 does not align with the current industry standard or
5 Company practice.
6 Q. Does the "With Micron" portfolio meet Idaho
7 Power' s internal reliability standard?
8 A. Yes . Both the "With Micron" and "Without
9 Micron" portfolios met the Company' s planning standard of
10 0 . 1 event-days per year Loss of Load Expectation ("LOLE") ,
11 as verified using Idaho Power' s Reliability and Capacity
12 Assessment Tool ("RCAT") .
13 III . TRANSMISSION COSTS
14 Q. Dr. Kaufman asserts that Idaho Power omitted
15 transmission costs attributable to Micron in its analysis .
16 Is this accurate?
17 A. No. All Interconnection Facilities and direct
18 assignment transmission infrastructure necessary to serve
19 Micron' s load are fully funded by Micron through the
20 Procurement and Construction Agreements, as described in my
21 direct testimony.
22 Q. What assumptions are reflected in the "With
23 Micron" and "Without Micron" portfolios regarding
24 transmission costs?
ELLSWORTH, DI-REB 9
Idaho Power Company
1 A. Both the "With Micron" and "Without Micron"
2 portfolios incorporate the same modeled assumptions for
3 transmission costs . For example, the Boardman to Hemingway
4 ("B2H") line is treated in the IRP as a resource that
5 provides capacity by enabling access to the Pacific
6 Northwest market, while Gateway West ("GWW") Segments 8 and
7 10 are modeled as necessary to integrate resources east of
8 the Treasure Valley onto the Idaho Power system. These
9 transmission investments are not tied to any single
10 customer but reflect system-level planning needs .
11 Q. Dr. Kaufman states that Micron demand is
12 equivalent to two thirds of the capacity of B2H and half
13 the capacity of GWW Segments 8 and 10, and therefore argues
14 that a proportional share of these costs should be assigned
15 to the "With Micron" portfolio. How do you respond?
16 A. Assigning a proportional share of these
17 transmission costs to the "With Micron" portfolio would
18 result in double-counting. The capacity required to serve
19 Micron is already reflected in the portfolio. Adding an
20 additional cost allocation based on relative demand would
21 incorrectly overstate Micron' s impact and is inconsistent
22 with how transmission planning and cost treatment is
23 handled within the IRP framework.
24 Q. On page 6 of his direct testimony, Dr. Kaufman
25 states that it is likely that Idaho Power will require
ELLSWORTH, DI-REB 10
Idaho Power Company
1 additional network upgrades to serve the Micron FAB. Do you
2 agree?
3 A. No. There is no evidence that such system
4 upgrades would not already be addressed through Idaho
5 Power' s existing cost allocation methodologies . The
6 Company' s no-harm analysis is grounded in assumptions
7 consistent with the 2023 IRP, which includes cost
8 assumptions related to transmission network infrastructure
9 as part of the generation cost for each resource.
10 Therefore, to the extent network costs are associated with
11 serving Micron' s load, those costs are already captured in
12 the IRP modeling and would be appropriately allocated to
13 Micron.
14 IV. ENERGY IMPORTS AND RESOURCE SURPLUS
15 Q. What topic do you address in this section?
16 A. I address Dr. Kaufman' s assumptions about
17 Idaho Power' s exposure to market losses in the event Micron
18 terminates service and explain how Idaho Power' s IRP
19 planning assumptions provide greater operational
20 flexibility.
21 Q. How do Idaho Power' s IRP modeling assumptions
22 regarding market imports impact Dr. Kaufman' s analysis of
23 lost revenues in the event of termination?
24 A. Dr. Kaufman assumes that if Micron terminates
25 service, Idaho Power would be forced to sell surplus energy
ELLSWORTH, DI-REB 11
Idaho Power Company
1 at a market rate of $45 per MWh. However, Dr . Kaufman' s
2 assumption exaggerates the potential financial exposure.
3 Idaho Power' s IRP includes seasonal import assumptions to
4 meet system needs . During these times, if Micron' s load
5 were removed, Idaho Power would reduce imports rather than
6 generating surplus energy to sell at a loss .
7 V. CONCLUSION
8 Q. Please summarize your conclusions .
9 A. Dr. Kaufman ' s testimony contains several
10 critical errors in his use and interpretation of Idaho
11 Power' s IRP. He mischaracterizes the portfolio comparison
12 by assigning incremental costs to Micron based on flawed
13 data, including a calculation error that doubles resource
14 costs . He incorrectly assumes Idaho Power must add 427 MW
15 of capacity contribution to serve Micron, misinterprets
16 reliability planning standards, and overstates potential
17 financial risk by overlooking Idaho Power' s planning
18 flexibility. Idaho Power' s modeling and planning framework
19 appropriately evaluates system-level needs and supports
20 reliable and cost-effective resource development. This
21 distinction between long-term system planning and
22 ratemaking is essential in evaluating the relevance of Dr.
23 Kaufman" s testimony.
24 Q. Does this conclude your testimony?
25 A. Yes, it does .
ELLSWORTH, DI-REB 12
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 and Resource Planning Director for the Planning,
7 Engineering and Construction Department.
8 2 . On behalf of Idaho Power, I present this
9 pre-filed rebuttal testimony and Exhibit No. 2 in this
10 matter.
11 3 . To the best of my knowledge, my pre-filed
12 rebuttal testimony and Exhibit are true and accurate.
13 I hereby declare that the above statement is true to
14 the best of my knowledge and belief, and that I understand
15 it is made for use as evidence before the Idaho Public
16 Utilities Commission and is subject to penalty for perjury.
17 SIGNED this 30th day of July 2025, at Boise, Idaho.
18
19
20
21 Signed:
22 JARED L. ELLSWORTH
23
24
25
26
27
ELLSWORTH, DI-REB 13
Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-44
IDAHO POWER COMPANY
ELLSWORTH , DI-REB
TESTIMONY
EXHIBIT NO. 2
Case No.IPC-E-24-44
Ellsworth Exhibit No.2
Kaufman(IIPA)Calculation Error
Column (A) (B) (C) (D) (E) (F) (G) (H) (1)
(A +B) (A*2+B) (E+F) (E*2+F)
Preferred Portfolio Additional 500 MW Portfolio Incremental
................................................................................ ................................................................................
Resource Market Portfolio Kaufman Resource Market Portfolio Kaufman Energy
Row Year Total Total Total Total Total Total Total Total (MWh)
(1) 2026 $ 509,589 $ 106,830 $ 616,419 $ 1,126,007 $ 509,649 $ 106,736 $ 616,385 $ 1,126,035 -
(2) 2027 630,798 93,676 724,473 1,355,271 631,024 93,365 € 724,390 € 1,355,414 € -
(3) 2028 686,016 55,783 741,799 1,427,815 686,228 55,669 741,896 1,428,124 -
(4) 2029 864,936 10,109 875,045 1,739,981 887,073 16,791 € 903,864 € 1,790,938 € 227,182
(5) 2030 1,009,302 (24,263) 985,039 1,994,341 1,040,005 (13,255) 1,026,750 2,066,755 501,035
(6) 2031 873,781 128,425 1,002,206 1,875,987 906,024 151,116 € 1,057,140 € 1,963,164 € 925,398
(7) 2032 866,518 162,663 1,029,181 1,895,699 982,752 176,146 1,158,898 2,141,650 1,644,927
(8) 2033 854,610 147,331 1,001,941 1,856,552 1,138,529 157,277 € 1,295,806 € 2,434,335 € 3,114,290
(9) 2034 870,075 143,675 1,013,750 1,883,825 1,192,661 154,607 1,347,268 2,539,929 4,041,267
(10) 2035 888,187 144,974 1,033,161 1,921,348 1,221,294 159,098 € 1,380,392 € 2,601,686 € 4,056,327
(11) 2036 869,065 141,687 1,010,752 1,879,818 1,207,558 156,480 1,364,038 2,571,596 4,063,013
(12) 2037 896,125 133,486 1,029,611 1,925,736 1,245,368 144,578 € 1,389,946 € 2,635,314 € 4,056,341
(13) 2038 898,532 128,504 1,027,036 1,925,568 1,269,099 139,716 1,408,815 2,677,914 4,056,406
(14) 2039 910,719 103,120 1,013,839 1,924,557 1,287,539 113,916 € 1,401,455 € 2,688,994 € 4,056,328
(15) 2040 922,326 93,751 1,016,078 1,938,404 1,318,891 102,577 1,421,468 2,740,359 4,062,989
(16) 2041 955,956 82,225 1,038,181 1,994,136 1,355,159 95,565 € 1,450,724 € 2,805,883 € 4,056,197
(17) 2042 963,642 87,086 1,050,728 2,014,371 1,366,472 98,980 1,465,452 2,831,924 4,056,387
(18) 2043 1,021,168 92,079 1,113,247 2,134,415 1,430,823 102,275 € 1,533,098 € 2,963,921 € 4,056,320
(19) 2044 1,049,931 79,950 1,129,881 2,179,812 1,462,456 92,810 1,555,266 3,017,722 4,063,038
(20) 2045 1,098,969 86,582 1,185,551 2,284,520 1,521,368 97,743 € 1,619,111 3,140,479 € 4,056,320
..................................... ..... .. . .. s <......................................:....................................................................................................................................................................
(21) Total $ 17,640,244 $ 1,997,673 $ 19,6-37,917 $ 37,278,162 $ 22,659,973 $ 2,202,190 $ 24,862,163 $ 47,522,136 55,093,765
............................................................................................_..........................................................................................................................................................................................................
(22)
(23) Comparison of IRP Portfolio vs.Kaufman Exhibit 203
(24) 500 MW vs.IRP Preferred Portfolio $/MWh Notes:
(25) Corrected Calculation $95 Rows 4-20:(Column G-Column C)/Column I
(26) IIPA Calculation With Error $186 Rows 4-20:(Column H-Column D)/Column I
...............................................................................................................................................................
(27) %Difference 96%
.............................................................................................................................................................:
Exhibit No.2
Case No. IPC-E-24-44
J. Ellsworth, IPC
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