20250905Direct Ellsworth.pdf

RECEIVED
September 05, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY' S APPLICATION FOR ) CASE NO. IPC-E-25-27
APPROVAL OF A POWER PURCHASE )
AGREEMENT WITH BLACKS CREEK )
ENERGY CENTER, 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 25-year Power Purchase Agreement ("PPA")
15 between Blacks Creek Energy Center, LLC and Idaho Power
16 Company supplying 80 megawatts ("MW") of output from the
17 solar powered generation facility to the Company ("Blacks
18 Creek Project") , and (2) acknowledging that the resulting
19 expenses associated with the PPA are prudently incurred for
20 ratemaking purposes . The Blacks Creek Project is necessary
21 for Idaho Power to continue to provide safe, reliable
22 electric service in 2027 and beyond.
23 Q. What is the purpose of your testimony in this
24 case?
ELLSWORTH, DI 2
Idaho Power Company

1 A. The purpose of my testimony is to inform the
2 Commission of the Company' s need for new resources to meet
3 an identified capacity deficit in 2027 as informed by a
4 Loss of Load Expectation ("LOLE") methodology utilized in
5 the 2023 Integrated Resource Plan ("IRP") , and subsequently
6 further enhanced through system reliability evaluations . I
7 will describe the most recent assessment of system
8 reliability and its impact to the capacity deficit
9 identified in the previous system reliability assessment.
10 Finally, I will provide support for the acquisition of
11 resources to address the identified near-term capacity
12 needs .
13 Q. Is this the same assessment of system
14 reliability that was performed to support the Company' s
15 request in Case No. IPC-E-25-10, Idaho Power Company's
16 Application for Approval of a Power Purchase Agreement and
17 an Energy Storage Agreement with Crimson Orchard Solar LLC
18 ("Crimson Orchard Project") , the most recent request for
19 approval of a resource procurement, which was also specific
20 to 2027 capacity needs?
21 A. No. The system reliability assessment
22 performed to support the Company' s request in this case
23 includes refreshed inputs and assumes the resources for
24 which Idaho Power seeks approval in Case No. IPC-E-25-10,
25 the Crimson Orchard Project, are online by June 1, 2027 .
ELLSWORTH, DI 3
Idaho Power Company

1 The most recent system reliability assessment identifies a
2 2027 capacity deficit of 143 MW.
3 I . BACKGROUND
4 Q. What is the goal of the IRP?
5 A. The goal of the IRP is to ensure : (1) Idaho
6 Power' s system has sufficient resources to reliably serve
7 customer demand and flexible capacity needs over a 20-year
8 planning period, (2) the selected resource portfolio
9 balances cost, risk, and environmental concerns, (3)
10 balanced treatment is given to both supply-side resources
11 and demand-side measures, and (4) the public is involved in
12 the planning process in a meaningful way. Idaho Power uses
13 Energy Exemplar' s Aurora' s Long-Term Capacity Expansion
14 ("LTCE") modeling platform to develop portfolios, through
15 the selection of a variety of supply- and demand-side
16 resource options, that are least-cost for a variety of
17 alternative future scenarios while meeting reliability
18 criteria. To verify the portfolios meet the Company' s
19 reliability requirements, Idaho Power utilizes a LOLE
20 methodology.
21 Q. Please explain the Loss of Load Expectation.
22 A. The LOLE is a statistical measure of a
23 system' s resource adequacy, describing the expected number
24 of event-days per year that a system would be unable to
25 meet demand. As utilities continue to add more renewable
ELLSWORTH, DI 4
Idaho Power Company

I energy to the electric grid, analyzing the effect variable
2 energy resources have on system reliability has become more
3 critical . The LOLE methodology recognizes that the output
4 of variable energy resources, such as wind and solar,
5 change with time (with their hourly output being dependent
6 on a multitude of factors like weather and environmental
7 conditions) ; it is essential to capture and value that
8 variability.
9 Q. What inputs are derived from the LOLE
10 methodology that are utilized in the Aurora LICE model?
11 A. Idaho Power implements the LOLE methodology
12 through an internally developed Reliability and Capacity
13 Assessment Tool ("RCAT") which is capable of producing
14 inputs such as a Planning Reserve Margin ("PRM") and
15 resource Effective Load Carrying Capability ("ELCC")
16 values . The PRM can be defined as the percentage of
17 expected capacity resources above forecasted peak demand.
18 The ELCC calculation is a reliability-based metric used to
19 assess the capacity contribution of variable and energy-
20 limited resources . The PRM and ELCC values that are
21 calculated using the LOLE methodology are a direct input to
22 the Aurora LTCE model .
23 Q. How are the PRM and ELCC values utilized?
24 A. Because the Aurora LTCE model and the RCAT are
25 two separate tools, a translation is required between the
ELLSWORTH, DI 5
Idaho Power Company

1 probabilistic LOLE analysis performed in RCAT and the
2 portfolios produced by the Aurora LTCE model . First, PRM
3 and ELCC values are calculated using the LOLE methodology,
4 which serve as direct inputs to the Aurora LTCE model .
5 After Aurora solves for and produces portfolios, select
6 resource buildouts and their corresponding data are
7 analyzed with the LOLE methodology and tested to ensure
8 they meet the pre-designated reliability hurdle through the
9 calculation of annual capacity positions . It is critical
10 when comparing future resource portfolios that each plan
11 achieves at least a base reliability threshold. Figure 1
12 below illustrates the model consolidation process .
13 Figure 1 . Idaho Power' s Reliability Flowchart
Generation ELCC
EXMNe ioae Ca.rying Cep.Nkli
RCAT LOLE nLTC
C.Reliability
o IRF
Febaoibty a Caps dy Ines of load EXPMation long TM Capxly Expansion
Assnnxoeol T-1 4 - Jdle
�MAIIAX AURORA
PRM LRtiR
Wad
Elwrlaxaa.ww/n Cay�AyEOMIIOII
14
15 Q. You indicated the RCAT and Aurora serve
16 different purposes in Idaho Power' s planning process, how
17 is the data exchanged between the two models translated
18 and aligned?
ELLSWORTH, DI 6
Idaho Power Company

1 A. To better assess the dynamic diversity benefit
2 caused by a changing resource mix, and to synchronize the
3 models, beginning with the 2023 IRP a feedback process was
4 implemented between the Aurora LTCE model and the RCAT .
5 Under the feedback process, the annual capacity positions
6 for an Aurora LTCE main case portfolio buildout were
7 calculated using the RCAT. Once the annual capacity
8 positions were known, the PRM in the Aurora LTCE model was
9 modified in years that had significant resource changes so
10 that both models identified a similar annual capacity
11 position. The feedback loop continued until the main case
12 portfolio was reliable as measured by the annual capacity
13 position to meet the LOLE threshold. The resulting Aurora-
14 produced optimized main case portfolios provide the least-
15 cost, least-risk future resource buildouts .
16 II . ANNUAL CAPACITY POSITION
17 Q. You indicated the Company updated the system
18 reliability assessment following the filing of Idaho
19 Power' s request for approval of the Crimson Orchard
20 Project. Why was the system reliability assessment updated?
21 A. The Company recognizes that during the near-
22 term resource decision-making phase, the annual capacity
23 positions can be very fluid. In addition, in the face of
24 growing loads, Idaho Power closely monitors resource needs
25 and responds with added urgency, as evidenced by Idaho
ELLSWORTH, DI 7
Idaho Power Company

1 Power' s consecutive requests to acquire resources to be
2 online in 2023, 2024, 2025, 2026 and 2027 . 1 The most recent
3 system reliability assessment has identified a capacity
4 deficit of 143 MW in 2027 .
5 Q. What drove the changes to the annual capacity
6 positions for 2027 in the most recent system reliability
7 assessment?
8 A. Any time the system reliability evaluation is
9 performed, Idaho Power includes the most up-to-date load
10 and resource inputs . The load forecast, which utilizes the
11 70th percentile peak load forecast for all months as
12 discussed in the Company' s request for approval of the
13 Crimson Orchard Project, has been updated and therefore has
14 been incorporated in the system reliability evaluation
15 performed for this case.
16 III . MEETING THE CAPACITY DEFICIENCY
17 Q. How does the Company propose to address the
18 2027 capacity deficit presented in this case?
19 A. As described in the Direct Testimony of Mr.
20 Eric Hackett, on August 8, 2025, Idaho Power executed the
21 Blacks Creek PPA, which will supply the 80 MW output to
22 the Company. While this resource was initially considered
23 as a project to meet Idaho Power' s 2028 capacity needs,
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, IPC-E-24-46, and IPC-E-25-10.
ELLSWORTH, DI 8
Idaho Power Company

1 the developer indicated the ability to advance the
2 commercial operation date to June 1, 2027 . Note, the Blacks
3 Creek Project is adjacent to, but incremental to and
4 distinct from, the Blacks Creek 320 MW solar project that
5 is the subject of a Clean Energy Your Way PPA under the
6 Brisbie special contract.
7 Q. How does the addition of the Blacks Creek
8 Project impact the capacity deficit in 2027?
9 A. Including the most up-to-date load and
10 resource inputs and market purchase assumptions, and
11 assuming all 2026 projects, the Jackalope Project, the
12 Crimson Orchard Project, and the Blacks Creek Project
13 reach commercial operation on time, the addition of the
14 Blacks Creek PPA would reduce the 2027 capacity deficit of
15 143 MW to a capacity deficit of 120 MW. The addition of
16 the Blacks Creek Project, one of the final shortlist
17 projects procured as a result of a Request for Proposals
18 ("RFP") , will support continued safe, reliable operations
19 in 2027 and beyond.
20 Q. You have indicated a capacity deficit will
21 still exist in 2027 even with the Blacks Creek Project .
22 What steps is Idaho Power taking to reduce that deficit?
23 A. The Company continues negotiations with
24 developers and energy suppliers for additional resources
25 necessary to meet the remaining 2027 capacity deficiency.
ELLSWORTH, DI 9
Idaho Power Company

1 In addition, as discussed earlier in my testimony, the
2 Company closely monitors resource needs, evaluating the
3 changing load and resource assumptions utilized in the
4 reliability analysis and the potential impact on the
5 capacity deficit . Therefore, because there are time
6 constraints associated with the Blacks Creek Project,
7 Idaho Power is only filing a request for approval of the
8 Blacks Creek PPA at this time .
9 Q. Why do you believe there is sufficient support
10 for the procurement of the Blacks Creek Project?
11 A. The resource acquisition presented in this
12 case was pursued and procured as a least-cost, least-risk
13 method of meeting the capacity deficits first identified
14 in the Company' s 2023 IRP and subsequently with the
15 results of the updated system reliability evaluation. The
16 fluidity of the capacity deficit period, continued high
17 load growth, and supply chain disruptions and delays
18 further support the resource procurement which is
19 necessary to adequately address 2027 capacity deficits .
20 Q. Are there any additional benefits beyond the
21 Blacks Creek Project being a least-cost, least-risk
22 resource necessary for meeting Idaho Power' s capacity
23 needs?
24 A. Yes . As evidenced by the annual capacity
25 positions presented in the 2025 IRP, incremental capacity
ELLSWORTH, DI 10
Idaho Power Company

1 deficits were expected beginning in 2027 and continuing
2 annually through the remainder of the planning period. As
3 detailed in the table below, the most recent system
4 reliability assessment shows a near-term incremental
5 capacity deficit even larger than previously expected in
6 2028 and 2029 :
7 Table 1 . Annual Capacity Position 2028-2030
Year 2025 IRP2 Most Recent3
Capacity Position Capacity Position
2028 (105) MW (186) MW
2029 (297) MW (363) MW
2030 (411) MW (477) MW
8
9 Q. How does the addition of the Blacks Creek
10 Project impact the annual capacity positions between 2028
11 and 2030?
12 A. In addition to helping meet the capacity
13 deficit of 143 MW in 2027, the Blacks Creek Project will
14 reduce the incremental capacity needs beyond 2027 as shown
15 in Table 2 below.
16
17
18
2 2025 IRP, Table 11.14. 2030 position adjusted to include Bridger Units 3 and
4.
3 Assumes a B2H online date and Four Corners capacity availability of November
2027. Assumes the Jackalope 600 MW Wind Project and Crimson Orchard Project
online June 2027 and Blacks Creek 320 MW solar online December 2027.
ELLSWORTH, DI 11
Idaho Power Company

1 Table 2 . Annual Capacity Position with the Blacks Creek
2 Project 2027-2030
Year Most Recent Most Recent Capacity Position
Capacity Position w/Blacks Creek Project4
2027 (143) MW (120) MW
2028 (186) MW (177) MW
2029 (363) MW (355) MW
2030 (477) MW (470) MW
3
4 A delay of resource procurements in 2027 will only
5 exaggerate the capacity deficiencies in 2028 and beyond.
6 Q. Beyond the capacity benefit, does the project
7 provide any additional benefits to Idaho Power' s system?
8 A. Yes . While the Blacks Creek Project' s capacity
9 benefit (i .e. , the ELCC) is only a fraction of the
10 project" s nameplate rating, it was found to be more cost-
11 effective than other 2028 resource bids . As described in
12 more detail in Mr. Hackett' s testimony, even absent the
13 Company' s capacity needs, the results of the Aurora
14 modeling show that the Blacks Creek Project would save
15 money over the project' s life because it will provide Idaho
16 Power cost-effective energy, allowing the Company to reduce
17 its reliance on existing, more expensive energy resources,
18 optimizing the dispatch of the system.
4 Id.
ELLSWORTH, DI 12
Idaho Power Company

1 Q. Did the Company evaluate any alternative
2 solutions for meeting the 2027 capacity deficiency to avoid
3 building a new resource?
4 A. Yes . As I discussed earlier in my testimony,
5 as part of the IRP process, the Company uses Aurora' s LTCE
6 modeling platform to develop portfolios, through the
7 selection of a variety of supply- and demand-side resource
8 options, that are least-cost for a variety of alternative
9 future scenarios while meeting reliability criteria. The
10 future supply- and demand-side resources available to meet
11 identified capacity deficiencies, whose costs are generally
12 based on the 2024 Annual Technology Baseline report
13 released by the National Renewable Energy Laboratory, 5
14 include new gas-fired resources, wind, solar, battery
15 storage, nuclear, geothermal, pumped hydro storage, market
16 purchases via available transmission capacity, demand
17 response and energy efficiency. The Preferred Portfolio
18 from the 2023 IRP, the most recent IRP that included
19 selectable 2027 resources for the Preferred Portfolio,
20 identified the combined procurement of 400 MW of wind, 375
21 MW of solar, and 5 MW of battery storage as the most cost-
22 effective resources for meeting the identified capacity
23 deficits in 2027 along with 20 MW of energy efficiency
24 potential . The results are indicative of the Company' s need
5 NREL Annual Technology Baseline.
ELLSWORTH, DI 13
Idaho Power Company

1 to procure resources to continue to provide safe, reliable
2 electric service to its customers in 2027 and beyond.
3 Q. What actions has Idaho Power taken to-date to
4 acquire least-cost, least-risk resources to ensure
5 continued safe, reliable electric service in 2027?
6 A. Under Idaho law, Idaho Power has an obligation
7 to provide adequate, efficient, just, and reasonable
8 service on a nondiscriminatory basis to all those that
9 request it within its certificated service area. 6 Further,
10 as indicated by Order No. 35643, Idaho Power is responsible
11 for planning and managing its load and resource portfolio
12 and the Commission expects "the Company to closely monitor
13 its projected capacity needs going forward and to act
14 proactively to ensure a robust RFP process can be
15 completed. "' Therefore, in order to meet its obligations to
16 reliably serve customers, Idaho Power filed an application
17 with the Public Utility Commission of Oregon ("OPUC") to
18 open an independent evaluator selection docket to oversee
19 the RFP process, 8 in compliance with the OPUC competitive
20 bidding guidelines, which the Commission directed Idaho
21 Power to follow as well . 9 This competitive solicitation
6 Idaho Code §§ 61-302, 61-315, 61-507.
Page 13.
8 Docket UM 2255.
9 Order No. 32745. Case No. IPC-E-10-03.
ELLSWORTH, DI 14
Idaho Power Company

1 process is discussed in greater detail in the Direct
2 Testimony of Mr. Eric Hackett.
3 Given the significant timeframe related to the RFP
4 process under the competitive bidding guidelines, which
5 spans nearly 15 months and is solely related to the RFP
6 process and excludes the time required for contract
7 negotiation and execution, material procurement, and
8 construction, which can add another two to six years to the
9 process, the RFP remained flexible to account for the
10 fluidity of the Company' s annual capacity positions as well
11 as any potential delays in the B2H online date and other
12 projects . Ultimately, the resources selected through the
13 RFP process were based on the recently-identified capacity
14 deficiency of 143 MW in 2027 . Note, this 143 MW deficit is
15 perfect capacity, so it requires Idaho Power to procure
16 more megawatts of nameplate capacity, depending on the ELCC
17 of each resource. Through the Company' s robust competitive
18 bidding process, Idaho Power identified the most cost-
19 effective bids from the RFP evaluation as necessary to fill
20 the 2027 capacity deficit, resulting in the execution of
21 the Blacks Creek PPA, supplying Idaho Power with 80 MW of
22 solar generation.
23
24
25
ELLSWORTH, DI 15
Idaho Power Company

1 IV. CONCLUSION
2 Q. Please summarize your testimony.
3 A. Idaho Power' s most recent system reliability
4 evaluation has identified a capacity deficiency of 143 MW
5 in 2027 . In response to this resource need, the Company has
6 identified the Blacks Creek Project, providing a total
7 output of 80 MW of solar generation, as a least-cost,
8 least-risk resource for which Idaho Power is requesting
9 Commission approval at this time.
10 Q. Does this complete your testimony?
11 A. Yes, it does .
12
ELLSWORTH, DI 16
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 5th day of September 2025, at Boise,
17 Idaho .
18 �✓ 1\
19 Signed:
20
ELLSWORTH, DI 17
Idaho Power Company