20260311Direct Richins - Redacted.pdf

RECEIVED
MARCH 11, 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
ADAM RICHINS

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 Adam Richins . My business address
5 is 1221 West Idaho Street, Boise, Idaho 83702 . I am
6 employed by Idaho Power as Executive Vice President and
7 Chief Operating Officer.
8 Q. Please describe your educational background.
9 A. I graduated from the University of Puget
10 Sound with a Bachelor of Science degree in Mathematics and
11 from Columbia University with a Bachelor of Science degree
12 in Civil Engineering, Magna Cum Laude. Thereafter, I earned
13 my law degree from the University of Washington with high
14 honors . In 2016, I graduated from Harvard Business School' s
15 Advanced Management Program.
16 Q. Please describe your work experience with
17 Idaho Power.
18 A. From 2010 to 2013 I was employed by Idaho
19 Power as Senior Counsel in the Legal Department. After that
20 role, I served as General Manager of Customer Operations
21 Engineering and Construction. In 2017, I was promoted to
22 Vice President of Customer Operations and Business
23 Development . In this role, I oversaw teams dedicated to
24 customer operations, customer satisfaction, and supporting
25 the Company' s brand. I was promoted to Senior Vice
RICHINS, DI 2
Idaho Power Company

1 President and Chief Operating Officer of Idaho Power in
2 2019, which became Executive Vice President and Chief
3 Operating Officer in 2026, where I have responsibility over
4 operations departments that include Idaho Power' s
5 generation, transmission, and distribution resources;
6 customer operations; planning, engineering, and
7 construction; business innovation; information systems;
8 safety; environmental; and training.
9 Q. What is the Company' s request in this case?
10 A. Idaho Power is requesting the Idaho Public
11 Utilities Commission ("Commission") issue an order (1)
12 granting a Certificate of Public Convenience and Necessity
13 ("CPCN") for the South Hills Power Plant, a cost-effective
14 natural gas-fueled facility providing up to 222 megawatts
15 ("MW") of nameplate generation ("South Hills") to meet an
16 identified capacity deficit in 2029, (2) granting a CPCN
17 for the Peregrine Power Plant, a cost-effective natural
18 gas-fueled facility providing 430 MW of nameplate
19 generation ("Peregrine") to meet an identified capacity
20 deficit in 2030, and (3) confirmation of the Company' s
21 application of accrual of Allowance for Funds Used During
22 Construction ("AFUDC") for both the South Hills and the
23 Peregrine plants to coincide with initial procurement
24 activities for the natural gas-fueled facilities . The South
25 Hills and Peregrine plants are necessary for Idaho Power to
RICHINS, DI 3
Idaho Power Company

1 continue to provide safe, reliable electric service in 2029
2 and beyond.
3 Q. What is the purpose of your testimony in
4 this matter?
5 A. The purpose of my testimony is to provide an
6 overview of Idaho Power' s resource procurement activities
7 and the current challenges of bringing resources online
8 timely as a result of the Company' s load growth across
9 multiple customer sectors at a time of rising costs, supply
10 chain constraints, permitting obstacles, and constrained
11 system capacity. I will discuss the timelines for
12 procurement activities associated with natural gas
13 resources that Idaho Power has been monitoring, ultimately
14 requiring the Company to take immediate action following
15 the identification of the South Hills and Peregrine natural
16 gas-fueled plants as least-cost, least-risk resources .
17 Finally, I will describe the natural gas transport and
18 supply landscape in Southern Idaho and the Company' s
19 efforts to secure additional incremental natural gas
20 transport capacity for the South Hills and Peregrine plants
21 as necessary for Idaho Power to continue to provide safe,
22 reliable electric service beginning in 2029 and beyond.
23 Q. Have you prepared any exhibits?
24 A. Yes . Exhibit No . 4 presents the Company' s
25 existing natural gas transport and storage map along the
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Idaho Power Company

1 Northwest Pipeline. Confidential Exhibit No. 5 illustrates
2 the proposed route of the
3 I . RESOURCE PROCUREMENT ACTIVITIES
4 Q. What is driving Idaho Power' s continuous
5 resource procurement activities?
6 A. As described in the Direct Testimony of
7 Company Witnesses Mr. Jared Ellsworth and Mr. Eric Hackett,
8 the Company' s annual capacity positions developed to inform
9 the 2023 Integrated Resource Plan ("IRP") identified
10 incremental deficits in 2028 that continued to grow through
11 2038 . Despite considerable investment and expansion in
12 generation resources in recent years, Idaho Power' s system
13 today is fully utilized by current customers, and the
14 Company continues to experience sustained customer growth.
15 Idaho Power must ensure it has sufficient resources
16 to fulfill its obligation to reliably and safely serve
17 customers and therefore began the competitive solicitation
18 for the acquisition of resources, conducted through the
19 issuance of a Request for Proposals ("RFP") . The all-source
20 RFP sought proposals for a combination of capacity and
21 energy resources that provide a minimum of approximately
22 138 MW of incremental peak capacity and 555 MW of supply-
23 side resource additions in 2028 and beyond; specifically,
24 bids that could meet an April 1, 2028, commercial operation
25 date ("2028 Bids") and bids with a commercial operation
RICHINS, DI 5
Idaho Power Company

1 date beyond April 1, 2028 ("2029 and Beyond Bids") .
2 Although Idaho Power has promptly initiated the competitive
3 solicitation process upon identification of the annual
4 capacity deficiencies, first in the 2021 IRP for 2023
5 through 2027 resources, and subsequently with the 2023 IRP
6 for 2028 and beyond resources, many of the resources
7 selected through the extensive process are not able to come
8 online as expected.
9 Q. What has been driving the delay in bringing
10 the new resources online?
11 A. The Company' s load growth across multiple
12 customer sectors, combined with rising costs, supply chain
13 constraints, permitting obstacles, and constrained system
14 capacity, is posing significant challenges for Idaho Power
15 and third-party developers in bringing resources online in
16 time to meet identified capacity deficiencies . More
17 recently, these challenges are exacerbated by the lack of
18 2029 and Beyond Bids received as well as the limited
19 diversity of dispatchable resources .
20 Q. Company Witness Mr. Hackett describes the
21 resources selected to meet the identified 2029 and 2030
22 capacity deficiencies as a result of the issuance of the
23 RFP. Did Idaho Power identify dispatchable resources that
24 can be brought online in time to meet the capacity
25 deficiencies?
RICHINS, DI 6
Idaho Power Company

1 A. Yes . To meet the 2029 capacity deficit, Idaho
2 Power identified the South Hills natural gas-fueled plant,
3 the 2029 and Beyond Bid benchmark bid, originally named the
4 Milner project, as a least-cost, least-risk resource
5 alternative. Regarding the 2030 and beyond deficits, the
6 Company had already solicited bids for resources to come
7 online in 2029 and beyond and received no viable bids to
8 reasonably address the identified 2030 and beyond capacity
9 shortfalls . As a result, the Company was required to take
10 immediate action to evaluate the procurement of alternative
11 resources to fill the identified capacity deficiencies,
12 ultimately leading to the identification of the Peregrine
13 natural gas-fueled plant as a least-cost, least-risk
14 resource. Peregrine was necessary and required to timely
15 meet the Company' s resource needs and continue to provide
16 reliable and adequate service to Idaho Power' s customers .
17 Due to supply chain timelines, the Company was required to
18 financially commit to procure these two necessary, cost-
19 effective capacity resources prior to this CPCN request to
20 preserve an opportunity to have the resources online by the
21 required need dates .
22 II . NATURAL GAS RESOURCE PROCUREMENT
23 Q. What are current timelines for procurement
24 activities of natural gas resources that required the
25 Company to take immediate action?
RICHINS, DI 7
Idaho Power Company

1 A. In April 2024, Idaho Power hired a consultant
2 to support a technical and commercial market review on
3 multiple types of gas generation technology. Following the
4 review, Idaho Power monitored lead times in the industry to
5 stay apprised on how manufacturing lead times were impacted
6 by externalities in the market for new gas generation
7 equipment. At the time, lead times as developed through the
8 market review were
The timelines
10 significantly changed over the next year, when the Internal
11 Bid Team was developing its bid for the Bennett Gas
12 Expansion Project, due to an increased demand for
13 reciprocating engines and were extended by as many as 16
14 additional months to
15 As a result, the Company continued monitoring the
16 lead times with Wartsila, the engine supplier for the
17 Bennett Gas Expansion Project, to ensure viability for
18 South Hills . In November 2025, just five months after
19 securing reciprocating engines for the Bennett Gas
20 Expansion Project, Wartsila notified Idaho Power that the
21 existing lead times had increased to 30 months due to
22 demand for the engines . The rapid escalation in lead times
23 required the Company promptly secure slot reservations to
1 Idaho Power considers the technical and commercial market review data as
proprietary information as the Company must compete with other bidders on
projects.
RICHINS, DI 8
Idaho Power Company

1 ensure delivery in time to meet the required June 1, 2029,
2 commercial operation date. Idaho Power secured reservation
3 slots for 12 reciprocating engines in December 2025 . All
4 reservation slots for 2029 commercial operation have been
5 filled and as discussed in Company Witness Mr. Hackett' s
6 testimony, all reservation slots for 2030 have been filled
7 as well . Idaho Power' s prudent actions have ensured the
8 Company will be able to bring a resource online in time for
9 a June 1, 2029, commercial operation date.
10 Q. Is there a high demand for natural gas
11 turbines as well, increasing the lead times associated with
12 Peregrine?
13 A. Yes . Due, in part, to the shift to more
14 dispatchable energy sources, increased demand for energy-
15 intensive data centers, increased demand for onshoring of
16 manufacturing, and the rise in electricity demand in
17 general across the world, the need for turbines has
18 increased significantly, which in turn negatively impacted
19 lead times . When Idaho Power began evaluating the potential
20 gas resources in early 2025, the Company was informed by
21 the three major natural gas turbine suppliers that there
22 were no combined cycle turbines available to meet a June 1,
23 2030, in-service date . Several large entities had bought
24 the remaining inventory.
25 Q. Were there simple cycle combustion turbines
RICHINS, DI 9
Idaho Power Company

1 available?
2 A. In terms of simple cycle turbine technologies,
3 one of the three turbine manufacturers informed Idaho Power
4 that they no longer had a production slot available to
5 ensure a June 1, 2030, commercial operation date . The
6 Company was informed by the two remaining suppliers that
7 Idaho Power needed to move fast to secure a turbine
8 manufacturing slot necessary to meet a June 1, 2030, in-
9 service date. Subsequently, a second supplier informed
10 Idaho Power that they no longer had the turbine the Company
11 needed available to meet the necessary timeline .
12 As such, following a competitive solicitation
13 process, in May 2025, the Company executed a reservation
14 agreement with anticipated delivery of a turbine in
15 November 2028 . By the time the sales contract was executed
16 in December 2025, that delivery date had shifted to March
17 2029, resulting in a nearly four-year lead time for the
18 procurement of turbines . If Idaho Power had not secured the
19 reservation slot when it did, a turbine delivery in time to
20 meet a June 1, 2030, commercial operation date would not
21 have been possible. The Company' s diligent efforts
22 monitoring timelines in a very restrictive procurement
23 environment have resulted in the identification of two
24 least-cost, least-risk, natural gas-fueled resource
25 alternatives, South Hills and Peregrine, that are necessary
RICHINS, DI 10
Idaho Power Company

1 to ensure Idaho Power can continue to provide safe,
2 reliable electric service beginning in 2029 and beyond.
3 III . GAS PIPELINE CAPACITY AND SUPPLY
4 Q. What is the natural gas transport and supply
5 landscape in Southern Idaho?
6 A. Currently, the Northwest Pipeline is the sole
7 provider of gas transport to Idaho. Owned by the Williams
8 Companies ("Williams") , the Northwest Pipeline is a 4, 000-
9 mile bi-directional natural gas transmission system
10 crossing the states of Washington, Oregon, Idaho, Wyoming,
11 Utah and Colorado. The Northwest Pipeline' s bi-directional
12 system provides access to British Columbia, Alberta, Rocky
13 Mountain and San Juan Basin gas supplies, which the Company
14 relies upon due to limited natural gas production within
15 the southern Idaho corridor. Right now, 100 percent of the
16 firm transport capacity is contracted for and there is no
17 firm delivery available to the southern Idaho corridor.
18 Q. How is gas supplied to fuel Idaho Power' s
19 existing natural gas power plants?
20 A. The Company is currently receiving fuel from
21 the Stanfield, Sumas, and Rockies market hubs . For the
22 Idaho gas facilities, approximately 80 percent of the
23 natural gas comes from the Stanfield hub and the remaining
24 approximately 20 percent comes from the Sumas market. Idaho
25 Power receives natural gas from the Rockies market hub to
RICHINS, DI 11
Idaho Power Company

1 fuel the gas units at the Jim Bridger and North Valmy power
2 plants . In addition, the Company retains storage at Spire
3 and Jackson Prairie to balance the fueling of Idaho Power' s
4 natural gas facilities . Exhibit No. 4 to my testimony
5 presents the Company' s existing natural gas transport and
6 storage map along the Northwest Pipeline.
7 Q. Does Idaho Power have firm capacity on the
8 Northwest Pipeline?
9 A. Prior to 2024, Idaho Power relied on some non-
10 firm pipeline capacity on the Northwest Pipeline to serve
11 natural gas facilities . However, the western energy markets
12 are undergoing a paradigm shift resulting in increased
13 volatility in the natural gas market attributable to coal
14 to gas conversions, renewables penetration and increasing
15 power demand, driving an increase in demand for gas-fired
16 generationz resulting in a tightened gas transport market.
17 This, coupled with the Company' s increased use of natural
18 gas the past couple of years, led Idaho Power to secure
19 additional incremental firm capacity, purchasing the last
20 remaining firm capacity on the Williams Northwest Pipeline
21 in September 2024 to support hedging and operational
22 practices .
2 Williams Northwest Pipeline Shipper Advisory Board Meeting Fall 2025
RICHINS, DI 12
Idaho Power Company

1 Q. Will this existing capacity on the Williams
2 Northwest Pipeline provide enough capacity to fuel and
3 hedge the South Hills and Peregrine gas facilities?
4 A. Not at certain times of the year. With the
5 tightening of the gas transport market, and upon
6 investigation by the Internal Bid Team of potential natural
7 gas resource options for bidding into the 2028 RFP, Idaho
8 Power contacted Williams
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RICHINS, DI 13
Idaho Power Company

1 Q.
2
3 A.
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14 Q. What is an Open Season and Reverse Open
15 Season?
16 A. An Open Season is a procedure whereby Williams
17 announces to prospective shippers of the potential for new
18 primary firm transportation service under the proposed
19 project, the Rockies Columbia Connector project in this
20 case, soliciting interest in any portion of the new primary
21 firm transportation. A Reverse Open Season is a request by
22 Williams soliciting offers for the permanent relinquishment
23 of primary firm transportation service on the Northwest' s
24 system in connection with the project. Any interested
25 parties submit a Non-Binding Open Season Bid Sheet, or Non-
RICHINS, DI 14
Idaho Power Company

I Binding Reverse Open Season Bid Sheet, expressing interest
2 in or relinquishment of, firm transportation service .
3 After the close of the Open Season, all non-binding
4 bids are evaluated and aggregated, establishing the broader
5 market interest in order to right size the project,
6 ultimately determining whether binding precedent agreements
7 for the project should be executed. The total capacity
8 awarded after the Open Season and the associated pricing is
9 based on the facilities required to provide the requested
10 service and reflected in the binding precedent agreements .
11 Q. Has Williams initiated the Open Season and
12 Reverse Open Season for the Rockies Columbia Connector
13 project?
14 A. Yes . The Open Season and Reverse Open Season
15 for the Rockies Columbia Connector project commenced on
16 June 25, 2025, and ended August 6, 2025 .
17 Q. Did Idaho Power submit a Non-Binding Open
18 Season Bid Sheet for the Rockies Columbia Connector
19 project?
20 A. Yes . Recognizing the impact the recent
21 tightening of the gas transport market has had as well as
22 identification in the 2025 IRP Preferred Portfolio of the
23 need for an additional 450 MW of natural gas resources by
24 2030 and hedging requirement needs, the Company submitted a
25 Non-Binding Open Season Bid Sheet for up to -
RICHINS, DI 15
Idaho Power Company

1 -. The bid sheet indicated a delivery preference for
2
3 Following the Open Season, Williams began
4 negotiating Precedent Agreements with each interested party
5 and anticipates finalizing the scope of the project based
6 on the Open Season commitments by April 2026 .
7 Q.
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10 A.
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RICHINS, DI 16
Idaho Power Company

1
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13 Idaho Power is taking timely and prudent actions
14 to secure gas transport upon recognition of the tightening
15 of the market positioned the Company to be able to procure
16 alternative, lower-cost resources to ensure Idaho Power can
17 continue to provide safe, reliable electric service
18 beginning in 2029 and beyond.
19 IV. CONCLUSION
20 Q. Please summarize your testimony.
21 A. Idaho Power has been facing challenges
22 bringing resources online timely as a result of the
23 Company' s historically high load growth across multiple
24 customer sectors at a time of rising costs, supply chain
25 constraints, permitting obstacles, and constrained system
RICHINS, DI 17
Idaho Power Company

1 capacity. The current procurement environment is very
2 restrictive with timelines for procurement activities
3 associated with natural gas resources rapidly shifting,
4 requiring the Company to take immediate action to procure
5 reciprocating engines, a turbine, and firm gas
6 transportation service following the identification of
7 South Hills and Peregrine as least-cost, least-risk
8 resources, ensuring Idaho Power can continue to provide
9 safe, reliable electric service beginning in 2029 and
10 beyond.
11 Q. Does this conclude your testimony?
12 A. Yes .
RICHINS, DI 18
Idaho Power Company

1 DECLARATION OF ADAM RICHINS
2 I, Adam Richins, declare under penalty of perjury
3 under the laws of the state of Idaho:
4 1 . My name is Adam Richins . I am employed by
5 Idaho Power Company as the Executive Vice President and
6 Chief Operating Officer.
7 2 . On behalf of Idaho Power, I present this
8 pre-filed direct testimony and Exhibit No. 4 and
9 Confidential Exhibit No. 5 in this matter.
10 3 . To the best of my knowledge, my pre-filed
11 direct testimony and exhibit are 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:
20 [NAME]
21
RICHINS, DI 19
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-26-04
IDAHO POWER COMPANY
RICHINS, DI
TESTIMONY
EXHIBIT NO. 4

Existing Natural Gas Transport and Storage Map
•. Van ❑�� ! - NWP
suwas j
. NWP Aquifers
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^~ — Tuscarora
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n Stanfield to Langley/Bennett — WhlteRiverHub
sal ��!• �' r _ 2 North Valmy
4. Bennett Mountain
2 Jim Bridger
Surrfas to Elmore/Langley ; 1
� L� � Q Langley Gulch
g
o,se'•A 2 Danskin
l7anskin (Elmore) i
� B'e�nett ---� Existing Transport
�A •••
••► RCL-Nov 2025
•• Opal im Bridger
Spire Stora
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Valm •` Williams.Saltt"a
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River Hub Williams corporate Hdqrs
Denver a t1 one WWlams Genter
Tulsa,ON 74172
- � Phone:[phone]
User:sstember Date:8/9/2024
5auamento
Exhibit No.4
Case No. IPC-E-26-04
Richins, IPC
Page 1 of 1

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-26-04
IDAHO POWER COMPANY
CONFIDENTIAL
RICHINS, DI
TESTIMONY
EXHIBIT NO. 5