20260311Direct Ellsworth- Redacted.pdf

RECEIVED
MARCH 10, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY' S APPLICATION FOR ) CASE NO. IPC-E-26-04
CERTIFICATES OF PUBLIC )
CONVENIENCE AND NECESSITY FOR )
THE SOUTH HILLS AND PEREGRINE )
POWER PLANTS 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 South Hills Power Plant, a cost-effective
16 natural gas-fueled facility providing up to 222 megawatts
17 ("MW") of nameplate generation ("South Hills") to meet an
18 identified capacity deficit in 2029, (2) granting a CPCN
19 for the Peregrine Power Plant, a cost-effective natural
20 gas-fueled facility providing 430 MW of nameplate
21 generation ("Peregrine") to meet an identified capacity
22 deficit in 2030, and (3) confirmation of the Company' s
23 application of accrual of Allowance for Funds Used During
24 Construction ("AFUDC") for both the South Hills and the
25 Peregrine plants to coincide with initial procurement
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Idaho Power Company

1 activities for the natural gas-fueled facilities . The South
2 Hills and Peregrine plants are necessary for Idaho Power to
3 continue to provide safe, reliable electric service in 2029
4 and beyond.
5 Q. What is the purpose of your testimony in this
6 matter?
7 A. The purpose of my testimony is to describe the
8 identification of Idaho Power' s need for new resources to
9 meet an identified capacity deficit beginning in 2029 as
10 informed by the Loss of Load Expectation ("LOLE")
11 methodology utilized in the 2023 Integrated Resource Plan
12 ("IRP") , and subsequently further enhanced through system
13 reliability evaluations . I will describe the most recent
14 system reliability and capacity deficit assessments used to
15 inform and identify near-term capacity needs, providing
16 sound analytical support for the acquisition of resources
17 to address the identified near-term capacity needs .
18 Finally, I will discuss the economic analysis performed to
19 evaluate the South Hills and Peregrine projects alongside
20 the remaining feasible projects .
21 Q. You indicated you performed an assessment of
22 system reliability. Is this the same assessment that was
23 performed to support the Company' s request in Case No. IPC-
24 E-25-29, Idaho Power Company's Application for a
25 Certificate of Public Convenience and Necessity for the
ELLSWORTH, DI 3
Idaho Power Company

1 Bennett Gas Expansion Project and an Associated Accounting
2 Order ("Bennett Gas Expansion Project") , the most recent
3 request for approval of a resource procurement, which
4 presented the Company' s 2028 through 2030 capacity needs?
5 A. No. The system reliability assessment
6 performed to support the Company' s request in this case
7 includes refreshed inputs and assumes the resource for
8 which Idaho Power seeks approval in Case No. IPC-E-25-29,
9 the Bennett Gas Expansion Project, is online by June 1,
10 2028 . The most recent system reliability assessment
11 identifies capacity deficits of 236 MW and 352 MW in 2029
12 and 2030, respectively.
13 I . BACKGROUND
14 Q. What is the goal of the IRP?
15 A. The goal of the IRP is to ensure : (1) Idaho
16 Power' s system has sufficient resources to reliably serve
17 customer demand and flexible capacity needs over a 20-year
18 planning period, (2) the selected resource portfolio
19 balances cost and risk, (3) balanced treatment is given to
20 both supply-side resources and demand-side measures, and
21 (4) the public is involved in the planning process in a
22 meaningful way. Idaho Power uses Energy Exemplar' s Aurora' s
23 Long-Term Capacity Expansion ("LTCE") modeling platform to
24 develop portfolios, through the selection of a variety of
25 supply- and demand-side resource options, that are least-
ELLSWORTH, DI 4
Idaho Power Company

1 cost for a variety of alternative future scenarios while
2 meeting reliability criteria. To verify the portfolios meet
3 the Company' s reliability requirements, Idaho Power
4 utilizes the LOLE methodology.
5 Q. Please explain Loss of Load Expectation.
6 A. LOLE is a statistical measure of a system' s
7 resource adequacy, describing the expected number of event-
8 days per year that a system would be unable to meet demand.
9 The LOLE methodology recognizes that the output of variable
10 energy resources, such as wind and solar, change with time,
11 with their hourly output being dependent on a multitude of
12 factors like weather and environmental conditions; it is
13 essential to capture and value that variability.
14 Q. What inputs are derived from the LOLE
15 methodology that are utilized in the Aurora LICE model?
16 A. Idaho Power implements the LOLE methodology
17 through an internally developed Reliability and Capacity
18 Assessment Tool ("RCAT") which is capable of producing
19 inputs such as a Planning Reserve Margin ("PRM") and
20 resource Effective Load Carrying Capability ("ELCC")
21 values . The PRM can be defined as the percentage of
22 expected capacity resources above forecasted peak demand.
23 The ELCC calculation is a reliability-based metric used to
24 assess the capacity contribution of variable and energy-
25 limited resources . The PRM and ELCC values that are
ELLSWORTH, DI 5
Idaho Power Company

1 calculated using the LOLE methodology are a direct input to
2 the Aurora LTCE model .
3 Q. How are the PRM and ELCC values validated
4 between models?
5 A. Because the Aurora LTCE model and the RCAT are
6 two separate tools, a translation is required between the
7 probabilistic LOLE analysis performed in the RCAT and the
8 portfolios produced by the Aurora LTCE model . First, PRM
9 and ELCC values are calculated using the LOLE methodology,
10 which serve as direct inputs to the Aurora LICE model .
11 After Aurora solves for and produces portfolios, select
12 resource buildouts and their corresponding data are
13 analyzed with the LOLE methodology and tested to ensure
14 they meet the pre-designated reliability hurdle through the
15 calculation of annual capacity positions . It is critical
16 when comparing future resource portfolios that each plan
17 achieves at least a base reliability threshold. Figure 1
18 below illustrates the model calibration process .
19 Figure 1 . Idaho Power' s Reliability Flowchart
ELLSWORTH, DI 6
Idaho Power Company

�► T
Geoegatbn ELCC
Eff—w toad C,,ryl g Calwdlny
RCAT LOLE LTCE
RelwbdhtyB Gpaclty toss of toad EapecfaTMn Long TMm CaWgy Eapanvon LOLE Portfolio
Z �^�^LTA J J Reliability Hurdle
IRP
A MAIIAN AURORA
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PRM MR
load
Manning Reserve M"n � c�.raly IbMllgll
1
2 Q. You indicated that RCAT and Aurora serve
3 different purposes in Idaho Power' s planning process, how
4 is the data exchanged between the two models translated
5 and aligned?
6 A. To better assess the dynamic diversity benefit
7 caused by a changing resource mix, and to synchronize the
8 models, the Company applies a feedback process between the
9 Aurora LTCE model and the RCAT. Under the feedback process,
10 the annual capacity positions for an Aurora LTCE main case
11 portfolio buildout are calculated using the RCAT. Once the
12 annual capacity positions are known, the PRM in the Aurora
13 LTCE model is modified in years that have significant
14 resource changes so that both models identify a similar
15 capacity position. The feedback loop continues until the
16 main case portfolio is reliable as measured by the annual
17 capacity position to meet the LOLE threshold. The resulting
18 Aurora-produced optimized main case portfolios provide the
ELLSWORTH, DI 7
Idaho Power Company

1 least-cost, least-risk future resource buildouts .
2 II . ANNUAL CAPACITY POSITIONS AND THE IRP
3 Q. Company Witness Mr. Hackett indicates the
4 annual capacity positions developed to inform the 2023 IRP
5 were the basis for the commencement of the competitive
6 solicitation for the acquisition of resources, conducted
7 through the issuance of Idaho Power' s 2028 All-Source
8 Request for Proposals (RFP) for Peak Capacity and Energy
9 Resources ("RFP") , which solicited bids in 2028 and beyond.
10 What were the annual capacity positions identified in the
11 2023 IRP beginning in 2029?
12 A. The 2023 IRP identified incremental capacity
13 needs of 142 MW in 2029 and 369 MW in 2030, growing to over
14 1, 150 MW by 2038 . 1 The 2023 IRP Preferred Portfolio included
15 the addition of large quantities of cost-effective clean
16 resources including solar, wind, battery storage, energy
17 efficiency, peaking hydrogen, incremental demand response
18 and geothermal .
19 Q. How did the annual capacity positions change
20 with the 2025 IRP?
21 A. The 2025 IRP identified increased incremental
22 capacity needs earlier in the planning period, 192 MW in
23 2029 and 380 MW in 2030, with the total shortfall exceeding
1 Idaho Power 2023 IRP at 174 (Table 11.15) .
ELLSWORTH, DI 8
Idaho Power Company

1 1, 000 MW by 2040 .2 While the 2025 IRP Preferred Portfolio
2 included solar, storage, wind, energy efficiency and
3 incremental demand response, it also included 550 MW of
4 incremental natural gas as cost-effective resource
5 additions .
6 Q. What is driving the need for the addition of
7 natural gas resources?
8 A. Idaho Power is in a period of unprecedented
9 demand growth that is expected to continue over the next
10 several years, including demand growth from large load
11 customers whose load is flat both seasonally and diurnally.
12 The Company also continues to experience significant
13 interest from prospective industrial customers . To meet
14 growing customer demands, the 2025 IRP shows the need for
15 the combination of flexible, dispatchable resources . At the
16 same time, Idaho Power finds itself in an era of heightened
17 uncertainty where numerous probable events could occur that
18 would materially change the resources selected in the near-
19 term action plan of the 2025 IRP. Specifically, there is a
20 real possibility for higher than expected load growth and
21 changes in federal and state policy that must be closely
22 monitored throughout the planning and procurement
23 processes .
2 Idaho Power 2025 IRP at 142 (Table 11.14) .
ELLSWORTH, DI 9
Idaho Power Company

1 In addition, uncertainty exists around the eventual
2 fate of the recent changes to the 111 (d) rule regarding
3 carbon emissions for existing and new resources . The 2025
4 IRP studied both large load and 111 (d) rule reversion
5 scenarios and the combinations thereof, which, ultimately
6 supported the pursuit of generation resources in 2029 and
7 2030 to meet forecasted needs, identified in the Preferred
8 Portfolio as natural gas, wind, solar and storage .
9 Q. Did the 2025 IRP consider the volatility of
10 natural gas prices prior to determination of the Preferred
11 Portfolio?
12 A. Yes . The Company tested portfolios under
13 multiple gas price variations, from different sources and
14 in high and low-price scenarios . In addition, modeling of
15 the 2025 IRP included a robust risk analysis, including the
16 stochastic analyses that help quantify the sensitivity and
17 risk associated with variables over which Idaho Power has
18 little or no control, including natural gas prices .
19 Finally, with the qualitative risk analysis, the Company
20 considered fuel supply risks that incorporated potential
21 impacts to fuel supply infrastructure that can be
22 susceptible to outages from weather, mechanical failures,
23 etc . , including that of natural gas infrastructure . Even
24 considering the natural gas price volatility, the analysis
ELLSWORTH, DI 10
Idaho Power Company

I and testing performed as part of the 2025 IRP showed the
2 clear need for firm flexible new natural gas resources .
3 Q. What years were new natural gas resources
4 identified as cost-effective resource selections in the
5 2025 IRP Preferred Portfolio?
6 A. The Preferred Portfolio included 150 MW of new
7 gas resources in 2029, 300 MW in 2030, 50 MW in 2041, and
8 50 MW of new natural gas resources in 2043 as cost-
9 effective resource additions . As mentioned by Company
10 Witness Mr. Eric Hackett, it was following this
11 identification that Idaho Power began investigating
12 alternative gas resource solutions that could economically
13 meet the Company' s resource needs, ultimately identifying
14 the South Hills and Peregrine natural gas-fueled facilities
15 to be considered in the competitive procurement process .
16 This conclusion was further validated by Idaho Power' s most
17 recent assessment of system reliability and the annual
18 capacity deficits .
19 III . SYSTEM RELIABILITY ASSESSMENT
20 Q. The Company provided a system reliability
21 assessment with the request for a CPCN for the Bennett Gas
22 Expansion Project identifying capacity needs during the
23 2028 through 2030 time period. Why was the system
24 reliability assessment updated?
ELLSWORTH, DI 11
Idaho Power Company

1 A. Idaho Power recognizes that during the near-
2 term resource decision-making phase, the annual capacity
3 positions can be very fluid. In addition, in the face of
4 growing loads, the Company closely monitors resource needs
5 and responds with added urgency, as evidenced by Idaho
6 Power' s consecutive requests to acquire resources to be
7 online in 2023, 2024, 2025, 2026, 2027, and 2028 . 3 The most
8 recent system reliability assessment has identified a
9 capacity deficit of 236 MW in 2029, increasing to 352 MW in
10 2030 .
11 Q. What drove the changes to the annual capacity
12 positions in the most recent system reliability assessment?
13 A. Any time the system reliability evaluation is
14 performed, Idaho Power includes the most up-to-date load
15 and resource inputs . The load forecast, which utilizes the
16 70th percentile peak load forecast for all months in the
17 RCAT, has been updated and therefore has been incorporated
18 in the system reliability evaluation performed for this
19 case . In addition, following the recommendation by
20 Commission Staff ("Staff") in their comments on the 2025
21 IRP, 4 the Company modeled a delay in the commercial
3 Case Nos. IPC-E-22-06, IPC-E-22-13, IPC-E-22-29, IPC-E-23-05, IPC-E-23-20,
IPC-E-24-12, IPC-E-24-16, IPC-E-24-42, IPC-E-24-45, IPC-E-24-46, IPC-E-25-10,
IPC-E-25-27 and IPC-E-25-29.
4 Case No. IPC-E-25-23, Staff Comments, pages 5-6.
ELLSWORTH, DI 12
Idaho Power Company

I operation date of the Southwest Intertie Project - North
2 ("SWIP North") .
3 Q. What is your understanding of Staff' s
4 recommendation to assume a delay in the commercial
5 operation date of SWIP-North for modeling purposes?
6 A. In Comments, Staff noted that the construction
7 of new transmission lines can be more vulnerable to legal
8 delays related to permitting and right-of-way than other
9 types of construction projects, citing the Boardman-to-
10 Hemingway transmission line, which could easily extend the
11 online date of a transmission project by months or years .
12 Noting that it is easier to adjust the online date of a
13 transmission resource to earlier than planned rather than a
14 delayed resource, Staff therefore recommended Idaho Power
15 consider adding up to 12 months to the commercial operation
16 date for modeling purposes . Though one right-of-way is
17 outstanding, and the Company believes receipt of the notice
18 to proceed will occur with adequate time, in the most
19 recent system reliability assessment Idaho Power modeled a
20 shift of the SWIP-North November 2028 commercial operation
21 date to May 2029 to better align with Staff' s modeling
22 recommendation.
23 Q. How does the addition of the proposed South
24 Hills and Peregrine projects impact the capacity
25 deficiencies in 2029 and 2030?
ELLSWORTH, DI 13
Idaho Power Company

1 A. Including the most up-to-date load and
2 resource inputs and market purchase assumptions, and
3 assuming all contracted 2026 and 2027 projects and the
4 Bennett Gas Expansion Project reach commercial operation
5 on time, the addition of the South Hills and Peregrine
6 plants would reduce the capacity deficits of 236 MW in
7 2029 and 352 MW in 2030, to a capacity deficit of 98 MW in
8 2029 and provide capacity length of 125 MW in 2030 . The
9 addition of the South Hills and Peregrine projects will
10 support continued safe, reliable operations in 2029 and
11 beyond.
12 Q. How does the addition of the South Hills and
13 Peregrine plants impact the annual capacity positions
14 beyond 2029?
15 A. In addition to helping meet the capacity
16 deficit of 236 MW in 2029 and 352 MW in 2030, 5 the South
17 Hills and Peregrine plants will reduce the incremental
18 capacity needs beyond 2029 as shown in Table 1 below.
19 Table 1 . Annual Capacity Position with the South Hills and
20 Peregrine Plants 2029-2032
Year Most Recent Most Recent Capacity
Capacity Position Position w/South Hills
and Peregrine Plants6
2029 (236) MW (98) MW
5 Because both South Hills and Peregrine have mid-year in-service dates, the
ELCC of the project is lower in the first year as compared to future years. By
2031, the full ELCC of both resources, approximately 500 MW, is recognized.
6 Assumes a SWIP-North online date of May 2029. Assumes the Crimson Orchard
Project and Blacks Creek 400 MW solar online June 2027.
ELLSWORTH, DI 14
Idaho Power Company

2030 (352) MW 125 MW
2031 (553) MW (60) MW
2032 (690) MW (196) MW
1
2 A delay of resource procurements in 2029 will only
3 exacerbate the capacity deficiencies in 2029 and beyond.
4 Further, based on the real possibility for additional load
5 growth in Idaho Power' s service area, the Company' s
6 capacity positions beyond 2029 could very likely grow to
7 even greater deficits .
8 Q. Does the 125 MW length in 2030 indicate a
9 capacity surplus for the Company?
10 A. No, the capacity positions are calculated
11 assuming all firm transmission imports are available 24
12 hours a day, seven days a week, including transmission that
13 does not have a resource behind it. During the operations
14 horizon, the Company evaluates how many purchases are
15 required to maintain reliability and avoid over-
16 procurement. An identified position of capacity length from
17 the RCAT gives Idaho Power flexibility to procure less
18 resources in the market and maintain reliability but it
19 does not represent surplus capacity that can be sold to the
20 market .
21 Q. Has Idaho Power evaluated the impact to the
22 capacity positions should the additional load materialize?
ELLSWORTH, DI 15
Idaho Power Company

1 A. Yes . Assuming only the addition of
2 ' in the load forecast, which is anticipated to come online
3 in 2029, and ramping to full load in 2032, the capacity
4 deficiencies grow considerably. Table 2 presents the
5 incremental capacity needs beginning in 2029, inclusive of
6 the South Hills and Peregrine plants, with and without the
7 load.
8 Table 2 . Annual Capacity Position with the South Hills and
9 Peregrine Plants and Additional Loads 2029-2032
Year Most Recent Capacity Most Recent Capacity
Position w/South Hills Position w/South Hills
and Peregrine Plants and Peregrine Plants
and
2029 (98) MW (191) MW
2030 125 MW (114) MW
2031 (60) MW (413) MW
2032 (196) MW (661) MW
10
11 As can be seen in Table 1, the addition of the South Hills
12 and Peregrine plants is necessary to position Idaho Power
13 to continue to provide safe, reliable electric service in
14 2029 and beyond. That identified need is further bolstered
15 under the scenario presented in Table 2 .
16 IV. SOUTH HILLS AND PEREGRINE COST-EFFECTIVENESS EVALUATION
17 Q. Did the Company evaluate the cost-
18 effectiveness of the South Hills and Peregrine plants
19 following their identification as resource alternatives
ELLSWORTH, DI 16
Idaho Power Company

1 that are able to contribute to Idaho Power' s capacity
2 needs?
3 A. Yes . After identification of the South Hills
4 and Peregrine gas-fired plants as potential resource
5 additions, Company Witness Mr. Eric Hackett requested the
6 Bid Evaluation Team evaluate the cost-effectiveness of the
7 projects as compared to all remaining feasible 2029 and
8 later final shortlist projects ("feasible 2029 Projects")
9 received through the RFP solicitation. This evaluation was
10 performed in a manner consistent with the analyses
11 performed to evaluate the 2028 bids, commencing with
12 Aurora' s LTCE modeling. Through this process, portfolios
13 are developed to meet the identified capacity needs through
14 the selection of resource options that are least-cost for a
15 variety of alternative future scenarios while meeting
16 reliability criteria.
17 Q. What resource options were available as part
18 of this evaluation?
19 A. As part of this evaluation, for 2029, Aurora
20 could either select the South Hills plant or any
21 combination of the feasible 2029 Projects, and for 2030,
22 Aurora could select either Peregrine or any combination of
23 the feasible 2029 projects . The feasible 2029 projects
24 included wind, solar and battery storage projects .
ELLSWORTH, DI 17
Idaho Power Company

1 Once the portfolios are created, Idaho Power uses
2 Aurora to determine the operating costs of the portfolios
3 for the 20-year planning timeframe. Through this process,
4 Aurora performs hourly simulations to compare how
5 portfolios perform throughout the planning timeframe . These
6 simulations include the costs associated with adding the
7 new generation resources and optimally dispatching the
8 resources to meet the constraints within the model . The
9 resulting portfolio costs are calculated as the net present
10 value ("NPV") of the 20-year stream of annualized costs,
11 fixed and variable, for each portfolio.
12 Q. What modeling assumptions were utilized in
13 Aurora for the evaluation?
14 A. The modeling assumptions utilized in Aurora
15 were consistent with those utilized in the 2025 IRP. In
16 addition, the resource characteristics and capital costs of
17 the feasible 2029 Projects, the South Hills and Peregrine
18 plants were Aurora inputs .
19 Q. What were the results of the evaluation?
20 A. With respect to South Hills, the Company
21 evaluated the following 20-year optimized portfolios : (1)
22 excluding South Hills in 2029, and including the most
23 economically feasible 2029 Projects, and (2) including
24 South Hills in 2029, and excluding other 2029 Projects .
25 Each portfolio was optimized for the other years in the 20-
ELLSWORTH, DI 18
Idaho Power Company

1 year horizon. The intention of this analysis is to
2 specifically evaluate South Hills compared to feasible
3 alternatives in 2029 . The results indicate that the NPV of
4 the portfolio that includes South Hills in 2029 is $-
5 — more cost-effective than the best feasible
6 alternative.
7 For 2030 resources, the Company took a similar
8 approach to evaluate the Peregrine project. The Company
9 evaluated optimized 20-year portfolios : (1) excluding
10 Peregrine in 2030, and including the most economically
11 feasible 2029 Projects, with a 2030 commercial operation
12 date, and (2) including Peregrine in 2030, and excluding
13 other projects . Each portfolio was optimized for the other
14 years in the 20-year horizon. Thus, Peregrine was compared
15 to feasible alternatives in 2030 . The results indicate that
16 the NPV of the portfolio that includes Peregrine is $-
17 — more cost-effective than the best feasible
18 alternative . As efficient, flexible, dispatchable
19 resources, South Hills and Peregrine offer least-cost,
20 least-risk resource alternatives to meeting the Company' s
21 identified capacity deficiencies .
22 Q. You indicated the annual capacity positions
23 could grow to even larger deficits with the addition of
24 additional load growth. Did Idaho Power consider if
ELLSWORTH, DI 19
Idaho Power Company

I additional load would change the economics of the natural
2 gas resources?
3 A. Yes . The Company continues to have significant
4 interest from prospective industrial customers . As such,
5 the 2025 IRP studied multiple additional large load
6 scenarios with both 300 MW and 500 MW cases . The results
7 indicated even larger quantities of natural gas resources
8 as cost-effective resource additions under additional large
9 load futures . As evidenced by the annual capacity positions
10 presented earlier in my testimony, the South Hills and
11 Peregrine plants help ensure the Company has sufficient
12 resources and positions Idaho Power to reliably serve
13 customer demand.
14 V. MEETING THE CAPACITY DEFICIENCY
15 Q. Do you believe there is sufficient support for
16 the procurement of the South Hills and Peregrine projects?
17 A. Yes . The resource acquisitions presented in
18 this case were pursued and procured as a least-cost,
19 least-risk method of meeting the capacity deficits first
20 identified in the Company' s 2023 IRP, again in the 2025
21 IRP, and subsequently with the results of the updated
22 system reliability evaluation. The fluidity of the
23 capacity deficit period, continued high load growth, and
24 supply chain disruptions and delays further support the
25 resource procurements which are necessary to adequately
ELLSWORTH, DI 20
Idaho Power Company

1 address 2029 and 2030 capacity deficits .
2 Q. What actions has Idaho Power taken to acquire
3 least-cost, least-risk resources to ensure continued safe,
4 reliable electric service beginning in 2029?
5 A. Under Idaho law, Idaho Power has an obligation
6 to provide adequate, efficient, just, and reasonable
7 service on a nondiscriminatory basis to all those that
8 request it within its certificated service area. ? Further,
9 as indicated by Order No. 35643, Idaho Power is responsible
10 for planning and managing its load and resource portfolio
11 and the Commission expects "the Company to closely monitor
12 its projected capacity needs going forward and to act
13 proactively to ensure a robust RFP process can be
14 completed. "8 Therefore, in order to meet its obligations to
15 reliably serve customers, as discussed in greater detail in
16 the Direct Testimony of Mr. Eric Hackett, Idaho Power filed
17 an application with the Public Utility Commission of Oregon
18 ("OPUC") to open an independent evaluator selection docket
19 to oversee the RFP process, 9 in compliance with the OPUC
20 competitive bidding guidelines, which the Commission
21 directed Idaho Power to follow as well . 10
Idaho Code §§ 61-302, 61-315, 61-507.
8 Page 13.
9 Docket UM 2255.
io Order No. 32745. Case No. IPC-E-10-03.
ELLSWORTH, DI 21
Idaho Power Company

1 Given the significant timeframe related to the RFP
2 process under the competitive bidding guidelines, which
3 spans nearly 18 months and is solely related to the RFP
4 process and excludes the time required for contract
5 negotiation and execution, material procurement, and
6 construction, which can add another two to six years to the
7 process, the RFP remained flexible to account for the
8 fluidity of the Company' s annual capacity positions as well
9 as any potential delays in the SWIP-North online date and
10 other projects . Ultimately, the alternative resources
11 selected were based on the recently-identified capacity
12 deficiency of 236 MW in 2029 and 352 MW in 2030 . Note,
13 these deficits are perfect capacity, so they require Idaho
14 Power to procure more megawatts of nameplate capacity,
15 depending on the ELCC of each resource. Through the
16 Company' s robust competitive bidding process, Idaho Power
17 identified the cost-effective resource alternatives as
18 necessary to fill the capacity deficiencies beginning in
19 2029, including the South Hills and Peregrine plants, which
20 will supply Idaho Power with 222 MW and 430 MW of nameplate
21 generation, respectively.
22 VI . CONCLUSION
23 Q. Please summarize your testimony.
24 A. Idaho Power' s most recent system reliability
25 evaluation has identified a capacity deficiency of 236 MW
ELLSWORTH, DI 22
Idaho Power Company

1 in 2029, increasing to 352 MW in 2030 . In response to this
2 resource need, the Company has identified the South Hills
3 plant, a natural gas facility providing up to 222 MW of
4 generation, and the Peregrine plant, a natural gas facility
5 providing 430 MW of nameplate generation, as a least-cost,
6 least-risk resources for which Idaho Power is requesting
7 the Commission grant a CPCN at this time .
8 Q. Does this complete your testimony?
9 A. Yes, it does .
ELLSWORTH, DI 23
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 loth day of March 2026, at Boise, Idaho.
17
18 �✓ ,\
19 Signed:
ELLSWORTH, DI 24
Idaho Power Company