20220203IPC to Staff 1-15.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]
February 3, 2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-21-41
In The Matter Of Idaho Power Company’s Application For Authority to
Proceed with Resource Procurements to Meet Identified Capacity
Deficiencies in 2023, 2024, and 2025 to Ensure Adequate, Reliable, and
Fair-Priced Service to its Customers
Dear Ms. Noriyuki:
Enclosed for electronic filing, please find Idaho Power Company’s Response to to
the First Production Request of the Commission Staff in the above matter.
Please handle the confidential information in accordance with the Protective
Agreement executed in this matter.
If you have any questions about this filing, please feel free to contact me directly.
Very truly yours,
Donovan E. Walker
DEW:cld
Enclosures
RECEIVED
2022 FEB 03 PM 3:46
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
AUTHORITY TO PROCEED WITH
RESOURCE PROCUREMENTS TO MEET
IDENTIFIED CAPACITY DEFICIENCIES IN
2023, 2024, AND 2025 TO ENSURE
ADEQUATE, RELIEABLE, AND FAIR-
PRICED SERVICE TO ITS CUSTOMERS.
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CASE NO. IPC-E-21-41

IDAHO POWER COMPANY’S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated January 13, 2022, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 2
REQUEST NO. 1: Please provide copies of all past and future data requests and
responses between the Company and the Oregon Public Utility Commission ("OPUC")
for the Docket No. UM 2210: Idaho Power Application for Waiver of Competitive Bidding
Rules. Please include both formal and informal responses. This response should include
public and confidential data responses. Please provide all future responses at, or shortly
after, the time when the Company files its responses to the request.
RESPONSE TO STAFF’S REQUEST NO. 1: Idaho Power received Data Request
Nos. 1-36 from the OPUC Staff in case No. UM 2210 on January 7, 2022. Idaho Power
responded to these requests on January 21, 2022. Please see the attached.
Idaho Power received Data Request No. 37 from the OPUC Staff in case No. UM
2210 on January 12, 2022. Idaho Power responded to this request on January 26, 2022.
Please see the attached.
Idaho Power received Data Request Nos. 38-39 from the OPUC Staff in case No.
UM 2210 on January 14, 2022. Idaho Power responded to these requests on January
28, 2022. Please see the attached.
The response to this Request is sponsored by Christy Davenport, Legal
Administrative Assistant of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 3

REQUEST NO. 2: Please explain why the Company limited the current 80 MW
Request for Proposal to wind, solar, energy storage, or some combination of these
resources.
RESPONSE TO STAFF’S REQUEST NO. 2: Respondents to the 2021 All Source
Request for Proposals (RFP) were required to submit proposals using the formatted
Proposal Entry Form (PEF) included with the RFP in the PowerAdvocate sourcing
platform (the Confidential PEF is attached to this response). The PEF is a prescriptive
Microsoft Excel tool that has input fields based on the type of resource being proposed.
Due to the short timeline for projects to be constructed to meet the 2023 identified capacity
deficit, Idaho Power assumed wind, solar, and energy storage solutions were the most
likely projects to be submitted in response to the RFP and the PEF was established to
allow these likely submittals.
Rather than prescriptively limit the resource type to the products outlined in Table
2 of the RFP, Section 3.2 of the RFP states “IPC may also accept other Products that
meet the ownership and electrical functionality criteria outlined in Table 2. Respondents
who propose a product not specifically identified in Table 2 must provide applicable
information, specifications, terms, etc. for evaluation purposes.”
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 4
REQUEST NO. 3: Please explain why the Company is limiting the current 80 MW
Request for Proposal to company-owned resources to meet the 2023 capacity deficit.
RESPONSE TO STAFF’S REQUEST NO. 3: The 2021 All Source Request for
Proposal is not limited to company-owned resources. The 2021 All Source Request for
Proposal requested ownership of, at a minimum, the storage component of a combined
solar or wind plus storage thus allowing a Power Purchase Agreement or other
arrangement for the wind or solar resources.
Idaho Power has an obligation to provide adequate, efficient, just, and reasonable
service on a nondiscriminatory basis to all those that request it within its certificated
service area. Idaho Power must at times acquire additional resources to meet the
identified capacity deficits on its system. Those resource acquisitions must take into
account the benefits of utility ownership and operation of resources, and not be premised
solely on short-term/least-cost, which can have catastrophic outcomes for electric service
and the public. Idaho Power is obligated to demonstrate that resource acquisitions are
prudent investments. With only limited exception, these resources should be owned by
Idaho Power, as it must satisfy its obligation to provide its customers with reliable service
and at the same time maintain its financial health to remain a viable, going concern,
regulated entity. This rationale is further explained in the responses to Staff Requests No.
7 and 12.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 5
REQUEST NO. 4: Please explain the difference in the Company's request for an
exemption in this case versus the request for a waiver of Oregon's Resource Procurement
Rules filed with the OPUC.
RESPONSE TO STAFF’S REQUEST NO. 4: The two filings are attempting to
generally accomplish the same result regarding the applicability of Oregon’s Resource
Procurement Rules to the resource needs identified for 2023, 2024 and 2025. Both the
Idaho and Oregon filings request the respective Commission to waive the Oregon
Resource Procurement Rules.
In Oregon, the Resource Procurement Rules 860-089-0010 2) states:
Upon request or its own motion, the Commission may waive any of the
Division 089 rules for good cause shown. A request for waiver must be made in
writing to the Commission prior to or concurrent with the initiation of a resource
acquisition.

The Company’s Oregon filing requests such a waiver, with the rules replaced by the
currently contemplated Request for Proposal/Certificate of Public Convenience and
Necessity process described in the Company’s Idaho and Oregon applications.
The Idaho request differs from the Oregon request, as it relates to broader long-
term resource procurement policy. In 2010, the Idaho Commission initiated a case, IPC-
E-10-02, seeking to establish competitive bidding guidelines for the RFP process used to
acquire supply-side resources by Idaho Power. In 2013, the Commission closed this case
without establishing Idaho-specific resource procurement guidelines, but rather directed
Idaho Power to follow the resource procurement guidelines applicable in its Oregon
service area. In the Idaho case only, Idaho Power raises concerns that the requirements
and goals of Oregon’s Resource Procurement Rules may not align with Idaho’s intended
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 6
system of regulation and the Company presents such concerns for the Commission’s
consideration.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 7
REQUEST NO. 5: Has the Company requested a waiver from the OPUC
Resource Procurement Rules for the current 80 MW Request for Proposal? Please
explain why or why not.
RESPONSE TO STAFF’S REQUEST NO. 5: No. As stated in Oregon Revised
Statutes 860-089-0100, excerpted below, the Resource Procurement Rules only apply
to Requests for Proposal greater than 80 megawatts.
Applicability of Competitive Bidding Requirements
(1) An electric company must comply with the rules in this division when it seeks
to acquire generating or storage resources or to contract for energy or capcity if
any of the following apply:
(a) The acquisition is of a resource or a contract for more than an aggregate of
80 megawatts and five years in length;

The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 8
REQUEST NO. 6: Please provide a markup to the OPUC Resource Procurement
Rules that would allow the Company to meet its time requirements to secure needed
resources to meet reliability requirements that are least cost while maintaining a fair and
transparent process.
RESPONSE TO STAFF’S REQUEST NO. 6: As described in the Company’s
application, the Company proposes a streamlined Request for Proposal process. The
primary changes to the rules would involve removal of the use of an Independent
Evaluator and Commission/stakeholder approval of various steps, primarily based upon
the extended time these items add to the process. Even with an expedited process, there
are very few developers that are willing to commit and/or are capable of bringing projects
online by June of 2023. The Company had not undertaken the requested markup of the
OPUC Resource Procurement Rules prior to this discovery request, and below is a rough
outline of such a process. The resource procurement rules are excerpted below:
Division 89
RESOURCE PROCUREMENT FOR ELECTRIC COMPANIES
860-089-0010
Applicability and Purpose of Division 089
(1) The rules contained in this Division apply to electric companies, and are intended to provide
an opportunity to minimize long-term energy costs and risks, complement the integrated resource
planning (IRP) process, and establish a fair, objective, and transparent competitive bidding process,
without unduly restricting electric companies from acquiring new resources and negotiating mutually
beneficial terms.
(2) Upon request or its own motion, the Commission may waive any of the Division 089 rules for good
cause shown. A request for waiver must be made in writing to the Commission prior to or concurrent with
the initiation of a resource acquisition.
(a) In addition to the filing requirements in OAR Chapter 860, Division 001, an electric company filing a
request for waiver under this section must serve the request on all parties to the electric company’s most
recent general rate case, request for proposal (RPF) filing, and IRP docket.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 9
(b) If a request for waiver is filed by an electric company after it acquires a resource, granting, if any, of
the waiver request does not result in or equate to the Commission’s acknowledgment of the resource
acquisition.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0020
Definitions
For purposes of this Division, unless the context requires otherwise:
(1) “Benchmark resource” is a resource identified in an electric company’s response to its own request for
proposals.
(2) “Commission-acknowledged IRP” means an IRP for which the Commission has acknowledged the
electric company’s action item to procure the resource subject to the rules in this division.
(3) "Electric company" has the meaning given that term in ORS 757.600.
(4) “Independent evaluator” or “IE” refers to a person engaged by an electric company to oversee an RFP
process under the rules in this division, and who also reports directly to the Commission during that
process. The IE must be independent of the utility and bidders, and also be experienced and competent
to perform all IE functions identified in these Division 089 rules.
(5) “Integrated resource plan” or “IRP” has the meaning given that term in OAR 860-027-0400.
(6) “IRP Update” means an update to an acknowledged IRP that is filed in accordance with OAR 860-
027-0400(9).
(7) “Qualifying facility” refers to qualifying facilities under 16 USC § 796(17) and (18) (2012) and ORS
758.505(8).
(8) “Request for proposals” or “RFP” means all documents, whether attached or incorporated by
reference, used for soliciting proposals from prospective bidders.
(9) “Resource acquisition” refers to a process for the purpose of acquiring energy, capacity, or storage
resources that starts with an electric company’s:
(a) Circulation of a final or draft RFP to third parties; or
(b) Communication of a final offer or receipt of a final offer in a two-party negotiation.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0100
Applicability of Competitive Bidding Requirements
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 10
(1) An electric company must comply with the rules in this division when it seeks to acquire generating or
storage resources or to contract for energy or capcity if any of the following apply:
(a) The acquisition is of a resource or a contract for more than an aggregate of 80 megawatts and five
years in length;
(b) The acquisition is of a resource or contract in which the electric company does not specify the size or
duration of the resource or contract sought but may result in an acquisition described in subsection (1)(a)
or (1)(c) of this rule;
(c) The acquisition is of multiple resources more than five years in length that in aggregate provide the
electric company with more than an aggregate of 80 megawatts, and these resources:
(A) Are located on the same parcel of land, even if such parcel contains intervening railroad or public
rights of way, or on two or more such parcels of land that are adjacent; and
(B) The generation equipment of any one of these resources is within five miles of the generation
equipment of any other of these resources and construction of these resources is performed under the
same contract or within two years of each other; or
(d) As directed by the Commission.
(2) An electric company may request that the Commission find that resources presumed to be subject to
subsection (1)(c) of this rule should not be considered in the aggregate. The electric company may make
this request before acquiring the resources. The electric company bears the burden of rebutting the
presumption that the acquisition is subject to these rules by showing each resource is separate and
distinct.
(3) An electric company is not required to comply with the competitive bidding requirements to acquire a
resource otherwise subject to section (1) of this rule when:
(a) There is an emergency; meaning a human-caused or natural catastrophe resulting from an unusual
and unexpected event, including but not limited to earthquake, flood, war, or a catastrophic energy plant
failure, that requires an electric company to take immediate action;
(b) There is a time-limited opportunity to acquire a resource of unique value to the electric company’s
customers;
(c) An alternative acquisition method was proposed by the electric company in the IRP and explicitly
acknowledged by the Commission; or
(d) Seeking to exclusively acquire transmission assets or rights.
(4) Within 30 days of seeking to acquire a resource under section (3) of this rule, the electric company
must file a report with the Commission explaining the relevant circumstances. The report must be served
on all the parties to the electric company's most recent rate case, RFP, and IRP dockets.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 11
860-089-0200
Engaging an Independent Evaluator
(1) Prior to issuing an RFP, an electric company must engage the services of an IE to oversee the
competitive bidding process. The electric company must notify all parties to the electric company’s most
recent general rate case, RFP, and IRP dockets of its need for an IE, and solicit input from these parties
and interested persons regarding potential IE candidates.
(2) The electric company must file a request for Commission approval to engage an IE. The Commission
Staff will review the request and recommend an IE to the Commission based in part on the consideration
of:
(a) Input received from the electric company and interested, non-bidding parties;
(b) Review of the degree to which the IE is independent of the electric company and potential bidders;
(c) The degree to which the cost of the services to be provided is reasonable;
(d) The experience and competence of the IE; and
(e) The public interest.
(3) The electric company is responsible for engaging the services of the IE and is responsible for all fees
and expenses associated with engaging the IE’s services. The electric company may request recovery of
fees and expenses associated with engaging an IE in customer rates.
(4) The electric company’s contract with the IE must require that the IE fulfills its duties under these rules
and that the IE confers as necessary with the Commission and Commission Staff on the IE’s duties.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.080, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0250
Design of Requests for Proposals
(1) For each resource acquisition, the electric company must prepare a draft request for proposals for
review and approval with the Commission, and provide copies of the draft to all parties to the IE selection
docket. Prior to filing the draft RFP with the Commission, the electric company must consult with the IE in
preparing the RFP and must conduct bidder and stakeholder workshops.
(2) The draft RFP must reflect any RFP elements, scoring methodology, and associated modeling
described in the Commission-acknowledged IRP. The electric company’s draft RFP must reference and
adhere to the specific section of the IRP in which RFP design and scoring is described.
(a) Unless the electric company intends to use an RFP whose design, scoring methodology, and
associated modeling process were included as part of the Commission-acknowledged IRP, the electric
company must, prior to preparing a draft RFP, develop and file for approval in the electric company’s IE
selection docket, a proposal for scoring and any associated modeling.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 12
(b) In preparing its proposal, the electric company must consider resource diversity (e.g. with respect to
technology, fuel type, resource size, and resource duration).
(3) At a minimum, the draft RFP must include:
(a) Any minimum bidder requirements for credit and capability;
(b) Standard form contracts to be used in acquisition of resources;
(c) Bid evaluation and scoring criteria that are consistent with section (2) of this rule and with OAR 860-
089-0400;
(d) Language to allow bidders to negotiate mutually agreeable final contract terms that are different from
the standard form contracts;
(e) Description of how the electric company will share information about bid scores, including what
information about the bid scores and bid ranking may be provided to bidders and when and how it will be
provided;
(f) Bid evaluation and scoring criteria for selection of the initial shortlist of bidders and for selection of the
final shortlist of bidders consistent with the requirements of OAR 860-089-0400.
(g) The alignment of the electric company’s resource need addressed by the RFP with an identified need
in an acknowledged IRP or subsequently identified need or change in circumstances with good cause
shown; and
(h) The impact of any applicable multi-state regulation on RFP development, including the requirements
imposed by other states for the RFP process; and
(4) An electric company may set a minimum resource size in the draft RFP, but it must allow qualifying
facilities that exceed the eligibility cap for standard avoided cost pricing to participate as bidders.
(5) The Commission may approve the RFP with any conditions it deems necessary, upon a finding that
the electric company has complied with the provisions of these rules and that the draft RFP will result in a
fair and competitive bidding process.
(6) The Commission will generally issue a decision approving or disapproving the draft RFP within 80
days after the draft RFP is filed. An electric company may request an alternative review period when it
files the draft RFP for approval including a request for expedited review upon a showing of good cause.
Any person may request an extension of the review period of up to 30 days upon a showing of good
cause.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758060, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0300
Resource Ownership
(1) An electric company may submit or allow its affiliates to submit bids in response to the electric
company’s request for proposals.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 13
(a) Electric company and affiliate bids must be treated in the same manner as other bids.
(b) Any individual who participates in the development of the RFP or the evaluation or scoring of bids on
behalf of the electric company may not participate in the preparation of an electric company or affiliate bid
and must be screened from that process.
(2) An electric company may propose a benchmark bid in response to its RFP to provide a potential cost-
based alternative for customers. The electric company may make elements of the benchmark resource
owned or secured by the electric company (e.g., site, transmission rights, or fuel arrangements) available
for use in third-party bids.
(3) If benchmark bid elements secured by the electric company are not made available to all bidders, it
must provide analysis explaining that decision when seeking RFP acknowledgement and recovery of the
costs of the resource in rates.
(a) If electric company resources are offered and made available for use in third-party bids, then the RFP
may provide for appropriate compensation of electric company resources by third-party bidders.
(b) Separate electric company affiliate bids are not subject to this section of this rule, and no information
on any decision to offer the use of separate electric company affiliate-owned elements to third-parties is
required to be supplied to the Commission.
(4) An electric company may consider ownership transfers within an RFP solicitation.
(5) The electric company issuing the RFP must allow independent power producers to submit bids with
and without an option to renew, and may not require that bids include an option for transferring ownership
of the resource.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0350
Benchmark Resource Score
(1) Prior to the opening of bidding on an approved RFP, the electric company must file with the
Commission and submit to the IE, for review and comment, a detailed score for any benchmark resource
with supporting cost information, any transmission arrangements, and all other information necessary to
score the benchmark resource. The electric company must apply the same assumptions and bid scoring
and evaluation criteria to the benchmark bid that are used to score other bids.
(2) If, during the course of the RFP process, the Commission or the IE determines that it is appropriate to
update any bids, the electric company must also make the equivalent update to the score of the
benchmark resource.
(3) Before the IE provides the electric company an opportunity to score other bids, the electric company
must file with the Commission and submit via a method that protects confidentiality the following
information:
(a) The final benchmark resource score developed in consultation with the IE, and
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 14
(b) Cost information and other related information shared under this rule.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0400
Bid Scoring and Evaluation by Electric Company
(1) To help ensure that the electric company engages in a transparent bid-scoring process using objective
scoring criteria and metrics, the electric company must provide all proposed and final scoring criteria and
metrics in the draft and final RFPs filed with the Commission.
(2) The electric company must base the scoring of bids and selection of an initial shortlist on price and, as
appropriate, non-price factors. Non-price factors must be converted to price factors where practicable.
Unless otherwise directed by the Commission, the electric company must use the following approach to
develop price and non-price scores:
(a) Price scores must be based on the prices submitted by bidders and calculated using units that are
appropriate for the product sought and technologies anticipated to be employed in responsive bids using
real-levelized or annuity methods. The IE may authorize adjustments to price scores on review of
information submitted by bidders.
(b) Non-price scores must, when practicable, primarily relate to resource characteristics identified in the
electric company’s most recent acknowledged IRP Action Plan or IRP Update and may be based on
conformance to standard form contracts. Non-price scoring criteria must be objective and reasonably
subject to self-scoring analysis by bidders.
(c) Non-price score criteria that seek to identify minimum thresholds for a successful bid and that may
readily be converted into minimum bidder requirements must be converted into minimum bidder
requirements.
(d) Scoring criteria may not be based on renewal or ownership options, except insofar as these options
affect costs, revenues, benefits or prices. Any criteria based on renewal or ownership options must be
explained in sufficient detail in the draft RFP to allow for public comment and Commission review of the
justification for the proposed criteria.
(4) The electric company may select an initial shortlist of bids after it has scored the bids and identified
the bids with top scores. Following selection of an initial shortlist of bids, the electric company may select
a final shortlist of bids.
(5) Unless an alternative method is approved by the Commission under OAR 860-089-0250(2)(a),
selection of the final shortlist of bids must be based on bid scores and the results of modeling the effect of
candidate resources on overall system costs and risks using modeling methods that are consistent with
those used in the Commission-acknowledged IRP.
(a) The electric company must use a qualified and independent third-party expert to review site-specific
critical performance factors for wind and solar resources on the initial shortlist before modeling the effects
of such resources.
(b) In addition, the electric company must conduct, and consider the results in selecting a final short list, a
sensitivity analysis of its bid rankings that demonstrates the degree to which the rankings are sensitive to:
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 15
(A) Changes in non-price scores; and
(B) Changes in assumptions used to compare bids or portfolios of bids, such as assumptions used to
extend shorter bids for comparison with longer bids, or assumptions used to compare smaller bids or
portfolios with larger ones.
(6) The electric company must provide the IE and Commission with full access to its production cost and
risk models and sensitivity analyses. When the IE and Commission concur that appropriate protections for
protected information are in place, the electric company must provide access to such information to non-
bidding interested parties that request the information in the final short list acknowledgment proceeding.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0450
Independent Evaluator Duties
(1) The IE will oversee the competitive bidding process to ensure that it is conducted fairly, transparently,
and properly.
(2) The IE must be available and responsive to the Commission throughout the process, and must
provide the Commission with the IE’s notes of all conversations and the full text of written
communications between the IE and the electric company and any third-party that are related to the IE’s
execution of its duties.
(3) The IE must consult with the electric company on preparation of the draft RFP and submit its
assessment of the final draft RFP to the Commission when the company files the final draft for approval.
(4) The IE must check whether the electric company’s scoring of the bids and selection of the initial and
final shortlists are reasonable.
(5) To determine if the electric company’s selections for the initial and final shortlists are reasonable,
when the RFP allows bidding by the issuing electric company or an affiliate of the company, or includes
resource ownership options for the electric company, the IE must independently score the affiliate bids
and bids with ownership characteristics or options, if any, and all or a sample of the remaining bids. When
the IE does not score all bids, and a request for acknowledgment of a final shortlist is pending before the
Commission, as provided in OAR 860-089-0500; a participant in the acknowledgment proceeding may
request that the Commission direct the IE to score all remaining bids or a broader sample.
(6) The IE must also evaluate the unique risks and advantages associated with any company-owned
resources (including but not limited to the electric company’s benchmark), and may apply the same
evaluation to third-party bids, including an evaluation of the following issues:
(a) Construction cost over-runs (considering contractual guarantees, cost and prudence of guarantees,
remaining exposure to ratepayers for cost over-runs, and potential benefits of cost under-runs);
(b) Reasonableness of forced outage rates;
(c) Reasonableness of any proposal or absence of a proposal to offer electric company owned or
benchmark resource elements (e.g., site, transmission rights or fuel arrangements) to third-party bidders
as part of the draft and final RFP;
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 16
(d) End effect values;
(e) Environmental emissions costs;
(f) Reasonableness of operation and maintenance costs;
(g) Adequacy of capital additions costs;
(h) Reasonableness of performance assumptions for output, heat rate, and power curve; and
(i) Specificity of construction schedules or risk of construction delays.
(7) The IE must review the reasonableness of any score submitted by the electric company for a
benchmark resource. Once the electric company and the IE have both scored and evaluated the
competing bids and any benchmark resource, the IE and the electric company must file their scores with
the Commission. The IE and electric company must compare results and attempt to reconcile and resolve
any scoring differences. If the electric company and IE are unable to resolve scoring differences, the IE
must explain the differences in its closing report to the Commission.
(8) The IE must review the electric company’s sensitivity analysis of the bid rankings required under OAR
860-089-0400 and file a written assessment with the Commission prior to the electric company requesting
acknowledgment of the final short list.
(9) The IE must file a closing report with the Commission after the electric company has selected its final
shortlist. The IE’s closing report must include an evaluation of the applicable competitive bidding
processes in selecting the least-cost, least-risk acquisition of resources. The Commission may request
that the IE include additional analysis in its closing report.
(10) Unless the Commission directs otherwise, the IE must participate in the final short list
acknowledgment proceeding initiated by the electric company, and must continue to participate if, at the
time of acknowledgment of the electric company’s final shortlist, the Commission chooses to require IE
involvement through final resource selection. In addition to making a decision on acknowledgment, the
Commission, on its own motion or at the request of other parties, including bidders, may require
expanded IE involvement. Upon such a request or its own motion, the Commission may require an IE to
be involved in the competitive bidding process through final resource selection.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0500
Final Short List Acknowledgement and Result Publication
(1) For the purposes of this section, “acknowledgment” is a finding by the Commission that an electric
company’s final shortlist of bid responses appears reasonable at the time of acknowledgment and was
determined in a manner consistent with the rules in this division.
(2) An electric company must request that the Commission acknowledge the electric company's final
shortlist of bids before it may begin negotiations. Acknowledgment of a shortlist has the same legal force
and effect as a Commission-acknowledged IRP in any future cost recovery proceeding.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 17
(3) A request for acknowledgement must include, at a minimum, the IE's closing report, the electric
company’s final shortlist of responsive bids, all sensitivity analyses performed, and a discussion of the
consistency between the final shortlist and the electric company’s last-acknowledged IRP Action Plan or
acknowledged IRP Update.
(4) The Commission will generally issue a decision on the request for acknowledgment within 60 days of
receipt of the electric company’s filing.
(5) The electric company must make a publicly available filing in the RFP docket providing the average
bid score and the average price of a resource on its final shortlist.
(6) Following execution of all contracts resulting from an RFP or cancellation of the RFP, the electric
company must provide information, on request, to a bidder about the bidder’s bid score.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
860-089-0550
Protected Information
The electric company may request a protective order be issued prior to making available protected
information required to be shared under the rules in this Division. Protected information may include, but
is not limited to, RFP-related and bidding information, such as a company’s modeling, cost support for
any benchmark resource and detailed bid scoring and evaluation results. Protected information may then
be provided to the Commission, the IE, and non-bidding parties, as appropriate under the terms of the
protective order. Information shared under the terms of a protective order issued under this rule may be
used in RFP review and approval, final shortlist acknowledgement, and cost-recovery proceedings.
Statutory/Other Authority: ORS Ch. 183, 756, 758, 2016 OL Ch. 28
Statutes/Other Implemented: ORS 756.040, 758.060, 2016 OL Ch. 28, Sect. 6
History:
PUC 4-2018, adopt filed 08/30/2018, effective 08/30/2018
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 18
REQUEST NO. 7: Please provide a detailed explanation of why it would be
extremely detrimental to the Company if the Company was required to comply with the
OPUC Resource Procurement Rules.
RESPONSE TO STAFF’S REQUEST NO. 7: There are two main reasons it would
be extremely detrimental to the Company if the Company was required to comply with the
OPUC Resource Procurement Rules.
First, the length of time required to complete the procurement process under the
OPUC Resource Procurement Rules would not allow for the timely installation of
necessary capacity to meet identified supply deficits in 2023, 2024 and 2025. The
estimated timeline for the entire procurement process required by the OPUC Resource
Procurement Rules is discussed on pages 13 – 16 of the Application in this case, and on
Attachment 1 to the Application. Idaho Power estimates, based upon the required
timelines from the OPUC Resource Procurement Rules, that it could take a minimum of
more than 18 months from the initial stages of selection of the required independent
evaluator until the final step of the process where the OPUC approves the short list of
bidders. Negotiations and necessary regulatory approvals could take an additional 12
months. Finally, engineering and construction of the generation resources could take up
to another two years to complete. Considering the timing of the identified near-term
resource deficits, a process that could take up to four and a half years from beginning to
commercial operation, would surely compromise the Company’s ability to perform its
obligation to provide safe, reliable service.
Second, as discussed on pages 15 and 16 of the Application, the OPUC Resource
Procurement Rules introduce a bias against the acquisition of utility-owned resources into
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 19
generation resource procurements, favoring the standalone per-MWh price of a fixed term
contract (typically well short of the useful life of the asset) over reliability, long-term
customer impacts, flexibility in resource operation to meet changing market and
operational conditions for the benefit of customers and reliability, and the financial viability
of the utility. The OPUC Resource Procurement Rules are designed to favor least cost
PPA resources that are not the optimal resources operationally or for a utility such as
Idaho Power that already holds a proportionately large amount of PPAs.
The OPUC Resource Procurement Rules were established under the incorrect
premise that without such rules, there is an inherent bias toward utility ownership or that
the utility holds an unfair advantage over third-party owners that must be corrected. In
fact, the utility does not hold an unfair advantage over third-party owners, but rather, a
regulated utility has been purposefully and thoughtfully granted a unique role to provide
an essential service to the public. This role is guided by the regulatory compact under
which a utility has the obligation to provide safe, reliable, affordable energy to customers
in its franchise service areas in exchange for recovery of prudently incurred costs and a
fair rate of return for investors. This model of regulation has worked well for customers
for over 100 years and should not be misrepresented as bias or an unfair advantage that
needs correction. Third-party owners do not operate under the regulatory compact and
therefore have no obligation to serve other than what can be included in an inflexible
contract as performance requirements and damages provisions. However, damages
payments under a contract do not equate to reliability. By contrast, a procurement
process for resources that takes into account not only price, but also reliability, system
operation, long-term operation and maintenance of facilities, financial viability of the utility,
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 20
economic dispatch, environmental policies, changing markets, real-time needs and load
growth, and other attributes, is one that benefits customers, developers, and the utility. A
procurement process that does not adequately address all of those factors for the
resource procurements described in the Application is thus extremely detrimental.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 21
REQUEST NO. 8: Table 1: Peak-Hour Load and Resource Balance shows a
deficit of 101 MW in July of 2023. Please explain why the current Request for Proposal
for 80 MW of capacity will reliably serve customer demand in 2023.
RESPONSE TO STAFF’S REQUEST NO. 8: Alongside the 2021 RFP, “Idaho
Power is also, in parallel, investigating different configurations of Company owned and
constructed battery energy storage systems…” (see Idaho Power’s application on page
2). This investigation of Company-owned battery storage and proposed changes to
demand response programs combined with the 2021 RFP will ensure Idaho Power can
meet deficits identified in the 2021 IRP for Summer of 2023 and reliably serve customer
demand.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 22
REQUEST NO. 9: If the 120 MW Jackpot Solar project is not in service by summer
2023, please explain why only approximately 40 MW of additional summer peak capacity
will be needed to meet projected customer demand.
RESPONSE TO STAFF’S REQUEST NO. 9: Although Jackpot Solar’s nameplate
is expected to be 120 MW, given the non-coincidence of peak solar production and net
peak load, the Jackpot Solar project’s Effective Load Carrying Capability (ELCC) is only
approximately 40 MW.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 23
REQUEST NO. 10: Please identify and explain any issues or limitations to
bringing Valmy Unit 1 back into service to meet the system reliability issues following the
reliability and economic impact analyses completed in May 2021.
RESPONSE TO STAFF’S REQUEST NO. 10: Pursuant to the terms of the North
Valmy Project Framework Agreement, Idaho Power’s relinquishment of its right to the
output from Unit 1 was irrevocable as of the effective date of its exit from Unit 1 in 2019.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 24
REQUEST NO. 11: Please provide the specific documents from the Northwest
Power and Conservation Council showing where it has moved to a LOLE of 0.05 days
per year, or no more than one loss of load event per 20 years.
RESPONSE TO STAFF’S REQUEST NO. 11: The reliability target used by the
Northwest Power and Conservation Council (Council) is presented in its latest Power
Plan, “Seventh Power Plan” in chapter 11. The Seventh Power Plan is available at
https://www.nwcouncil.org/reports/seventh-power-plan.
The Council also references the reliability used in their analysis on the Resource
Adequacy site at https://www.nwcouncil.org/energy/energy-topics/resource-adequacy.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 25
REQUEST NO. 12: Please fully explain and provide specific examples supporting
the Company's statement regarding the OPUC Resource Procurement Rules where the
rules "... are designed to favor least cost PPA resources that are not the optimal resources
operationally or for a utility such as Idaho Power that already holds a proportionately large
amount of PPAs."
RESPONSE TO STAFF’S REQUEST NO. 12: In addition to the response below,
please see the response to Staff’s Request No. 7. While the OPUC Resource
Procurement Rules do contemplate non-price factors as part of the evaluation, the OPUC
Resource Procurement Rules appear to heavily weight price over some of the operational
constraints that occur with a contracted resource. OAR 860-089-0300(1)(a) provides that
“[e]lectric company and affiliate bids must be treated in the same manner as other bids.”
However, ownership of a resource and a contractual right to the output of a resource,
when constrained by the other terms and conditions of the contract, are not equivalent.
For instance, OAR 860-089-0300(5) provides that the “electric company issuing the RFP
must allow independent power producers to submit bids with and without an option to
renew, and may not require that bids include an option for transferring ownership of the
resource.” OAR 860-089-0400(2), pertaining to bid scoring, provides that the “electric
company must base the scoring of bids and selection of an initial shortlist on price and,
as appropriate, non-price factors. Non-price factors must be converted to price factors
where practicable.” The OAR then prescribes the method by which the utility must
develop the price and non-price scores. This includes subsection (2)(d), which provides
that scoring criteria “may not be based on renewal or ownership options, except insofar
as these options affect costs, revenues, benefits or prices.” The combination of these
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 26
rules, together with an independent examiner and intervenors heavily focused on price,
introduce a heavy bias toward PPA transactions. This is further exacerbated by federal
tax credit amortization rules for regulated utilities that favor third-party ownership of
resources, resulting in a power purchase agreement (PPA) bias.
One of the primary features of an owned resource is the ability to configure,
reconfigure, maintain, operate, and economically and operationally dispatch the unit
without application of the confines of the terms and conditions of a PPA with a third party.
Ownership of the resource allows the utility to still focus on price (as the Commission
maintains authority over recovery of costs regardless of application of the OPUC
Resource Procurement Rules), but also focus on reliability, system operation, long-term
operation and maintenance of facilities, financial viability of the utility, economic dispatch
in changing energy markets, and adaptation for environmental policies. For a utility such
as Idaho Power, which is seeking to meet capacity deficits (as opposed to merely energy
deficits), it is beneficial for the company to have that flexibility. As the amount of PPA
generation resources in Idaho Power’s portfolio increases, a number of issues are
exacerbated: integration of the power becomes more difficult and costly; the utility loses
maintenance and control over the facility and its condition; the utility typically loses the
generation resource at a specified contract date short of the useful life of the plant; the
utility is relegated to the terms of the contract despite a dynamic energy landscape;
curtailment of the facility is limited, expensive, or fraught with potential legal challenges;
and cyber and physical security oversight of the facility is diminished. The attendant
contractual remedy of damages in many circumstances will not adequately compensate
the company for the reliability, system, company, customer, reputation, and shareholder
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 27
impacts that may result from a contract breach and can result in costly and protracted
litigation. While each of these items individually is significant, collectively they can be
hugely impactful.
For a utility-scale battery storage facility in particular, PPA arrangements introduce
additional complications, particularly when operating in the Energy Imbalance Market
(EIM) where dispatch changes are made real-time within an hour. If the company were
to execute a PPA for a battery storage facility, the dispatchability, curtailment,
maintenance, security, mandatory payment, and operational terms, conditions, and
limitations, would be pre-defined for the term of the PPA. These terms would be
detrimental in that:
 Based on discussions with external legal counsel familiar with PPA terms for
energy storage projects, utility curtailment of a battery storage facility under the
terms of the PPA is compensable – i.e., absent emergency conditions or an event
of force majeure, it is typical and market-standard in a PPA that the utility
compensate the asset owner for energy that would have flowed during the
curtailment, despite not receiving the energy. The off-taker typically is required to
make the generator "whole" by paying the contract price for all energy that the
generating facility would have produced and delivered to the delivery point, but for
the curtailment by off-taker. As Idaho Power increases the amount of intermittent
energy on its system and participates in the EIM, the company needs additional
flexibility in operation of its capacity resources to integrate the energy. With Idaho
Power already having 1,273 MW of intermittent renewable energy on its system,
and the 2021 IRP forecasting additional renewable energy resources, Idaho Power
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 28
expects that the ability to curtail certain resources, including battery storage
facilities, will be essential to its ability to provide reliable energy services. This
curtailment increases even more as part of the EIM. Negotiating a PPA with
compensable curtailment, without knowing the extent by which Idaho Power will
need to curtail the battery storage facility, creates economic uncertainty. Seeking
to negotiate a contract that allows for, and pre-pays for, curtailment is not likely
available in the market at a reasonable price, based on Idaho Power’s discussions
with external legal counsel.
 Operating an electric grid is complex. Idaho Power operates its system in a
manner that considers economics for customers, resource availability, resource
location, market conditions, energy market requirements, voltage and frequency,
possible outages and available paths, and regulatory mandates. It also operates
as part of the EIM, which quickly and automatically dispatches and curtails energy
to achieve economic benefits. Having ownership of the capacity resources, as
opposed to mandatory and inflexible PPA terms regarding how a resource is
dispatched, allows Idaho Power to operate its system and its capacity resources
in a manner that considers each of those factors and the real-time market. To
focus on just one of those areas, dynamic market conditions are a further hurdle
for PPA-based battery storage systems. It would be exceptionally difficult to pre-
negotiate PPA terms that would accommodate a level of flexibility that provides for
adaptation for changing market conditions, Idaho Power’s system operation to
accommodate those conditions, the EIM, and development of new markets like the
emerging energy day-ahead market currently in development in the western U.S.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 29
Even if Idaho Power were to pre-negotiate curtailment and dispatch rights of
thousands of different scenarios minutes and years in advance, which is unlikely,
the proposed flexibility would be relatively expensive. As an example, the
interrelationship between the Jim Bridger power plant and the energy markets
demonstrates the operational need for flexibility and the benefit of owned
resources. Idaho Power determines in advance a planned operational schedule
for the Jim Bridger plant. For each hour of the day, Idaho Power must have
available resources that are equal to the load forecast to participate in the EIM, or
in other words, being balanced each hour of the day, For June, July, and August
2021, a period of 92 days, there were 83 days during which the generation from
the plant deviated notably from the pre-defined schedule for hours 18-22, which
indicates the EIM made alternative dispatch decisions based on market conditions,
economics, and operating conditions in real-time. Indeed, of the 460 hours during
that timeframe, the EIM adjusted (and often curtailed) Bridger’s operation from the
plan 285 times. This same form of flexibility in dispatch and curtailment should be
carried forward to other capacity resources, if Idaho Power is expected to operate
a reliable and economically effective system.
 For an owned battery storage resource, Idaho Power has greater flexibility around
charging of the battery, which thus leads to greater flexibility and utility by Idaho
Power on the discharge side of the battery. This has tax implications. In order to
be eligible to receive the Investment Tax Credit (ITC), a battery must be charged
at least 75% of the time by the solar facility where it is co-located. If the battery is
charged from the grid at all, the ITC is reduced (or subject to recapture) based on
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 30
the percentage of charging from the solar facility. For example, if the battery was
charged 15% of the time from the grid, the project would only be entitled to 85% of
the ITC for which it would otherwise qualify. As a result, typical PPAs prohibit grid
charging during the ITC recapture period (i.e., the first 5 years of the term). Some
PPAs permit grid charging but require the off-taker to hold the generator harmless
for all lost ITCs. Again, as the resource owner under the PPA will base its financial
model and associated pricing on the ITCs, Idaho Power’s charging source and
timing, and by corollary the dispatch, of the flexibility would be limited by the PPA
terms that are associated with the owner’s anticipated returns, without regard to
the economics of the method of charging and dispatch. Further, aside from the
ITC considerations on the source of the battery charge, for a combined battery-
solar facility the PPA is unlikely to contain pre-negotiated terms for dispatch of both
simultaneous to the grid, as the number of potential dispatch iterations and
conditions, and the factors that will determine those decisions, are complex and
endless and not easily contemplated in advance in the terms of a PPA. If the
interconnection is throughput limited, the issue becomes even more complex and
difficult to predict with any economic or operational certainty at the time the PPA
is executed.
 Finally, if the company were to execute a contractual arrangement for a typical 20-
year term that provides for dispatch rights and control over the facility, the PPA
would need to be capitalized per generally accepted accounting principles (GAAP)
rules on the company’s financial statements, which can have adverse impacts to
the company’s financial condition, financial ratios, credit ratings, and revenue
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 31
requirement for rate cases.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 32
REQUEST NO. 13: Please fully explain and provide specific detail showing how
the OPUC Resource Procurement Rules differs from the Idaho Power's Request for
Proposal process given the Company's statement: "By contrast, a procurement process
for resources that takes into account not only price, but also reliability, system operation,
long-term operation and maintenance of facilities, financial viability of the utility, economic
dispatch, environmental policies, real-time needs and load growth, and other attributes,
is one that benefits customers, developers, and the utility."
RESPONSE TO STAFF’S REQUEST NO. 13: The principal differences between
the Oregon Resource Procurement Rules and Idaho Power’s Request for Proposal are
1) timing of the process and 2) consideration of non-price attributes in the evaluation of
bids received. Please see the Company’s response to Staff’s Request Nos. 7 and 12 for
further discussion of these topics.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 33
REQUEST NO. 14: Please provide a schedule illustrating the specific changes to
the Company's assumptions and modeling from the 2019 second amended IRP and the
2021 IRP. Please include the effects of each change on the Company's capacity
deficiency date.
RESPONSE TO STAFF’S REQUEST NO. 14: The two primary factors impacting
capacity between the IRPs are changes to the capacity assumptions for demand
response and market purchases. Please see Idaho Power’s response to OPUC Staff’s
Request 39 in Oregon Docket UM 2210, which has been provided in the Company’s
response to Staff’s Request No. 1 in this docket. That response includes an attached
Excel file comparing the Load and Resource Balance capacity assumptions between the
2019 Second Amended IRP and the 2021 IRP.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader of Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 34
REQUEST NO. 15: Does the Company plan to file CPCN case(s) with the Idaho
Commission after it completes its resource selections? If not, please explain.
RESPONSE TO STAFF’S REQUEST NO. 15: Yes. As stated in its application,
page 18:
Once a winning bidder is selected and contractual documents are executed,
the Company, as it has done in the past, will bring the proposed generation
acquisition to the Commission for is review in a CPCN proceeding to establish both
the need and expected cost of the procurement. The required CPCN process as
well as the subsequent rate making proceedings will provide considerable
oversight of the procurement process, and ensure low cost, reliable resource
acquisitions for customers - as it has done for the Company’s more than 100-year
history.

The response to this Request is sponsored by Mark Annis, Regulatory Consultant
of Idaho Power Company.

Respectfully submitted this 3rd day of February 2021.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF – 35
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 3rd day of February 2022, I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY’S RESPONSE TO
THE FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF upon the
following named parties by the method indicated below, and addressed to the following:

Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074

Emailed to:
[e-mail]
Industrial Customers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702

Emailed to:
[e-mail]

Northwest and Intermountain Power
Producers Coalition
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise, Idaho 83702

Emailed to:
[e-mail]

IdaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 w. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701

Emailed to:
[e-mail]
[e-mail]
Idaho Conservation League
Benjamin J. Otto
710 North 6th Street
Boise, ID 83701
Emailed to:
[e-mail]
________________________________
Christy Davenport, Legal Assistant