20220203IPC to Staff Attachment 1 - UM 2210 - Responses to 1-39.pdf

UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 1:
See IPC’s Second Amended 2019 IRP (LC 74), Appendix C, page 27 stating “Exit from North
Valmy units not considered to affect capacity deficiency period because of IRP’s assumed peak-
hour wholesale electric market imports across existing north Valmy transmission line.” Please
provide a narrative description of changes in the Company’s finding since the Second Amended
2019 IRP.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 1:
As part of the Valmy Unit 2 Exit Analysis and in preparation for the 2021 IRP, Idaho Power
reviewed capacity assumptions utilized for the load and resource balance used in the Second
Amended 2019 IRP. The Valmy Unit 2 Exit Analysis report, filed under docket LC 74 on August
4, 2021, provides additional details on the capacity assumption changes since the Second
Amended 2019 IRP. Further information can be found in Idaho Power’s 2021 IRP (Chapter 9 –
Planning Margin section and Chapter 10 – Capacity Planning Margin).
As described in the Valmy Unit 2 Exit Analysis, drivers of changes to the capacity deficiency
period included adjustments to the Market Purchase Assumptions and the Effective Load Carrying
Capability (ELCC) for wind, solar, and demand response resources.
For the Second Amended 2019 IRP, an exit of North Valmy units was assumed to open
transmission capacity on the existing North Valmy transmission line that could be used to move
market purchases from southern market hubs to the Idaho Power area. This assumption was
further analyzed in the Valmy Unit 2 Exit Analysis study. Idaho Power found that, although Idaho
Power owned and controlled transmission capacity north of the Idaho-Nevada border that would
be made available with North Valmy exits, no firm transmission capacity is available on the NV
Energy system between Southern Market hubs such as Mead, Palo Verde, and Four Corners to
deliver across Nevada to the Idaho border. To further test transmission and market availability,
the Company issued a market-specific Request for Proposal (RFP) on April 26, 2021 to assess
these transmission system constraints for delivery to Idaho’s border. No bids were received,
emphasizing the difficulty of importing energy under a constrained transmission system. As a
result of these transmission availability findings, Market Purchase Assumptions for the load and
resource balance were adjusted -- internally set aside transmission capacity now requires that a
corresponding reservation on neighboring systems be considered for expected firm purchases
from regional markets.
Secondly, following the development of the 2019 IRP, Idaho Power modified its Planning Margin
approach to utilize Loss of Load Expectation (LOLE) probabilistic methods to determine system
needs to meet a reliability threshold for all hours of the day on the system. The LOLE method
evaluates the capability of existing resources to meet demand through the determination of ELCC
for each resource type. For the Valmy Unit 2 Exit Analysis and the 2021 IRP ELCC, adjustments
were made for wind, solar, and demand response that resulted in changes to the peak-serving
capability of Idaho Power’s existing resources and, therefore, the capacity deficiency period.
Further information on LOLE methods can be found in Appendix C of Idaho Power’s 2021 IRP.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 2:
See IPC’s Second Amended 2019 IRP (LC 74), Appendix C, page 27 stating “Deficiency period
start First capacity deficit = (42) MW July 2029.” Please provide a narrative description of changes
since the Second Amended 2019 IRP.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 2:
Please see the Company's response to Staff's Data Request No. 1 for a summary of the primary
drivers of the change in the first capacity deficit since the Second Amended 2019 IRP.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 3:
Please either provide workbooks to support identified capacity deficits or direct Staff to where the
information can be found in the 2021 IRP.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 3:
Monthly Load and Resource Balance Data for 2021-2040 is provided in Idaho Power’s 2021 IRP,
Technical Appendix C, pages 18-37. Pages 20-22 present the years 2023, 2024, and 2025 and
support the identified capacity deficits.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 4:
Do your assumptions for QF renewals align with recommendation from OPUC Staff in Idaho
Power’s latest PURPA avoided cost docket? If not, please explain.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 4:
In the 2021 Integrated Resource Plan (IRP), Idaho Power assumed all PURPA contracts renew
upon expiration except for wind contracts. For wind contracts, Idaho Power included three renewal
scenarios as part of the 2021 IRP:
 0% renew (included as a sensitivity),  25% renew (base IRP assumption), and  100% renew (included as a sensitivity).
The Company is not aware of any recommendations from OPUC Staff related to qualifying facility
renewals specific to Idaho Power’s latest PURPA avoided cost docket.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 5:
See IPC’s 2019 Second Amended IRP, page 120 stating “For winter adequacy, Idaho Power
generally has excess resource capacity to support the region.” Please confirm that this summary
is still accurate. If not, please explain why.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 5:
Yes, this summary is still accurate -- Idaho Power has excess resource capacity in the winter.
This information is available in the monthly Load and Resource Balance contained in the 2021
IRP, Appendix C: Technical Appendix, pages 18-37. The second to last row at the bottom of each
page lists the monthly surplus or deficit.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 6:
Please provide workpapers supporting the 2023 78 MW capacity deficit identified in May 2021.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 6:
Please see the attached Excel file with the load and resource balance that was used in May 2021
to determine the July 2023 78 MW capacity deficit.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 7:
Did Idaho Power have any indication prior to May 2021 of a 78 MW capacity deficit in 2023? If so,
please explain in what forum and format did Idaho Power share this information with Oregon
stakeholders or Commission staff? In your response, please indicate whether this information was
shared with stakeholders in Docket LC 74.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 7:
Idaho Power first identified a capacity deficit during the Valmy Unit 2 Exit Analysis performed early
in 2021. Idaho Power shared preliminary Valmy Unit 2 study information with stakeholders,
including OPUC staff, during Integrated Resource Plan Advisory Council meetings on February
9, 2021, and April 8, 2021. The Valmy Unit 2 Exit Analysis report was filed in Docket LC 74 on
August 4, 2021.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36

TOPIC OR KEYWORD: CAPACITY

STAFF’S DATA REQUEST NO. 8:

Pages 2-3 of the Application explain that “Idaho Power is also, in parallel, investigating different
configurations of Company owned and constructed battery storage systems, possible
modifications to existing Demand Response programs, and pursuing other short-term market
solutions to meet the forecasted capacity deficits. However, these efforts will not be enough to
meet the rapidly evolving and dynamic forecasted capacity deficits.” Please explain:
a. When the Company will know whether these are viable options,
b. How much specifically each of these options can address the capacity deficits, and
c. Why specifically these options cannot address the deficits.

IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 8:

The following table summarizes the options evaluated by the Company. Currently, short-term
market solutions are considered non-viable, while Demand Response (“DR”) and battery storage
options are considered viable. However, as noted below, the amount of capacity provided by
these viable options will be insufficient to meet the expected capacity deficits in 2024 and 2025
intended to be addressed by the Company’s Request for Proposals (“RFP”).

Option Viability Quantity (MW) Ability to Meet Capacity
Deficit
Short-term market RFP Not viable. Zero bids
received.
0 None.
Demand Response
changes
Viable. Filed for
approval.
110 MW increase Insufficient without other
resources.
Battery storage systems Viable. Approximately 80
– 120 MW
Insufficient without other
resources.

Idaho Power issued a short-term market RFP in the spring of 2021, for delivery of power to the
Idaho Power border, and received no responses. Therefore, with existing transmission capacity
market solutions are not considered viable.

Idaho Power filed requests in 2021 to update its DR programs in Idaho and Oregon and hopes to
begin implementing the new contracts in the Spring of 2022 with an expected enrollment of 300
megawatts (“MW”) of nameplate capacity. DR program updates (as discussed in the 2021 IRP
report on pages 68-69) will contribute an anticipated 176 MW towards the peak capacity need
(compared to 66 MW for the existing program).

Idaho Power is currently in the process of investigating different configurations of Company-
owned and constructed battery storage systems. Based on evaluations to date, the Company has
identified potentially viable options ranging from approximately 80 to 120 MW. As discussed
further in the Company’s Response to Staff’s Request No. 29, the Company is proposing in its
Application in this case to make a future filing with the OPUC to request acknowledgement of any
selected resources identified through this evaluation.

Based on the information in the table above, the options discussed on pages 2-3 of the Company’s
Application are insufficient to address the deficits for 2024 and 2025 identified in the Company’s
RFP.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 9:
Related to changes in the load and resource balance described in the UM 2210 initial filing, see
IPC’s Second Amended 2019 IRP (LC 74), Appendix C, page 27. Please describe how any of the
values in the "Peak-Hour Capacity (MW)" column have changed due to IPC's LOLE and ELCC
planning methodologies.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 9:
Idaho Power adopted a reliability-based method to calculate the ELCC of variable energy
resources for the 2021 IRP. The values are calculated based on the hours of highest risk
(LOLE) rather than just the hours of highest load. The increased penetration of renewable
energy has shifted the hours of highest risk from the hours of highest load to hours that don’t
necessarily match the highest load hours. A summary of the changes and the new values used
in the load and resource balance is provided below.
Resource Type Resource MW Changes
Coal Bridger 663 Adjusted based on its EFOR*
Valmy 122 Adjusted based on its EFOR
Natural Gas Langley 306 Adjusted based on its EFOR and
temperature
Bennett Mountain 143 Adjusted based on its EFOR and
temperature
Danskin 221 Adjusted based on its EFOR and
temperature
Hydro Hells Canyon
Complex
1,060 Adjusted based on its EFOR
Run of River 295
Variable Energy
Resources
Solar 197 Updated based on its ELCC value
Jackpot 40 Updated based on its ELCC value
Wind 109 Updated based on its ELCC value
Demand Response 176 Updated based on its ELCC value
Non-Variable CSPP Cogen 163 Updated based on its ELCC value
*EFOR-Equivalent Forced Outage Rate
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: CAPACITY
STAFF’S DATA REQUEST NO. 10:
Does Idaho Power’s PURPA avoided cost values reflect the capacity shortfall used to justify both
the 2021 and the 2022 AS RFPs?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 10:
No. Idaho and Oregon rules both specify that the capacity deficiency period used in the avoided
cost calculation is updated after an Integrated Resource Plan (IRP) is acknowledged by the
respective Commission. After Public Utility Commission of Oregon (OPUC) acknowledgement of
the 2019 IRP at an April 15, 2021, Special Public Meeting, Idaho Power filed an application with
the OPUC on April 30, 2021, to update the capacity deficiency date used in its Oregon PURPA
avoided cost calculations. The Commission approved the Company’s updated PURPA rates on
June 15, 2021.
The capacity deficiency date for use in PURPA avoided cost rates is scheduled to be updated
after acknowledgment of the Company’s 2021 IRP. Because the 2021 and the 2022 AS RFPs
reflect capacity shortfalls identified in the 2021 IRP, which was filed at the end of 2021, those
capacity shortfalls are not reflected in current PURPA avoided cost values.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: LOAD
STAFF’S DATA REQUEST NO. 11:
For each calendar year, 2022 through 2026, please provide:
a. A list of forecasted load by customer rate schedule as well as a comparison with the
previously forecasted load. For example, Idaho Power notes on page 10 of the Application
that customer additions into the service area were approximately 30 percent higher than
prior expectations.
b. For industrial customers, an accompanying explanation of what exactly the Company is
relying on to forecast the potential growth in industrial customers. For reference, the
Company generally explains on Page 10 in the Application that new and existing industrial
customers have made “a sufficient and significant binding investment and/or interest
indicating a commitment of locating or expanding operations in the Company’s service
area.”
i. Particularly for the latter, what exactly is the Company relying on – media reports,
direct contact with the customers, etc.
ii. Does the Company have a system for tracking and assessing this data and, if so,
is the data shareable?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 11:
a. Please see the attached Excel file “Sales” tab showing the prior year and current year
vintage of the forecasted 2022 through 2026 sales by primary customer class. For
purposes of this analysis the Company used a forecast by primary customer class rather
than by rate schedule. The “Customers” tab of the Excel spreadsheet provides the forecast
customer additions compared with actual customer additions in 2021.
b. The Company has a direct relationship with existing and potential customers from the
moment they express interest in expansion or locating within Idaho Power’s service area.
Within the Company, relationships with new and expanding customers are managed by a
team focused on large load customers with a peak power demand greater than one
megawatt. Customer load growth or new customer load is evaluated on a case-by-case
basis and may be included in the load forecast for the following reasons: signed contracts,
financial commitments, and/or verified project expansion provided by the customer.
In addition to direct communication with existing and potential customers, the Company
also maintains strong relationships with industry experts and state and local communities
to enhance our understanding of growth trends. This information is tracked closely within
the Company but is not shareable due to proprietary customer information and/or
executed non-disclosure agreements.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: LOAD
STAFF’S DATA REQUEST NO. 12:
Regarding Table 1: Hour Load and Resource Balance:
a. If not already provided in the previous DR responses, please provide all data and analysis
used to create Table 1.
b. Please identify the peak hour referred to in Table 1.
c. Regarding part b above, during similar hours in the past, has IPC been able to make market
purchases? If no, please explain what hours, and why. If yes, please explain how the
Company was able to make market purchases during these hours.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 12:
a. The capacity deficits shown in Table 1 are from the Load and Resource Balance analysis
from the 2021 IRP. The Load and Resource Balance Data table can be found in Appendix
C: Technical Report of the 2021 IRP, pages 18-37.
b. The peak hours from Table 1 are for the peak forecasted demand hours in July 2023, July
2024, and July 2025.
c. Yes, for similar hours in the past, including the Summer 2021 peak season, Idaho Power
made market purchases to serve summer peak demand loads. Idaho Power makes these
market purchases on existing transmission connections to the Northwest mainly from the
Mid-C market. The surplus/deficit values in Table 1 are the additional peak capacity
megawatts (MW) required to meet a planning margin that already accounts for 710 MW
of transmission in 2023, 2024, and 2025. These transmission amounts are listed in the
following rows of the Load and Resource Balance table: “Available Transmission w/3rd
Party Secured” and “Emergency Transmission (CBM)”.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: LOAD
STAFF’S DATA REQUEST NO. 13:
Please provide all data and assumptions used to prepare “Table 10.7 July Peak Hour Load and
Resource Balance” on IPC's 2021 IRP page 136.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 13:
Please see the attached Excel file that contains the load and resource balance from Idaho
Power’s 2021 IRP.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: TRANSMISSION
STAFF’S DATA REQUEST NO. 14:
What day did the Company first become aware of the third-party transmission constraints? Please
describe the challenges Idaho Power encountered, and how it dealt with the constraints.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 14:
While the Company cannot point to a specific date when it became aware of third-party
transmission constraints, the Company began to recognize potential constraints following the
August 2020 energy emergency event in California. It was during this time that third-party
marketing firms began to reserve unprecedented amounts of firm transmission outside the
Company’s border, limiting Idaho Power’s access to market hubs. The transmission constraints
were fully evaluated and understood during the Valmy Unit 2 Exit Analysis. Transmission
constraints were evaluated again in preparation of the 2021 IRP in early 2021.
In response to these external challenges, Idaho Power has made long-term transmission
reservations on neighboring transmission systems (where possible) to firm up delivery from the
Mid-C market to Idaho Power. For example, Idaho Power started service in 2021 under a new
long-term transmission service reservation on Avista’s system to import energy from the
Northwest into Idaho Power’s system. This long-term firm reservation is for 100 megawatts (MW)
and service started in May 2021. Idaho Power also purchased significantly more short-term and
non-firm transmission service to import market purchases to serve load in 2021 than it had in
2020. In addition, Idaho Power has secured an additional 100 MW of long-term firm transmission
service on Avista’s transmission system that will begin service in May 2022 and an additional 80
MW of long-term firm transmission service that will begin January 2023.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: TRANSMISSION
STAFF’S DATA REQUEST NO. 15:
Page 8 of the initial filing describes that the Company “reduced the transmission availability within
the L&R balance from approximately 900 MW in the 2019 IRP to approximately 700 MW in the
2021 IRP during the peak load month of July.” Please explain what factors led the Company to
select the value used for the reduction of transmission availability (from 900 MW to 700 MW).
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 15:
The adjustment was made in response to increased transmission reservations on third party
systems between energy market hubs and the Idaho Power system. The Company adjusted its
method for determining transmission availability for serving peak loads to require a Company
reservation on third party transmission systems between market hubs and Idaho Power in addition
to the set-aside reservation of internal Idaho Power controlled transmission.
An assumption of the 2019 IRP was that generation from North Valmy could be replaced by
market purchases from southern market hubs. The Valmy Unit 2 Exit Analysis performed by the
Company early in 2021 tested this assumption. It was determined that firm transmission across
the NV Energy system to southern market hubs is not available. This was further tested by a
market Request for Proposal issued April 2021 for energy delivery during peak summer hours
2023-2025 that received no bids. The Valmy to Midpoint 345kV line has a south to north rating of
360 megawatts (MW) of which approximately 130 MW is reserved for North Valmy Unit 2. The
remaining approximate 230 MW of transmission capacity on the Valmy – Midpoint 345kV line was
removed from the available transmission counting toward peak capacity.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: DEMAND RESPONSE
STAFF’S DATA REQUEST NO. 16:
Page 5 of the initial filing explained that the L&R balance was affected by “…the ability of DR
program to meet peak load…”. Please provide workpapers that show the difference between what
the 2019 IRP projected for Demand Response programs ability to meet peak load, as compared
to Demand Response program ability to meet peak load under current assumptions based on
program changes. Please also describe drivers and forecasting assumptions leading to changes
in the Demand Response program’s ability to meet peak load.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 16:
In the 2019 Integrated Resource Plan (IRP) Idaho Power used the 380-megawatt (MW)
nameplate capacity of the demand response (DR) portfolio for the load and resource balance. For
the 2021 IRP the company implemented a reliability-based method to calculate variable
resources’ and energy-limited resources’ Effective Load Carrying Capability (ELCC)
The Company calculated the ELCC of the existing DR portfolio and found it to be 16.8% effective.
The Company then filed requests to modify the parameters of the DR portfolio to increase its
effectiveness. The filings were submitted to the Idaho Public Utilities Commission (IPC-E-21-32)
and the Public Utility Commission of Oregon (Advice No. 21-12, Docket ADV 1355).
For the 2021 IRP Idaho Power estimated that the modified 300 MW nameplate DR portfolio
(reduction due to anticipated participant attrition) would have an ELCC of approximately 59% with
the proposed changes. The 59% is equivalent to 176 MW, which is the number the Company
used for the 2021 IRP load and resource balance months of June and July.
The increased level of Variable Energy Resources (VER) is one of the main drivers for changes
to the DR programs. The high penetration of VERs results in critical hours that no longer match
peak load hours. To account for this shift, the company implemented the ELCC method.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: DEMAND RESPONSE
STAFF’S DATA REQUEST NO. 17:
What day did the Company first become aware that changes to the Demand Response program
might result in reductions in its ability to help meet peak load?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 17:
The Company first became aware that modifications to the Demand Response programs might
improve ability to meet peak load through updated Loss of Load Expectation analysis performed
for the Valmy Unit 2 Exit Analysis and in preparation of the 2021 IRP. The Company does not
have specific daily records to report which day it became aware of this finding.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: DEMAND RESPONSE
STAFF’S DATA REQUEST NO. 18:
In Docket No. ADV 1355, Idaho Power requests to change the hours of DSM programs later into
the evening to increase their ability to help meet peak net load. Please confirm that compared to
the analysis in its 2019 IRP, no decrement to the effectiveness of IPC’s DSM programs is needed
and that changes to the accounting of IPC’s DSM programs are not driving resource need. In your
response, please describe if or how the changes in hours in ADV 1355 are or are not reflected in
Idaho Power’s current capacity need.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 18:
The Company confirms in part and does not confirm in part. While the changes to the DR
programs requested in Docket No. ADV 1355 are not driving resource need, a decrement to the
peak-meeting capability of DR is required due to the use of effective load carrying capability
(“ELCC”) in the 2021 IRP.
As described in Idaho Power’s Response to Staff’s Data Request No. 16, Idaho Power used the
380-megawatt (MW) nameplate capacity of DR during the 2019 Integrated resource Plan (IRP)
for the load and resource balance. For the 2021 IRP Idaho Power implemented the reliability-
based ELCC method to calculate energy-limited and variable resource contributions to peak.
Based on this method, the current DR program has a very low ELCC due to the limitations of the
program, thus resulting in a decrement relative to the 2019 IRP. However, the DR portfolio with
updated parameters has an ELCC of 59% and assumes a 300 MW nameplate rating, and
therefore has an effectiveness of 176 MW. In other words, a decrement to the effectiveness of
Idaho Power’s DR programs is necessary relative to the 2019 IRP due to the change to the ELCC
method, but the changes to the program requested in Docket No. ADV 1355 serve to increase
the programs’ ability to serve peak load requirements.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: DEMAND RESPONSE
STAFF’S DATA REQUEST NO. 19:
In what ways has IPC considered increasing participation in its DSM programs in lieu of acquiring
more than 78 MW? Please describe.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 19:
Idaho Power analyzed increased participation of its Demand Response (DR) programs as an
option to replace Valmy Unit 2 capacity through the Valmy Unit 2 Exit Analysis study. Through
the study it was determined retaining Valmy Unit 2 through 2025 was more economic than
expanding DR programs.
Expansion of the DR program was also included as a selectable resource as part of the 2021 IRP
process. A maximum of approximately 280 megawatts (MW) of additional DR above an assumed
level of 300 MW (the anticipated nameplate from existing programs, once the proposed
modifications are taken into account) was available for selection in the AURORA model. The
additional DR capacity was divided into 20 MW bundles for possible selection. The 2021 IRP
preferred portfolio includes 20 MW bundle additions in 2023 and 2025 as well as 60 MW towards
the end of the 20-year IRP timeframe.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: JACKPOT SOLAR
STAFF’S DATA REQUEST NO. 20:
Page 5, footnote 5 of the initial filing explained that Jackpot Solar is anticipating a delay from the
current scheduled operation date.
a. What day did the Company first become aware of the potential delay?
b. Does the Company anticipate Jackpot Solar coming online on, or after the December 1,
2022? Is the company planning for a situation in which Jackpot Solar does not come online
at all?
c. Please describe how Table 1: Peak-Hour Load and Resource Balance includes, or does not
include Jackpot Solar.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 20:
a. Idaho Power received a letter from Jackpot Holdings, LLC (“Jackpot”) dated November 9,
2021, notifying Idaho Power of what Jackpot deems a Force Majeure event related to the
“Global Supply Chain Disruption” and indicating potential impacts to the project schedule.
Idaho Power and Jackpot have continued to discuss and exchange correspondence
regarding the potential delay; however, based on the information provided by Jackpot to
date, Idaho Power has not accepted Jackpot’s characterization of this circumstance as a
Force Majeure event nor agreed to extend the Scheduled Commercial Operation Date in
the Power Purchase Agreement (“PPA”).
b. The Scheduled Commercial Operation Date in the PPA remains December 1, 2022, and
Jackpot currently anticipates a 40-day delay in project completion. The PPA requires
Seller to pay Delay Damages if the project does not achieve commercial operation by the
Scheduled Commercial Operation Date.
Idaho Power anticipates Jackpot Solar coming online on or after December 1, 2022. Idaho
Power’s Integrated Resource Plan and current and forthcoming Request for Proposals
assume Jackpot Solar will be online as of the current Scheduled Commercial Operation
Date of December 1, 2022. Idaho Power does not anticipate, in either its Integrated
Resource Plan or its RFP processes, a situation in which Jackpot Solar does not come
online at all. Idaho Power will continue to monitor the situation to determine if any
additional resource or procurement actions are necessary.
c. Table 1 includes Jackpot Solar coming online as of its Scheduled Commercial Operation
Date.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 21:
Page 10 of the Application explains that “the RFP evaluation team developed detailed criteria and
a methodology for evaluating both price and qualitative attributes of a proposed resource.” Please
explain the specific steps and considerations the evaluation team used to develop the detailed
criteria and methodology. Was it modeled off of another RFP? In addition, please describe how
stakeholders were engaged in the process.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 21:
The steps and considerations to develop the detailed criteria and methodology within the 2021 All
Source Request for Proposal (“RFP”) were determined by comparing similar request for proposals
as well as the prior experience of Black & Veatch Management Consultants, LLC (“Black &
Veatch”) with large scale power procurement processes. The primary steps and considerations
included, but were not limited to, the following:  examination of other recent request for proposals for similar products including, among
others, the Public Service of Colorado 2021 Company Ownership RFP, the PacifiCorp
2020 All Source RFP, the Puget Sound Energy 2021 All Source RFP, and the CPS Energy
FlexPower Bundle RFP;  identification of the characteristics of the products needed including technology type,
ownership structure, term, first delivery date, resource status, design life, capacity,
interconnection, and point of delivery;  identification of the breadth and depth of the evaluations needed to support decision-
making for large power supply commitments, including quantitative (production cost
simulation) and qualitative (multi-factor review by subject matter experts) aspects;  development of the detailed factors included in the RFP within the qualitative categories
of Project Feasibility, Project Capability, Counterparty Profile, Community Stewardship;  identification of the time available to successfully perform the solicitation working
backwards from the capacity need dates including time for resource construction,
development, regulatory approval and post-solicitation negotiations.
Section 3. Product Specifications of the RFP highlight the desired product specifications and
Exhibit A and Exhibit B of the RFP detail the factors and categories that proposals should include
to allow Idaho Power to evaluate each proposal.
Given the expedited timeframe Idaho Power required to develop and solicit the RFP, the steps
identified above were completed solely by Idaho Power and Black & Veatch Management
Consultants, LLC.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 22:
Page 11 of the Application states “Idaho Power used an objective scoring methodology that
reasonably evaluated the price and non-price attributes of each bid...”
a. Please explain why Idaho Power thinks the scoring methodology was objective.
b. What Idaho Power does mean by stating that the price and non-price attributes of each bid
were “reasonably evaluated.”
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 22:
a. With respect to qualitative evaluation based on thirty-seven unique factors included in the
2021 All Source Request for Proposal (“RFP”) and the Proposal Entry Form, the scoring
methodology was objective because 1) the rating criteria for each factor were determined
before proposals were received and not changed thereafter; 2) the subject matter expert
staff performing the qualitative evaluation performed their respective evaluation
independent of quantitative evaluation to avoid the situation of a qualitative evaluator
becoming biased for or against a particular proposal due to its evaluated cost, and; 3) after
scoring was completed, the scores were reviewed and evaluation scores that were outliers
were questioned and re-scored and calibrated to ensure consistent application of scores
and rating criteria. The unique factors were detailed in Exhibit A of the RFP. Additionally,
respondents could provide additional information to Idaho Power if they desired to clarify or
support their proposal.
b. ”Reasonably evaluated” means, with respect to qualitative evaluation, that the method of
allowing qualitative evaluators to independently utilize their subject matter expertise while
being constrained to follow the rating criteria guidance and be subject to calibration resulted
in a reasonable balance between individual expertise and group consensus and therefore
reasonable evaluation results. With respect to quantitative evaluation, it means that use of
a consistent common evaluation tool (AURORA) and consistent common assumptions in
that tool resulted in reasonable evaluation results.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 23:
In Idaho Power’s opinion, was the scoring reasonably subject to self-scoring by bidders? Why or
why not?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 23:
Idaho Power did not choose an approach of requesting bidders to perform self-scoring. However,
the evaluation factors were clearly defined in the 2021 All Source Request for Proposal (“RFP”)
in Exhibit A and the Proposal Entry Form such that respondents could clearly understand the
intent of the RFP. Furthermore, Section 3. Product Specifications outlines the products and
significant terms desired by Idaho Power. Idaho Power believes the internal evaluation with
prescribed criteria better serves the objective of identifying proposals that fit the needs specified
in the RFP.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 24:
Page 11 of the Application states that Idaho Power utilized the third-party expertise of Black &
Veatch Management Consulting, LLC, to assist in the development of the RFP and the bid
evaluation process.
a. Please explain how exactly Black & Veatch Management Consulting, LLC helped with the
development of the bid and evaluation process.
b. Please explain whether and how Black and Veatch Management Consulting, LLC
participated in the actual bid evaluation process.
c. Please provide a copy of the contract with Black and Veatch Management Consulting, LLC
to support development the 2022 RFP.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 24:
a. Black & Veatch Management Consulting, LLC (“Black & Veatch”) helped develop the 2021
All Source Request for Proposals (“RFP”) and its exhibits, supported issuance of the RFP,
and designed and administered the evaluation processes. Idaho Power utilized Black &
Veatch’s consulting expertise in developing the RFP requirements and requests, and Black
& Veatch’s experience in designing and administering the RFP and evaluation processes.
Black & Veatch provided scheduling, editing, process development, and the tools to conduct
evaluations. Black & Veatch further assisted Idaho Power in the consolidation and
integration of final evaluations, to the extent identified evaluators were only able to rank
specific criteria as subject matter experts and were not provided transparency into the
scoring matrix, and overall weighting of individual factors.
b. Black & Veatch did not participate in the actual bid evaluation process. Black & Veatch
administered the bid evaluation process, including proposal data processing, evaluation
training, rating collection, score compilation, proposal ranking, and other necessary
summary and reporting tasks. Black & Veatch also supported responding to bidders’
questions regarding the RFP content and Idaho Power evaluators’ questions regarding
evaluation processes, factors and criteria.
c. A confidential copy of the executed contract with Black & Veatch is attached to this
Response.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 25:
Page 20 of Attachment 1 (the 2021 RFP) explains that Idaho Power reserves the right to “Appoint
evaluation committees to review proposals, seek the assistance of outside technical experts and
consultants in proposal evaluation, and seek or obtain data from any source that has the potential
to improve the understanding and evaluation of the responses to this RFP.” Did Idaho Power
exercise any of these options in the 2021 RFP process? Why or why not? And, if so, how did it
do so?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 25:
Idaho Power was supported by Black & Veatch Management Consultants, LLC as described in
Idaho Power’s response to Data Request No. 24.
Idaho Power assigned an internal committee of subject matter experts to review and score each
of the thirty-seven factors defined in Exhibit A of the 2021 All Source Request for Proposals and
the Proposal Entry Form during the qualitative evaluation process. Committee members were
assigned specific evaluation factors and criteria related to their knowledge of the factor subject
matter. Committee members did not have transparency into the overall qualitative evaluation or
how the scoring of each ranking affected the overall qualitative evaluation.
Idaho Power sought external counsel from Baker Botts LLP in development of Exhibit E – Draft
Form Term Sheet.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 26:
Page 14 of the Application states that “the 2021 RFP was well received by the market and solicited
numerous eligible bids.”
a. Please explain how the Company determined the RFP was “well received” by the market.
b. Did the Company solicit feedback on the RFP and if so, please provide any and all available
feedback the company received.
c. How many eligible bids did the company receive?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 26:
a. Idaho Power issued a public Notice of Intent (“NOI”) on May 21, 2021. Idaho Power
posted the NOI to https://www.idahopower.com/about-us/doing-business-with-us/request-
for-resources/, issued a press release and the NOI to multiple media outlets, and directly
e-mailed the NOI to approximately eighty developers (the list of developers was comprised
of developers currently in the Idaho Power Generation Interconnection Queue as well as
market research of potential developers) to reach as many potential respondents as
possible. Thirty-eight developers responded to the Notice of Intent identifying
approximately seventy separate potential proposals by registering within the sourcing
platform in PowerAdvocate requesting to receive the 2021 All Source Request for
Proposals (“RFP”) directly when released. During the solicitation, Idaho Power received
twenty-five questions from developers and responded accordingly. In Idaho Power’s
opinion, the number of developers that registered and engaged during the RFP solicitation
suggests the RFP was well received.
b. No direct feedback was solicited or received from respondents, only anecdotal information
through conversation and negotiation. This anecdotal information was used to further
refine and improve the 2022 All Source Request for Proposal.
c. Idaho Power received fourteen project proposals from eleven different developers
spanning a variety of product types. Six of these proposals were screened during the initial
threshold screen as either incomplete or not meeting the solicitation criteria.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 27:
Was there a benchmark resource involved in the 2021 RFP? If so:
a. Was any additional scrutiny provided to that bid? If so, please describe. If not, please explain
why not.
b. Did the benchmark resource rely on any utility-owned or controlled assets? If so, were those
made available to other bidders?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 27:
Idaho Power did not explicitly include a benchmark resource in the 2021 All Source Request for
Proposals (“RFP”) due to time constraints in developing a benchmark resource to include as
part of the RFP. Instead, Idaho Power relied on developers to propose potential projects that
would meet the criteria outlined in the RFP.
Idaho Power is simultaneously pursuing a self-build battery energy storage solution. As stated
in the application on page 2:
“Idaho Power is also, in parallel, investigating different configurations of Company
owned and constructed battery energy storage systems…”
Idaho Power informally evaluated price and project reasonableness of the self-build options
against information obtained from the 2021 RFP
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 28:
It appears that contract term sheets were provided to bidders to redline. Were actual form
contracts also provided? If so, when? If not, please explain why not.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 28:
Form contracts were not available at the time of the solicitation of the 2021 All Source Request
for Proposal. Rather, a term sheet with significant and applicable terms was provided as Exhibit
E – Draft Form Term Sheet that would influence a Build Transfer Agreement. Respondents were
directed to provide redline responses to Exhibit E. A form Build Transfer Agreement contract was
provided to three shortlisted respondents on October 15, 2021. The Form Build Transfer
Agreement contract was modeled after the draft form term sheet. A form Power Purchase
Agreement was provided to two shortlisted respondents on October 20, 2021.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 29:
The Company explains that the CPCN includes discussion of the basis for the selection of the
chosen resource(s). Please describe this CPCN process. Please also explain whether IRP
modeling is used, and whether sensitivities are provided – e.g. looking at the procurement under
a low market price scenario.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 29:
As described in the application, under Idaho law, a Certificate of Public Convenience and
Necessity (CPCN) is required for the utility to construct a new generation resource or plant.
Granting a CPCN does not constitute ratemaking treatment; instead, it reflects a finding by the
IPUC that the relevant resource is needed to provide safe and reliable service. The CPCN process
provides a broad mechanism for considerable regulatory oversight into the procurement process.
The Company’s proposed filing would include an overview of the resource procurement process,
identify the selected resource(s), and explain the basis for the selection of the chosen resource(s).
Substantively, Idaho Power’s proposed filing would include generally the same material that would
be included in a request for acknowledgment of the RFP shortlist contemplated by the CBRs.
Idaho Power would request acknowledgment of the selected resource(s) based on the
reasonableness of the Company’s selection in light of the information available at the time of
acknowledgment. The filing would provide a contemporaneous opportunity for Commission and
stakeholder review of the RFP process and results, rather than waiting until the Company
requests to include the selected resource(s) in rates through a general rate case or other revenue
requirement proceeding.
The Company uses AURORA modeling similar to that used to develop a preferred portfolio in the
IRP to evaluate ids received in the RFP, but this modeling does not include multiple sensitivities
such as a low-market price scenario.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 30:
Please provide the timeline of all of the steps for the 2021 RFP from development of the RFP
through the CPCN. Include in your response the following:
a. Please describe how the 2022 RFP timeline differs from the 2021 RFP.
b. What is the shortest resource procurement timeline Idaho Power currently thinks is possible
for the 2022 RFP.
c. What is the longest timeline Idaho Power currently thinks is possible for the 2022 RFP?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 30:
Idaho Power began preparation of the 2021 All Source Request for Proposals (“RFP”) in May
2021 after identifying a capacity deficit beginning in June 2023. The following is a timeline of key
steps of the RFP:  March 2021 – Idaho Power began updating load and resource balance assumptions for
Valmy unit 2 exit date evaluation and the 2021 Integrated Resource Plan (IRP). Based on
potential reductions in transmission import capacity and demand response program
effectiveness relative to Idaho Power’s 2019 I RP, Idaho Power identified a potential deficit
beginning in June 2023. Idaho Power began discussions on how to address potential 2023
deficits.  April 2021 – Idaho Power further vets assumptions leading to potential resource deficit.
Idaho Power begins process of hiring consultant to help facilitate RFP process.  May 2021 – Idaho Power, based on the information at the time, identified an approximate
seventy-eight (78) megawatt capacity deficit beginning June 2023.  May 12, 2021 – Idaho Power executed a contract with Black & Veatch Management
Consultants, LLC to support development and solicitation of the RFP.  May 21, 2021 – Idaho Power released a Notice of Intent to notify interested developers
that an RFP would be forthcoming.  June 30, 2021 – Idaho Power released the RFP to developers who responded to the
Notice of Intent with an Intent to Bid as well as posted publicly on Idaho Power’s webpage.  August 11, 2021 – Respondent proposal due date.  September 2021 – Idaho Power conducted a series of threshold screening, qualitative,
and quantitative evaluation of submitted proposals.  October 2021 – Idaho Power began negotiations with shortlisted respondents.  December 2021 – January 2022 – Idaho Power continues contract negotiations with a
single respondent with anticipated contract execution in January 2022.  February 2022 – Potential CPCN filings.  June 2022 – Regulatory approval required by this date before potentially delaying 2023
operation date for new resources.
a. The 2022 All Source Request for Proposals (“2022 RFP”) timeline and steps are
substantively similar to the 2021 RFP. Idaho Power began preparing the 2022 RFP in
November 2021, issued a Notice of Intent on December 10, 2021, and released the 2022
RFP solicitation on December 30, 2021, the same day Idaho Power filed the 2021 IRP.
Consistent with the 2021 IRP, the 2022 RFP is seeking resources to achieve commercial
operation in either June 2024 or June 2025.
b. Idaho Power is confident that its efforts to solicit the 2022 RFP at the end of December
2021 will allow resources to achieve commercial operation by June of 2024. Critical dates
are outlined in section 2.6 Schedule in the 2022 RFP to ensure expedited evaluation and
contract negotiation to support this aggressive schedule.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
c. The 2022 RFP contemplates resources to support Idaho Power needs in both 2024 and
2025 and is confident respondents will provide timelines that support the longest
duration to meet June 2025 commercial operation.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 31:
The Company’s website related to the 2022 AS RFP, under the section regarding the Notice of
Intent Questions and Answers indicates that battery storage projects must ultimately transfer
ownership to the utility. Please explain:
a. Why the company believes this is a reasonable requirement.
b. Why this requirement is in the interest of rate payers?
c. How does this requirement not create vertical and horizontal market power.
d. How this requirement fairly treats third-party developers of storage, per ORS 757.646 (2)(b).
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 31:
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.
Idaho Power objects to subparts (c) and (d) because the requests seeks legal analysis and opinions related to the interpretation and application of ORS 757.646 to Idaho Power. Without waiving this objection, Idaho Power responds that ORS 757.646 does not apply to the Company. See ORS 757.601(3).
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 32:
The Company distributed an email regarding the Notice of Intent on December 22, 2021. Please
provide the distribution list to whom this email was sent, indicate which of the recipients were
participants in the 2021 AS RFP.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 32:
It is important to note that the December 22, 2021, Notice of Intent email was sent as a reminder
email and contained Questions and Answers to the December 10, 2021, Notice of Intent.
The December 10, 2021 Notice of Intent email was sent to the distribution list below after the
Notice of Intent was posted to idahopower.com and Idaho Power issued a news release to trade
media outlets (also included below). This distribution list was created based on the interested
parties that submitted an Intent to Bid from Idaho Power’s 2021 Notice of Intent.
December 10, 2021 Notice of Intent: Media Outlets
Media Outlet or Organization Contact
Clearing Up: [e-mail]
[e-mail]
Energy Central: [e-mail]
National Hydro Association:[e-mail];
Northwest Hydro Association: [e-mail]
SP Global: [e-mail]
Freelance energy reporter (formerly with
SP Global):
[e-mail]
Industry Dive: [e-mail]
Transmission Hub: Jeff Postelwait
[e-mail];
Nikki Chandler
[e-mail];
Idaho Office of Energy and Mineral
Resources:
[e-mail],
[e-mail]
Public Utility Commission of Oregon:[e-mail];
[e-mail];
[e-mail]
Idaho Public Utilities Commission: [e-mail];
[e-mail];
[e-mail];
[e-mail]
December 10, 2021, and December 22, 2021, Notice of Intent: distribution list:
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
Project Company Contact Phone Email
Ormat Nevada, Inc. Alora Bartosz 775-356-9029
ext. 32307
[e-mail]
Rathdrum Power, LLC Andrew
Argetsinger
913-754-5732 [e-mail]
Black Mesa Energy LLC Brian Lynch 310.750.7796 [e-mail]
Frederickson Power LP Champe Fisher 617-977-2498 [e-mail]
GlidePath Development LLC Chris Vickery 312-513-8033 [e-mail]
Telocaset Wind Power Partners,
LLC
Christopher
Baxter
Angela Shen
713-430-6682
832-887-2168
[e-mail]
[e-mail]
Bear Lake Solar, LLC (Specific LLC to
be created
Collin Thomas 503-327-3649 [e-mail]
[Jackalope Project Company], LLC Daniel Handal 561-289-7115 [e-mail]
Brad Thompson Energy Company
LLC (Note-1)
Dave Salem 206-619-3920 [e-mail]
Obsidian Renewables, LLC David Brown 503-310-3669 [e-mail]
NuDay Partners Inc David Davis 801-597-4474 [e-mail]
Hawaii Land and Power Corp David T. Berryhill 808-724-3080 davidtberryhill@hawaiilandandpowerco
rp.com
NaturEner Glacier Wind Energy 1,
LLC
Dwayne Howard 561-944-6139 [e-mail]
Wartsila North America Inc. F. Gregory Hall 208-440-8484 [e-mail]
Appaloosa Wind and Solar LLC Garth Klimchuk 914-320-2974 [e-mail]
Enbala Power Networks (USA) LLC Graham Horn 604-641-2877 [e-mail]
Archway Solar Energy LLC Greg Leuchtman
Heidi Aschbacher
Sam Bernat
720-283-4694
312-582-1740
[e-mail]
OnPeak Power, LLC (Bells Rapids) Ingmar Sterzing 512-284-1922 [e-mail]
Cat Creek Energy & Water
Company, LLC
James Carkulis 406-459-3013 [e-mail]
Clenera on behalf of Parasol REH Jeremy Kuhre 817-846-9773 [e-mail]
KitzWorks LLC Kevin Kitz 208-761-3442 [e-mail]
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
Project Company Contact Phone Email
Applied Metering Technologies, Inc Kevin Lee 949-202-7312 [e-mail]
Obsidian Renewables, LLC Laurie
Hutchinson
503-488-6153 [e-mail]
Co-Gen Co, LLC Levi Huffman 541-874-2231 [e-mail]
Pleasant Valley Solar, LLC Luigi Resta 415-602-2569 [e-mail]
Form Energy, Inc Marco Ferrara 617-510-1129 [e-mail]
Great Basin Transmission, LLC Mark Strength 636-534-3236 [e-mail]
Able Grid Development Holdings,
LLC
Mark
Tourangeau
801-678-9346 [e-mail]
EDF Renewables Matthew Beltz 215-407-9132 [e-mail]
Eavor Inc Niel Ethier
James Jackson
403-998-1771
210-497-3715
[e-mail]
[e-mail]
Mitsubishi Power Americas, Inc Peter Sawicki 619-890-6502 [e-mail]
esVolta, LP Peter Zullo 415-610-1046 [e-mail]
Longroad Development Company Sam Johnson 339-222-1903 [e-mail]
Fresh Air Energy II, LLC Scott Piscitello 503-467-8355 [e-mail]
Franklin Solar Project, LLC Teresa Kanter 704-390-3321 [e-mail]
ARB Inc. Wayne Truchan 949-697-3224 [e-mail]
[e-mail]
Centered Enterprise, Inc Young S Ong 213-785-4800 [e-mail]
Sole Trader Renewable Energy LLC Kevin Butler 901-628-6541 [e-mail]
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 33:
In the December 22, 2021 Notice of intent, respondents were instructed to reply by 5:00 PM on
December 23, 2021. Please explain how the Company is accommodating a fair and competitive
process with potential applicants being given at most two days to respond to the request.
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 33:
Idaho Power publicly published, as well as directly distributed to developer contacts, a Notice of
Intent regarding the 2022 All Source Request for Proposal (“2022 RFP”) on December 10, 2021,
requesting that parties interested in receiving the 2022 RFP solicitation register in the sourcing
portal by December 23, 2021. This timeline provided adequate time for potential respondents to
register and ensure they received the 2022 RFP solicitation on December 30, 2021. The
December 22, 2021, notification was simply a reminder to interested parties of the pending
deadline. Additionally, potential respondents can register and submit a proposal anytime up to
the proposal due date of March 20, 2022.
PROTECTED INFORMATION UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36

TOPIC OR KEYWORD: RFP PROCESS

STAFF’S DATA REQUEST NO. 34:

Which recipients replied to the Notice of Intent sent on December 22, 2021?

IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 34:

SEE CONFIDENTIAL ATTACHMENT TO RESPONSE No. 1
UM 2210 – Response to Staff DR 34-35

As previously stated, a formal Notice of Intent was issued on December 10, 2021. The following
recipients have responded by submitting an Intent to Bid Form. (Note: List of Respondents include
Parties that have submitted a Formal Intent to Bid Form as of January 17, 2022. Idaho Power’s
methodology is inclusionary and all interested parties are able to participate in the 2022 All Source
Request for Proposals to the extent Idaho Power would not have to extend the deadline for
proposal submittals, due to critical deficit need.)

List of Respondents (as of January 17, 2022)

Northrenew Energy LLC
esVolta, LP
Mitsubishi Power Americas
Black Mesa Energy LLC
Fresh Air Energy II, LLC
Bird Dog Development, LLC
Longroad Development Company, LLC
Franklin Solar, LLC
Clearway Renew LLC
Tyr Energy, Inc
Wärtsilä
Wheeler Machinery Co.
Aypa Power Development LLC
Able Grid Infrastructure Holdings, LLC
National Grid Renewables Development, LLC
Ormat Nevada, Inc
Invenergy
Oriden LLC (Mitsubishi Power Americas Inc.)
rPlus Energies
Clenera DevCo, LLC
Sunverge Energy, Inc
Garden of Eden Energy LLC
Plus Power, LLC
Siemens Energy
Idaho Power Co. - Power Supply
Eavor Inc.
Mesa Natural Gas Solutions
EDF Renewables
PROTECTED INFORMATION UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36

Sole Trader
NextEra Energy Resources Development, LLC
Bear Lake Solar
Energy Vault, Inc
Magic Valley Energy, LLC
JUGU BN, LLC
Applied Metering Technologies
Ormat
Hecate Energy Populus Solar LLC
Cat Creek Energy LLC
Scout Clean Energy, LLC

PROTECTED INFORMATION UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36

TOPIC OR KEYWORD: RFP PROCESS

STAFF’S DATA REQUEST NO. 35:

For each response to the December 2, 2021 NOI, please provide the project details from each
respondent, including size, technology, LGIA status, location, and ownership structure. Please
explain whether a respondent, a proposed project, or project site was included in the 2021 RFP.

IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 35:

SEE CONFIDENTIAL ATTACHMENT TO RESPONSE No. 1
UM 2210 – Response to Staff DR 34-35

It is Idaho Power’s assumption that this request is in reference to the December 10, 2021, Notice
of Intent and the subsequent follow up email stating Questions and Answers sent to recipients on
December 22, 2021.

Below is the respondent list, associated project information, and any alternative project
information as submitted by respondents; including but not limited to project details, size,
technology, location, ownership structure additional comments as provided by respondents.
(Note: If fields below are blank, that indicated respondent did not submit information in the related
field.) All of the below respondents have been included in Idaho Power’s 2022 All Source Request
for Proposals (“2022 RFP”) as of January 17, 2022. It is Idaho Power’s intent to be inclusionary
with this solicitation and future respondents may be added to the 2022 RFP, to the extent the
deadline for submittals is preserved.

UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 1-36
TOPIC OR KEYWORD: RFP PROCESS
STAFF’S DATA REQUEST NO. 36:
Please explain why did the additional capacity shortfall articulated in UM 2210 is being addressed
in a separate 2022 RFP rather than in an expansion of the 2021 RFP?
IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 36:
The 2021 All Source Request for Proposals (“RFP”) was solicited on an expedited timeframe
specifically requesting responses to satisfy identified capacity needs in 2023 only. In May 2021
Idaho Power was in the early stages of an Integrated Resource Plan process with evolving
planning assumptions at the time, so Idaho Power chose to focus near-term attention to the most
critical needs. Idaho Power believed that the 2022 All Source Request for Proposal (“2022 RFP”)
would be best solicited after the 2021 Integrated Resource Plan (“2021 IRP”) was completed and
resource needs were certain.
UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 37

TOPIC OR KEYWORD: ONGOING REQUESTS

STAFF’S DATA REQUEST NO. 37:

Please provide both the request and the Company’s response to all production requests, audit
requests, data requests, and other interrogatories issued to the Company in Idaho PUC docket
IPC E-21-41. This is an ongoing request.

IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 37:

Idaho Power received the attached First Production Request of the Commission Staff to Idaho
Power from the Idaho Public Utilities Commission Staff in Case No. IPC-E-21-41 on January 13,
2022. Responses are due February 3, 2022.

Idaho Power received the attached First Set of Interrogatories to Idaho Power Company from
IdaHydro on in Case No. IPC-E-21-41 on January 21, 2022. Responses are due February 11,
2022.

All such requests and responses will be provided to participants in this Oregon docket when the
responses are filed in the Idaho docket.

UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 38-39

TOPIC OR KEYWORD: RFP

STAFF’S DATA REQUEST NO. 38:

Page 1, line 18 of the initial filing states that in May of 2021 the company updated its L&R balance
and identified a 78 MW capacity deficit starting in “June 2023, growing each year through 2026…”.
Page 2, lines 14 – 20 then states that the Company issued an RFP for 80 MW to meet the 2023
capacity deficit. If the capacity deficit was projected to increase in each year through 2026, please
explain why the company did not issue a larger 2021 RFP that could have addressed the growing
capacity deficit identified at that time?

IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 38:

The following is as stated in Idaho Power’s response to Data Request No. 36 and is the same
response.

The 2021 All Source Request for Proposals (“RFP”) was solicited on an expedited timeframe
specifically requesting responses to satisfy identified capacity needs in 2023 only. In May 2021
Idaho Power was in the early stages of an Integrated Resource Plan process with evolving
planning assumptions at the time, so Idaho Power chose to focus near-term attention to the most
critical needs. Idaho Power believed that the 2022 All Source Request for Proposal (“2022 RFP”)
would be best solicited after the 2021 Integrated Resource Plan (“2021 IRP”) was completed and
resource needs were more certain.

UM 2210
Idaho Power Company’s Responses to Staff
Data Request Nos. 38-39

TOPIC OR KEYWORD: RFP

STAFF’S DATA REQUEST NO. 39:

Page 2, lines 3 – 11 of the initial filing describes multiple factors that contribute to the forecasted
capacity deficit. Please provide a worksheet that includes each of the described factors impacting
capacity, including the scale of the impact in MW, the start date of the anticipated deficit, and the
date when the Company became aware of the deficit. Please also include which factors
contributed to the issuance of the 2021 RFP verses the 2022 RFP.

IDAHO POWER COMPANY’S RESPONSE TO STAFF’S DATA REQUEST NO. 39:

Please see the attached Excel file comparing the Load and Resource Balance capacity
assumptions between the 2019 second amended Integrated Resource Plan (IRP) with the 2021
IRP for July 2023. The workbook includes the factors described on Page 2, lines 3 -11 and the
scale of impact in MW. The two primary factors impacting capacity between the IRPs are changes
to the capacity assumptions for demand response and market purchases.

The complete load and resource balance workbook from the Idaho Power 2021 IRP analysis is
attached to Data Request No. 13. This workbook includes the capacity surplus / deficit for each
month in the IRP planning horizon. As described in Data Request No. 7, Idaho Power became
aware of a capacity deficit during the Valmy Unit 2 Exit Analysis performed early in 2021. The
company does not have specific daily records to report which date it became aware of this finding.

The same factors contributed to both RFP issuances. Anticipated capacity deficits identified for
the 2023 summer peak season led to the issuance of the 2021 RFP. Given resource lead times,
the nearer term deficit in 2023 required that the RFP be issued in 2021 rather than waiting for the
2022 RFP. The 2022 RFP was issued to address deficits starting in 2024.