20250919Direct Ellsworth.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY' S APPLICATION FOR A ) CASE NO. IPC-E-25-29
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR THE BENNETT GAS )
EXPANSION PROJECT AND FOR AN )
ASSOCIATED ACCOUNTING ORDER. )
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
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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 granting a Certificate of Public Convenience and Necessity
15 ("CPCN") for the expansion of the existing Bennett Mountain
16 Power Plant to include the addition of a cost-effective
17 natural gas-fueled facility providing up to 167 megawatts
18 ("MW") of generation ("Bennett Gas Expansion Project") to
19 meet an identified capacity deficit in 2028, (2)
20 confirmation of the Company' s application of accrual of
21 Allowance for Funds Used During Construction ("AFUDC") for
22 the Bennett Gas Expansion Project upon initial procurement
23 activities for the reciprocating internal combustion
24 engines ("recips") , and (3) approving the commencement of
25 the accrual of AFUDC on capital expenditures associated
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Idaho Power Company

1 with future resource procurements at the time the project
2 has been deemed viable by the Company. The Bennett Gas
3 Expansion Project is necessary for Idaho Power to continue
4 to provide safe, reliable electric service in 2028 and
5 beyond.
6 Q. How is the Company' s case organized?
7 A. My testimony begins with the identification of
8 Idaho Power' s need for new resources to meet an identified
9 capacity deficit in 2028 as informed by the Loss of Load
10 Expectation ("LOLE") methodology utilized in the 2023
11 Integrated Resource Plan ("IRP") , and subsequently further
12 enhanced through system reliability evaluations . I will
13 describe the most recent assessment of system reliability
14 and its impact to the capacity deficit providing support
15 for the acquisition of resources to address the identified
16 near-term capacity needs .
17 The Direct Testimony of Mr . Eric Hackett provides an
18 overview of the competitive resource acquisition process
19 undertaken to meet Idaho Power' s identified capacity
20 deficiency, providing an overview of the extensive Request
21 for Proposals ("RFP") process undertaken in accordance with
22 the Public Utility Commission of Oregon' s ("OPUC")
23 competitive bidding rules . Mr. Hackett explains how the
24 resulting least-cost, least-risk resources were selected
25 through the fair and competitive RFP process, including the
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Idaho Power Company

1 Bennett Gas Expansion Project, a natural gas facility that
2 will be constructed alongside Idaho Power' s existing
3 Bennett Mountain Power Plant in Mountain Home, Idaho, and
4 will consist of nine, fast-ramping, natural gas-fueled
5 recips that will provide up to 167 MW of generation.
6 Finally, the Direct Testimony of Ms . Courtney Waites
7 describes AFUDC and the commencement of its accrual as soon
8 as funds are expended and committed to a construction
9 project. For generation resources, this has typically
10 occurred subsequent to the request for a CPCN. However,
11 Idaho Power has incurred expenditures associated with the
12 Bennett Gas Expansion Project prior to filing the request
13 for a CPCN and therefore is requesting the Commission
14 confirm the application of accrual of AFUDC when
15 expenditures are first incurred.
16 Q. You indicated you performed an assessment of
17 system reliability. Is this the same assessment that was
18 performed to support the Company' s request in Case No. IPC-
19 E-25-27, Idaho Power Company's Application for Approval of
20 a Power Purchase Agreement with Blacks Creek Energy Center,
21 LLC ("Blacks Creek Project") , the most recent request for
22 approval of a resource procurement, which presented the
23 Company' s 2027 through 2030 capacity needs?
24 A. No. The system reliability assessment
25 performed to support the Company' s request in this case
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Idaho Power Company

1 includes refreshed inputs and assumes the resource for
2 which Idaho Power seeks approval in Case No. IPC-E-25-27,
3 the Blacks Creek Project, is online by June 1, 2027 . The
4 most recent system reliability assessment identifies a 2028
5 capacity deficit of 265 MW.
6 I . BACKGROUND
7 Q. What is the goal of the IRP?
8 A. The goal of the IRP is to ensure : (1) Idaho
9 Power' s system has sufficient resources to reliably serve
10 customer demand and flexible capacity needs over a 20-year
11 planning period, (2) the selected resource portfolio
12 balances cost, risk, and environmental concerns, (3)
13 balanced treatment is given to both supply-side resources
14 and demand-side measures, and (4) the public is involved in
15 the planning process in a meaningful way. Idaho Power uses
16 Energy Exemplar' s Aurora' s Long-Term Capacity Expansion
17 ("LTCE") modeling platform to develop portfolios, through
18 the selection of a variety of supply- and demand-side
19 resource options, that are least-cost for a variety of
20 alternative future scenarios while meeting reliability
21 criteria . To verify the portfolios meet the Company' s
22 reliability requirements, Idaho Power utilizes the LOLE
23 methodology.
24 Q. Please explain Loss of Load Expectation.
25 A. LOLE is a statistical measure of a system' s
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Idaho Power Company

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

1 probabilistic LOLE analysis performed in the 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 LR<R
Wad
n..rlaw••»� awanEealuo.
14
15 Q. You indicated that 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?
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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 capacity position.
11 The feedback loop continued until the main case portfolio
12 was reliable as measured by the annual capacity position to
13 meet the LOLE threshold. The resulting Aurora-produced
14 optimized main case portfolios provide the least-cost,
15 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 Blacks Creek Project.
20 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
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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 265 MW in 2028 .
5 Q. What drove the changes to the annual capacity
6 positions for 2028 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 in the
12 RCAT, has been updated and therefore has been incorporated
13 in the system reliability evaluation performed for this
14 case . In addition, as evidenced by Idaho Power' s request to
15 withdraw the CPCN associated with the Jackalope Wind
16 Project filed concurrently with this case, which is delayed
17 due to uncertainty around federal land use policies2 and
18 would have added 600 MW of nameplate capacity to supply
19 wind-energy by June 1, 2027, the Company has excluded the
20 project from the available resource inputs in 2027 .
21
22
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, IPC-E-25-10, and IPC-E-25-27.
2 Case No. IPC-E-25-28, In the Matter of the Petition of Idaho Power Company to
Withdraw Certificate No. 559, Inclusive of the Build Transfer Agreement and
Power Purchase Agreement for the Jackalope Wind Project Approved by Order No.
36659.
ELLSWORTH, DI 9
Idaho Power Company

1 III . MEETING THE CAPACITY DEFICIENCY
2 Q. How does the Company propose to address the
3 2028 capacity deficit presented in this case?
4 A. As described in the Direct Testimony of Mr.
5 Eric Hackett, on August 19, 2025, the Company' s Internal
6 Bid Team was provided a Notice to Proceed with the Bennett
7 Gas Expansion Project, a natural gas facility that will
8 provide up to 167 MW of generation. This benchmark
9 resource was initially considered as a project to meet
10 Idaho Power' s 2029 capacity needs but was able to
11 accelerate the commercial operation date to June 1, 2028 .
12 Q. How does the addition of the Bennett Gas
13 Expansion Project impact the capacity deficit in 2028?
14 A. Including the most up-to-date load and
15 resource inputs and market purchase assumptions, including
16 the removal of the Jackalope Wind Project, and assuming
17 all 2026 projects, the Crimson Orchard Project, the Blacks
18 Creek Project, and the Bennett Gas Expansion Project reach
19 commercial operation on time, the addition of the gas
20 facility would reduce the 2028 capacity deficit of 265 MW
21 to a capacity deficit of 155 MW.3 The addition of the
22 Bennett Gas Expansion Project, one of the final shortlist
23 projects procured as a result of an RFP, will support
3 In 2028, the incremental ELCC of the Bennett Gas Expansion Project is 110 MW
due to the June 2028 in-service date. However, as shown in Table 2, the ELCC of
the project in future years, is closer to 156 MW.
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Idaho Power Company

1 continued safe, reliable operations in 2028 and beyond.
2 Q. You have indicated a capacity deficit will
3 still exist in 2028 even with the Bennett Gas Expansion
4 Project. What steps is Idaho Power taking to reduce that
5 deficit?
6 A. The Company continues negotiations with
7 developers and energy suppliers for additional resources
8 necessary to meet the remaining 2028 capacity deficiency.
9 In addition, as discussed earlier in my testimony, the
10 Company closely monitors resource needs, evaluating the
11 changing load and resource assumptions utilized in the
12 reliability analysis and the potential impact on the
13 capacity deficit. Therefore, because of the long lead time
14 associated with materials procurement, Idaho Power is only
15 filing a request for a CPCN for the Bennett Gas Expansion
16 Project at this time .
17 Q. Why do you believe there is sufficient support
18 for the procurement of the Bennett Gas Expansion Project?
19 A. The resource acquisition presented in this
20 case was pursued and procured as a least-cost, least-risk
21 method of meeting the capacity deficits first identified
22 in the Company' s 2023 IRP and subsequently with the
23 results of the updated system reliability evaluation. The
24 fluidity of the capacity deficit period, continued high
25 load growth, and supply chain disruptions and delays
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Idaho Power Company

1 further support the resource procurement which is
2 necessary to adequately address 2028 capacity deficits .
3 Q. Are there any additional benefits beyond the
4 Bennett Gas Expansion Project being a least-cost, least-
5 risk resource necessary for meeting Idaho Power' s capacity
6 needs?
7 A. Yes . As evidenced by the annual capacity
8 positions presented in the 2025 IRP, incremental capacity
9 deficits were expected beginning in 2027 and continuing
10 annually through the remainder of the planning period. As
11 detailed in the table below, the most recent system
12 reliability assessment shows a near-term incremental
13 capacity deficit larger than previously expected, even
14 larger than presented in the Company' s request for
15 approval of the Blacks Creek Project :
16 Table 1 . Annual Capacity Position 2028-2030
Year 2025 IRP' Capacity Position Most Recent6
Capacity Case No. IPC-E-25-275 Capacity Position
Position
2028 (105) MW (177) MW (265) MW
2029 (297) MW (355) MW (447) MW
2030 (411) MW (470) MW (577) MW
17
4 2025 IRP, Table 11.14. 2030 position adjusted to include Bridger Units 3 and
4.
5 Assumes a B2H online date and Four Corners capacity availability of November
2027. Assumes the 600 MW Jackalope Wind Project, Crimson Orchard Project, and
Blacks Creek 80 MW solar online June 2027 and Blacks Creek 320 MW solar online
December 2027.
6 Assumes a B2H online date and Four Corners capacity availability of November
2027. Assumes the Crimson Orchard Project and Blacks Creek 80 MW solar online
June 2027 and Blacks Creek 320 MW solar online December 2027.
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Idaho Power Company

1 Q. How does the addition of the Bennett Gas
2 Expansion Project impact the annual capacity positions
3 between 2028 and 2030?
4 A. In addition to helping meet the capacity
5 deficit of 265 MW in 2028, the Bennett Gas Expansion
6 Project will reduce the incremental capacity needs beyond
7 2028 as shown in Table 2 below.
8 Table 2 . Annual Capacity Position with the Bennett Gas
9 Expansion Project 2028-2030
Year Most Recent Most Recent Capacity
Capacity Position Position w/Bennett Gas
Expansion Project
2028 (265) MW (155) MW
2029 (447) MW (291) MW
2030 (577) MW (421) MW
10
11 A delay of resource procurements in 2028 will only
12 exaggerate the capacity deficiencies in 2029 and beyond.
13 Q. Did the Company evaluate any alternative
14 solutions for meeting the 2028 capacity deficiency to avoid
15 building a new resource?
16 A. Yes . As I discussed earlier in my testimony,
17 as part of the IRP process, the Company uses Aurora' s LTCE
18 modeling platform to develop portfolios, through the
19 selection of a variety of supply- and demand-side resource
' Assumes a B2H online date and Four Corners capacity availability of November
2027. Assumes the Crimson Orchard Project and Blacks Creek 80 MW solar online
June 2027 and Blacks Creek 320 MW solar online December 2027.
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Idaho Power Company

1 options, that are least-cost for a variety of alternative
2 future scenarios while meeting reliability criteria. The
3 future supply- and demand-side resources available to meet
4 identified capacity deficiencies, whose costs are generally
5 based on the 2024 Annual Technology Baseline report
6 released by the National Renewable Energy Laboratory, $
7 include new gas-fired resources, wind, solar, battery
8 storage, nuclear, geothermal, pumped hydro storage, market
9 purchases via available transmission capacity, demand
10 response and energy efficiency. The Preferred Portfolio
11 from the 2025 IRP identified 150 MW of new gas-fired
12 resources as a cost-effective resource for helping meet the
13 identified capacity deficit in 2029, the first year the
14 modeling allowed for selectable resources, indicative of
15 the cost-effectiveness of gas-fired resources . While the
16 Bennett Gas Expansion Project commercial online date is
17 being accelerated to June 1, 2028, as detailed in the
18 Direct Testimony of Mr. Eric Hackett, the project remains a
19 least-risk, least-cost resource necessary for Idaho Power
20 to continue to provide safe, reliable electric service to
21 its customers in 2028 and beyond.
22 Q. What actions has Idaho Power taken to-date to
23 acquire least-cost, least-risk resources to ensure
24 continued safe, reliable electric service in 2028?
e NREL Annual Technology Baseline.
ELLSWORTH, DI 14
Idaho Power Company

1 A. Under Idaho law, Idaho Power has an obligation
2 to provide adequate, efficient, just, and reasonable
3 service on a nondiscriminatory basis to all those that
4 request it within its certificated service area. 9 Further,
5 as indicated by Order No. 35643, Idaho Power is responsible
6 for planning and managing its load and resource portfolio
7 and the Commission expects "the Company to closely monitor
8 its projected capacity needs going forward and to act
9 proactively to ensure a robust RFP process can be
10 completed. "10 Therefore, in order to meet its obligations to
11 reliably serve customers, Idaho Power filed an application
12 with the Public Utility Commission of Oregon ("OPUC") to
13 open an independent evaluator selection docket to oversee
14 the RFP process, " in compliance with the OPUC competitive
15 bidding guidelines, which the Commission directed Idaho
16 Power to follow as well . 12 This competitive solicitation
17 process is discussed in greater detail in the Direct
18 Testimony of Mr. Eric Hackett.
19 Given the significant timeframe related to the RFP
20 process under the competitive bidding guidelines, which
21 spans nearly 18 months and is solely related to the RFP
22 process and excludes the time required for contract
9 Idaho Code §§ 61-302, 61-315, 61-507.
10 Page 13.
11 Docket UM 2255.
12 Order No. 32745. Case No. IPC-E-10-03.
ELLSWORTH, DI 15
Idaho Power Company

1 negotiation and execution, material procurement, and
2 construction, which can add another two to six years to the
3 process, the RFP remained flexible to account for the
4 fluidity of the Company' s annual capacity positions as well
5 as any potential delays in the B2H online date and other
6 projects . Ultimately, the resources selected through the
7 RFP process were based on the recently-identified capacity
8 deficiency of 265 MW in 2028 . Note, this 265 MW deficit is
9 perfect capacity, so it requires Idaho Power to procure
10 more megawatts of nameplate capacity, depending on the ELCC
11 of each resource. Through the Company' s robust competitive
12 bidding process, Idaho Power identified the most cost-
13 effective bids from the RFP evaluation as necessary to fill
14 the capacity deficiencies beginning in 2028, including the
15 Bennett Gas Expansion Project, which will supply Idaho
16 Power with up to 167 MW of generation.
17 IV. CONCLUSION
18 Q. Please summarize your testimony.
19 A. Idaho Power' s most recent system reliability
20 evaluation has identified a capacity deficiency of 265 MW
21 in 2028 . In response to this resource need, the Company has
22 identified the Bennett Gas Expansion Project, a natural gas
23 facility providing up to 167 MW of generation, as a least-
24 cost, least-risk resource for which Idaho Power is
25 requesting the Commission grant a CPCN at this time .
ELLSWORTH, DI 16
Idaho Power Company

1 Q. Does this complete your testimony?
2 A. Yes, it does .
3
ELLSWORTH, DI 17
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 19th day of September 2025, at Boise,
17 Idaho .
18 �✓ ,\
19 Signed:
20 Jared L. Ellsworth
21
ELLSWORTH, DI 18
Idaho Power Company