20220720IPC to Staff 22-27-Redacted.pdf

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DONOVAN WALKER
Lead Counsel
dwalker@ida hopower.com
July 20, 2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
1 1331 W. Chinden Blvd., Bldg 8,
Suite 2O1-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re Case No. IPC-E-22-13
ln the Matter of ldaho Power Company's Application for a Certificate of
Public Convenience and Necessity to Acquire Resources to be Online by
20231o Secure Adequate and Reliable Service to its Customers
Dear Ms. Noriyuki:
Attached for electronic filing please find ldaho Power Company's Response to the
Second Production Request of the Commission Staff in the above matter.
The confidential version will be provided to those parties who have executed the
Protective Agreement in this matter.
Please feel free to contact me directly with any questions you might have about
this filing.
Very truly yours,
fuzdd!4
Donovan E. Walker
DEW:sg
Enclosures
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
122'l West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker@ idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVEN!ENCE
AND NECESSIW TO ACQUIRE
RESOURCES TO BE ONLINE BY 2023 TO
SECURE ADEQUATE AND RELIABLE
SERVICE TO ITS CUSTOMERS.
CASE NO. IPC-E-22-13
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
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COMES NOW, ldaho Power Company ("ldaho Power" or'Company'), and in
response to the Second Production Request of the Commission Staff ("IPUC or
Commission') dated June 29, 2022, herewith submits the following information:
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
REQUEST FOR PRODUCTION NO. 22: Please explain whether the 40MW BESS
co-located at the 40 MW solar PV generation facility at Black Mesa can be charged
directly from the grid.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Yes, the 40 megawatts
('MW) Battery Energy Storage System ('BESS') can be charged directly from the grid
when needed for operational benefits; however, it will primarily be charged directly from
the solar photovoltaic ("P\f) system for at Ieast the first five years of operation to
maximize federal investment tax credits ("lTC").
The response to this Request is sponsored by Eric Hackett, Senior Manager
Projects and Design, Idaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO.23: Please provide the following information
related to the 80 MW stand-alone battery storage facility potentially installed at the
Hemmingway substation :
a. A detailed listing of all remaining costs outside the BESS contract required
to complete the battery storage facility.
b. Company analysis detailing the annualized Operations and Maintenance
("O&M') costs expected over the life of the battery storage facility.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23:
a. ldaho Power is in the process of negotiating some of the agreements
necessary for the development and construction of the 80 MW BESS but
estimates the remaining costs to be approximately The
following table provides engineering estimates for completion of the 80 MW
BESS installation:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
Project Management, Engineering, Design,
Construction Management, Permitting, and
Genera! Administration
Civil Construction, Site Work, Underground
Conduit and Grounding, Fencing, Concrete
Foundations
Electrical Construction
BESS lnstallation
Testing and Commissioning
ldaho Power lnterconnection Facilities
TOTAL
b. Depending on the final scope of the Long-Term Service Agreement
('LTSA') ldaho Power is currently negotiating with Powin Energy
Corporation ("Powin") and the services and prices negotiated forthe 80 MW
BESS, the estimated Ievelized payment ranges from approximately
, as shown below:
LTSA
Property Tax/lnsurance
Total Levelized Payment
The response to this Request is sponsored by Eric Hackett, Senior Manager
Projects and Design, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISS]ON STAFF - 4
REQUEST FOR PRODUCTION NO.24: Please provide the following information
related to the 40MW BESS co-located at the 40 MW solar PV generation facility at Black
Mesa:
a. A detailed listing of all remaining costs outside the BESS contract required to
complete the battery storage facility.
b. Company analysis detailing the annualized O&M costs expected over the life
of the battery storage facility.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24:
a. ldaho Power is in the process of negotiating some of the agreements necessary
for the development and construction of the 40 MW BESS but estimates the
remaining costs to be approximately The following table
provides engineering estimates for completion of the 40 MW BESS installation
Project Management, Engineering, Design,
Construction Management, Permitting, and
General Administration
Givil Construction, Site Work, Underground
Conduit and Grounding, Fencing, Concrete
Foundations
Electrical Construction
BESS lnstallation
Testing and Commissioning
BESS Assignment and Assumption
TOTAL
IDAHO PO\A/ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
b. Depending on the final scope of the LTSA ldaho Power is currently negotiating
with Powin and the services and prices negotiated for the 40 MW BESS, the
estimated levelized payment ranges from approximate
as shown below.
LTSA
Property Tax/lnsurance
Total Levelized Payment
The response to this Request is sponsored by Eric Hackett, Senior Manager
Projects and Design, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF .6
REQUEST FOR PRODUGTION NO. 25: Does the Company plan to entera Long-
Term Service Agreement with the contracted BESS supplier to maintain the stated
capacity for the two facilities? lf so, what is the duration of the agreement and the yearly
cost for each facility? lf not, please explain the Company's approach to maintaining the
two facilities and the expected costs.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25: Yes. ldaho Power is
currently negotiating an LTSA with Powin in which quarterly and annual preventative
maintenance, warranty work, performance monitoring, and other services will be
performed. Depending on the scope of services, the price may range from
per megawatt of nameplate capacity annually. The Company does not anticipate the
LTSA will include capacity management augmentation. Rather, ldaho Power will likely
augment the BESS as needed in the future based on operational needs. The BESS is
sized at beginning of life such that augmentation would not be needed until year six or
later based on 365 cycles per year.
The duration of the agreement has not yet been determined. Once finalized, ldaho
Power will evaluate the costs associated with outsourcing the maintenance, performing
maintenance in-house using Company personnel, or a combination of both, determining
the most cost-effective option for maintenance of the BESS.
The response to this Request is sponsored by Eric Hackett, Senior Manager
Projects and Design, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REOUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 26: Are federal tax credits available for the
40MW BESS co-located at the 40 MW solar PV generation facility at Black Mesa? If so,
please provide Company analysis showing the value of the tax credits over the life of the
facility. lf not, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26: Yes, the 40 MW BESS
will benefit from the federal investment tax credit. The 40 MW BESS will be integrally
connected to the Black Mesa solar PV generation project and will be charged by the solar
project to the greatest extent possible for the first five years of BESS operations to
maximize the federal tax credits. The project is estimated to provide
credits to be amortized over of the life of the asset.
of tax
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader, ldaho Power Company.
IDAHO POVVER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF. S
REQUEST FOR PRODUCTION NO. 27: Are federal tax credits available for the
80MW BESS facility potentially installed at the Hemmingway substation? lf so, please
provide Company analysis showing the value of the tax credits over the life of the facility.
lf not, please explain why.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: There are currently no
federaltax credits available for the 80 MW BESS facility as current federal tax credits are
only availabb for solar and other qualiffing renewable projects. The ITC can flow through
to a battery project if it is integrally connected to the renewable project and is charged
directly from the renewable project for the first five years of BESS operations. Because
the 80 MW project is not connected to a solar project, it does not benefit from the federal
investment tax credits. A standalone energy storage lTC has been included in the Build
Back Better Bill introduced in Congress but has not yet passed.
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISS]ON STAFF - 9
DATED at Boise, ldaho this 2fih day of Jaly ZAE.
fu*2hht4-
DONOVAN E. WALKER
Attomey for ldahs Power Company
IDAHO POTII/ER COIiPANYS RESPONSE TO THE SECOND PRODUETPN REQUEST OF TI{E
coMMlssroN STAFF-10
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of July 2022,1 served a true and correct
copy of ldaho Power Company's Response to the Second Production Request of the
Commission Staff upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Dayn Hardie
Riley Newton
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No.8,
Suite 201-A (83714)
PO Box 83720
Boise, lD 83720-0074
lndustrial Customers of ldaho Power
Peter J. Richardson
515 N. 27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaHydro
C. Tom Arkoosh
Amber Dresslar
Arkoosh Law Offices
913 W. River Street, Ste. 450
P.O. Box 2900
Boise, lD 83701
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R i lev. Newto n @puc. ida ho.qov
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Amber.dresslar@a rkoosh.com
Erin. cecil@arkoosh. com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
Micron Technology, lnc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street Suite 3200
Denver, Co 80202
Jim Swier
Micron Technology, lnc.
8000 South FederalWay
Boise, !D 83707
ldaho Conservation League
Marie Kellner
Emma E. Sperry
ldaho Conservation League
710 N. 6th Street
Boise, lD 83702
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tnelson@holland ha rt.com
awie [e-mail]
aclee@holla nd hart. com
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mke llne r@ida h oco nservatio n. oro
esperry@idahoconversation. orq
:,b"+&^t.
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12