20230327IPC to Staff 26-37.pdf

Donovan E. Walker
Lead Counsel
[e-mail]

March 27, 2023

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-23-01
In the Matter of Idaho Power Company’s Application for a Certificate of
Public Convenience and Necessity for the Boardman to Hemingway 500-
kV Transmission Line

Dear Ms. Noriyuki:

Enclosed for electronic filing, please find Idaho Power Company’s Response to the
Second Production Request of Commission Staff.

The confidential documents will be provided to the parties who sign the Protective
Agreement.

If you have any questions about the attached filing, please do not hesitate to
contact me.

Very truly yours,

Donovan E. Walker
DEW:sg
Enclosures
RECEIVED
2023 March, 27 3:57PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND 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 A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY FOR
THE BOARDMAN TO HEMINGWAY 500-KV
TRANSMISSION LINE.
)
)
)
)
)
)
)

CASE NO. IPC-E-23-01

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Second Production Request of the Commission Staff (“IPUC or
Commission”) dated March 6, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 26: The Application for Case No. PAC-E-
23-01, PacifiCorp ("PAC") states there will need to be 10 communication stations built
within the right of way of the proposed transmission line. See Case No. PAC-E-23-01,
Application at 5. Please confirm if these communication stations are included in the
Company's Boardman to Hemingway ("B2H") project scope and cost estimate. If these
are included in the project scope, please:
a. Provide a map indicating where the 10 communication stations will be located
along the transmission line; and
b. Provide the estimated cost to build each communication station.
RESPONSE TO REQUEST FOR PRODUCTION NO. 26: The current project
scope includes eight communication regeneration sites located along the B2H
transmission line.
a. The approximate location of the eight communication regeneration sites are
shown in Attachment 1.
b. The estimated cost of each communication site, including overheads and
contingency is approximately . Note, this estimate does not include
Allowance for Funds Used During Construction (“AFUDC”) or property taxes.
The response to this Request is sponsored by Joe Stippel, Principal Engineering
& Construction Project Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
REQUEST FOR PRODUCTION NO. 27: In Case No. PAC-E-23-01, PAC witness
Vail describes access roads being constructed in the B2H project. See Case No. PAC-
E-23-01, Vail Direct at 2. However, the Company did not mention road construction in
its Application. Please confirm if access road costs are included in the Company's plan
for building the transmission line. If these are included in the project scope, please
describe the following:
a. The scope of work for constructing new access roads including the number of
miles needed, the estimated costs, and timeline for construction; and
b. The scope of work for modification of existing access roads including the number
of miles that need modification, the estimated costs, and timeline for
construction.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27: The project scope
includes use of existing access roads and construction of new access roads. The latest
design includes use of approximately 600 miles of existing access roads (approximately
525 miles of which may require some level of improvement) and the construction of
approximately 250 miles of new access roads. The estimated cost for the new access
roads and use and improvement of existing access roads, including overheads and
contingency, is approximately $ . Note this estimate does not include AFUDC
or property taxes. The current schedule includes access road construction commencing
in the second half of 2023 and the majority of work wrapping up by mid-2025.
The response to this Request is sponsored by Joe Stippel, Principal Engineering
& Construction Project Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 28: Company witness Ellsworth identifies
many of the B2H project cost assumptions made for the 2021 Integrated Resource Plan
("IRP") analysis. Ellsworth Direct at 48-50. However, it is difficult to account for all the
scope elements throughout his testimony.
Please provide the following:
a. Please provide a tabulated comparison of the project scope that was assumed in
the 2021 IRP, and the scope currently included in the project [as defined by the
Joint Construction Funding Agreement ("JCFA")];
b. Please include the cost that was estimated for each scope element assumed in
the IRP and the current cost estimate for each element; and
c. Please provide a list of any B2H-related costs that are outside of the JCFA, such
as the Midpoint Transformer Upgrade.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28:
a. The 2021 IRP included costs associated with all components of the B2H
transaction, including local interconnection into the Treasure Valley transmission
system, and costs related to the asset exchange with PacifiCorp.1 The following
is a list of the various components:
 Boardman to Hemingway Project
o B2H transmission and substation costs
o B2H midline series capacitor
o BPA permitting buyout payment
 Local interconnection projects (230-kV line from Hemingway to Bowmont

1 In re Idaho Power Company, 2021 IRP, Case No. IPC-E-21-43, IRP Appendix D at 6-9, 28-29 (Feb.
2022).

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
to Hubbard substations, including supporting equipment)
 Midpoint 500/345-kV second transformer addition
 Midpoint-Kinport 345-kV series capacitor
 PacifiCorp asset exchange costs
All of the items listed above currently remain in the scope of the project, though
some will fall under a combination of the JCFA, the Purchase, Sale and Security
Agreement, the Midpoint Transformer Construction Agreement, the Kinport
Capacitor Bank Construction Agreement, and the Joint Purchase and Sale
Agreement, as outlined in Confidential Exhibit No. 2. However, because the local
interconnection projects are specific only to Idaho Power, there is no agreement
associated with that portion of the project costs.
b-c. See table below:
B2H Project Component Exhibit No. 11 Line
Identification
Exhibit No. 11
Column Identification
2021 IRP Plus
20% Contingency1
December 2022
IPC-E-23-01
Estimate
B2H Transmission and
substation costs
A component of the Total B2H
Project Estimated Costs $509.8 million $603.6 million
B2H midline series
capacitor
A component of the Total B2H
Project Estimated Costs $11.3 million2 $11.3 million2
BPA’s permitting interest BPA Permitting Buyout (Future)3 $22,715,669 $28,444,985
Local 230-kV upgrades Local Interconnection Costs $42,376,019 $46,948,997
Southern Idaho upgrades
(Midpoint 500/345-kV
second transformer
addition and Midpoint-
Kinport 345-kV Series
Capacitor)
Not Applicable4 $47 million --
PacifiCorp asset exchange Not Applicable5 Reflected in
Southern Idaho
upgrades cost
--

Notes:
1. The 2021 IRP Plus 20% Contingency line on Confidential Attachment 1 to the
Company’s Response to Staff’s Request for Production No. 3 does not tie to the

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
amounts presented in Mr. Ellsworth’s direct testimony because Idaho Power
presented the 2021 IRP costs on Confidential Attachment 1 to the Company’s
Response to Staff’s Request for Production No. 3 with the inclusion of the
contingency amounts for comparison to previously reported cost estimate
purposes. For modeling in the 2021 IRP, the Company excluded contingency
amounts from all potential resources and their associated costs.
2. This amount is included in the Total B2H Project Estimated Costs amount and
excludes overheads and Allowance for Funds Used During Construction.
3. The amounts presented on the BPA Permitting Buyout (Future) line of
Confidential Attachment 1 to the Company’s Response to Staff’s Request for
Production No. 3 are future costs while Mr. Ellsworth’s direct testimony presents
the present value of those costs.
4. The southern Idaho upgrades, which include the Midpoint 500/345-kV second
transformer addition and the Midpoint-Kinport 345-kV Series Capacitor are not
identified in Confidential Attachment 1 to the Company’s Response to Staff’s
Request for Production No. 3. The Company anticipates investing in the southern
Idaho upgrades, but it will be independent of the B2H project and therefore are
not a component of the B2H project costs. Idaho Power did however, model the
costs as part of the 2021 IRP, treating the cost and capacity of the two projects
differently in portfolios inclusive of B2H, compared to portfolios exclusive of B2H.
If a B2H-inclusive portfolio was selected as the Preferred Portfolio, the Company
plans to include these assets as part of a larger asset exchange arrangement
with PacifiCorp and modeled the costs accordingly. If the Preferred Portfolio was

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
exclusive of B2H, the Company would not transact on an asset exchange with
PacifiCorp, and therefore assumed that Idaho Power and PacifiCorp would both
participate in the upgrades, per the parties’ existing Joint Ownership and
Operating Agreement, at their respective ownership shares. While appropriately
not included in Confidential Attachment 1 to the Company’s Response to Staff’s
Request for Production No. 3, the southern Idaho upgrades were a component of
the 2021 IRP portfolio cost modeling with differing costs and capacity depending
on whether or not B2H was included in the portfolio. Therefore, the difference
between the least-cost B2H portfolio and the least-cost non-B2H portfolio
captures the project costs under the different scenarios.
5. As the Company developed its 2021 IRP, it did not have sufficient information
regarding the PacifiCorp asset exchange to model a detailed cost associated
with the transaction. Idaho Power determined, however that there was sufficient
information to make a conservative estimate and assumed that it would be
funding 100 percent of the cost of the Midpoint Transformer and Kinport Series
Capacitor projects. Idaho Power expects the costs of the two projects, plus the
net book value (”NBV”) of its existing transmission assets that will be transferred
to PacifiCorp will exceed the NBV of the assets it is acquiring from PacifiCorp in
the exchange, and therefore the Company modeled an estimate of these costs in
the 2021 IRP. For additional clarity, Idaho Power does not anticipate funding 100
percent of the cost of the Midpoint Transformer and Kinport Series Capacitor
projects. Rather this approach was intended as a conservative IRP estimate.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9
REQUEST FOR PRODUCTION NO. 29: The predicted cost of wholesale power
is an important factor in the IRP Aurora modeling. Please provide the following:
a. Please provide an hour-by-hour comparison of the 2021 IRP modeled Mid-C
market prices with the actual Mid-C market prices for 2021 and 2022; and
b. Please identify causal factors and provide explanations for any significant
differences between the two, especially during critical summer months.
RESPONSE TO REQUEST FOR PRODUCTION NO. 29:
a. Please see Attachment 1 for an hour-by-hour comparison of the 2021 Integrated
Resource Plan (“IRP”) modeled Mid-C market prices and the actual Mid-C
market prices for 2021 and 2022. Please note that historical Mid-C market prices
are captured as single values for heavy load and light load hours each day.
b. The AURORA modeled Mid-C prices are based on planning or typical conditions
while the actual Mid-C prices are based on the market’s assessment of actual
conditions. As such, anytime actual conditions deviate from planning conditions,
it is reasonable to expect modeled and actual prices to diverge. Generally, Mid-C
prices are influenced by myriad factors over vast and diverse geographies across
the Western Interconnection, for which accurate historical data is not available.
Therefore, the Company cannot explain each hourly market vagary and can only
comment on general conditions.
Over the specified years, energy markets moved due to: drought
conditions throughout the Western Electricity Coordinating Council (“WECC”),
one in 1,000-year type weather events in the Pacific Northwest, post-pandemic
related gas supply issues throughout the United States, localized natural gas

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
pipeline disruptions, and wildfire disruptions to transmission infrastructure,
amongst many other widely reported events with hard-to-quantify influence on
market prices. Additionally, other often unreported events like generation and
transmission outages can play a significant role in market price changes.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
REQUEST FOR PRODUCTION NO. 30: Please quantify the following benefits
that the Company expects to gain from the proposed B2H project and provide
supporting workpapers:
a. Please quantify the expected benefits for native load customers;
b. Please quantify the expected benefits from off-system sales;
c. Please quantify the expected benefits from wheeling power as a result of B2H;
d. Please list and describe in detail any other benefits that cannot be readily
quantified; and
e. Please quantify the expected benefits by year over the IRP planning cycle.
RESPONSE TO REQUEST FOR PRODUCTION NO. 30:
a. Table 10.3 from the 2021 IRP, presented below, compares the net present value
(“NPV”) of the different portfolios. Comparing the preferred portfolio, Base with
B2H, to the Base without B2H PAC Bridger Alignment portfolio, results in a $266
million difference, or $266 million more costly than the preferred portfolio.

Using the updated B2H project costs provided in the Company’s
Response to Staff’s Request for Production No. 3, increases the total cost of the
preferred portfolio in the 2021 IRP from $7,942 million to $8,027 million.
However, because the least-cost non-B2H portfolio, the Base without B2H PAC
Bridger Alignment portfolio, included Gateway West, another 500-kV

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
transmission project that the Company is jointly developing with PacifiCorp, it
would be appropriate to update the Gateway West cost estimate consistent with
the B2H project costs. To estimate the increase, as an approximation Idaho
Power assumed the Gateway West cost per mile would be equivalent to the B2H
cost per mile. The result was that the Base without B2H PAC Bridger Alignment
portfolio cost increases from $8,208 million to $8,255 million. Comparing the
difference between the least-cost B2H portfolio, $8,027 million, and the least-cost
non-B2H portfolio, $8,255 million, results in a $228 million difference, or a $228
million benefit to Idaho Power’s native load customers.
b. Increased off-system sales have not been identified as a benefit of B2H therefore
Idaho Power has not quantified any differences associated with the addition of
B2H. The B2H project is modeled in AURORA as additional transmission
capacity available for Idaho Power energy purchases and sales from the Pacific
Northwest. To the extent this incremental export transmission capacity enabled
additional Company resource sales over the existing transmission system,
benefits would be captured in the AURORA modeling process and reflected in
total portfolio costs.
c. The estimated incremental levelized transmission wheeling revenues resulting
from B2H using the B2H project cost estimate provided in the Company’s
Response to Staff’s Request for Production No. 3 are approximately $48.8 million
annually. The incremental transmission wheeling revenue estimate is based only
on the increased Open Access Transmission Tariff transmission formula rate
anticipated with the inclusion of the B2H project but does not include any

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
changes associated with incremental transmission wheeling volumes. Due to the
significant increase in capacity the B2H project provides to the Idaho to
Northwest path, the Company believes firm, short-term firm, and non-firm usage
of Idaho Power’s transmission system by third parties could increase, as
supported by the over 1,000 MWs of transmission requests that the Company
has seen across the Idaho to Northwest path over the past 24 months.
Additionally, Idaho Power’s acquisition of 200 MW of bidirectional capacity to
Four Corners, New Mexico will only further enhance the value of the Company’s
transmission system to third parties. These potential revenues would further
increase the incremental transmission wheeling revenues. However, to be
conservative, Idaho Power assumed a constant transmission usage by third
parties (no increase or decrease) from an average of usage over recent years.
d. As explained in detail in the Direct Testimony of Mr. Ellsworth,2 Idaho Power
anticipates additional benefits, although not directly quantified, associated with:
improved economic efficiency, renewable integration, grid reliability/resiliency,
flexibility, Energy Imbalance Market value and economic value along the B2H
project route. As also discussed in the Direct Testimony of Mr. Ellsworth, Idaho
Power performed an analysis of transmission system losses with and without
B2H, and determined B2H allows the Company to save 6.4 MW per hour
average electrical losses. Loss savings were quantified as part of the IRP
portfolio analysis discussed in (a).
e. Please see (c) for annual OATT benefits. When comparing the least-cost B2H

2 See Direct Testimony of Jared Ellsworth, Pages 58-75.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 14
portfolio to the least-cost non-B2H portfolio, the 2021 IRP quantified total benefits
of $266 million (NPV). Assuming the $266 million NPV benefits accrue starting in
2026, when B2H is placed into service, the $266 million equates to about $39
million in total annual customer benefits, which is inclusive of all quantified B2H
related benefits. Benefits are relative to an alternative non-B2H portfolio.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 15
REQUEST FOR PRODUCTION NO. 31: In Company witness Barrett's
testimony, she stated "milestone dates will be tied to monetary penalties for the
construction manager if key dates slip." Barrett Direct at 40. Please describe the
milestone dates to which the construction manager will have to adhere. Please provide
a workpaper that includes penalties associated with each milestone.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31: Milestone dates and
monetary penalties for the construction manager have not yet been determined. As
described in Ms. Barretto’s testimony, as the B2H project transitions into the
construction phase, all material and construction services will be competitively bid and
be pulled into a guaranteed maximum price (“GMP”) that will serve as the construction
pricing, if awarded. This GMP is tied to a schedule that Idaho Power and the
construction manager will have developed together, and as a result of the contract, the
construction manager will be responsible for meeting that schedule. Milestone dates
will be tied to monetary penalties for the construction manager if key dates slip. The
Company anticipates selecting a construction manager in the third quarter of 2023.
The response to this Request is sponsored by Lindsay Barretto, 500KV and Joint
Projects Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 16
REQUEST FOR PRODUCTION NO. 32: Please provide the forecasted
operation and maintenance costs for the proposed B2H transmission line. Please
provide supporting workpapers that detail costs by year over the IRP planning period.
RESPONSE TO REQUEST FOR PRODUCTION NO. 32: Please see
Attachment 1. The operation and maintenance (“O&M”) expense estimate for B2H was
based on the historical O&M charges to the Kinport-Midpoint 345-kV line.
The response to this Request is sponsored by Pete Schindele, Senior Financial
Analyst, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 17
REQUEST FOR PRODUCTION NO. 33: Production Request No.7 asks why
Bonneville Power Association ("BPA") wants out of the deal. Please explain why the
Company decided to buyout all of BPA's interest as opposed to PAC buying out the
interest, or the Company and PAC splitting the buyout.
RESPONSE TO REQUEST FOR PRODUCTION NO. 33: To meet BPA’s goal of
a single transmission wheel from BPA’s transmission system to their Southeast Idaho
customers, Idaho Power was better positioned to accommodate this request as the
Company presently controls and owns the west-to-east capacity across the southern
Idaho system. BPA’s entire B2H interest is needed to serve BPA’s Southeast Idaho
load. Also, as explained in BPA’s letter to the region, included as Attachment 1, in
consideration of PacifiCorp’s transfer of its Goshen area (located in Southeast Idaho)
load serving assets to Idaho Power, BPA evaluated and provided options for increasing
BPA transmission service to PacifiCorp’s load service area in Central Oregon. Idaho
Power’s assumption of BPA’s ownership interest and providing service was part of the
balanced three-party arrangement.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 18
REQUEST FOR PRODUCTION NO. 34: Please describe the forecasted
timeline for the reimbursement of BPA's permitting costs. Ellsworth Direct at 14. Please
provide supporting workpapers that show terms and repayment by year.
RESPONSE TO REQUEST FOR PRODUCTION NO. 34: Idaho Power’s current
forecast of the repayment schedule of the Bonneville Power Administration’s (“BPA”)
permitting costs are included in Confidential Attachment 1. Column (7) presents the
BPA reimbursements during the contract timeframe. The contracted terms and
conditions for reimbursing BPA’s permitting costs are detailed in Exhibit B of the
Purchase, Sale and Security Agreement included in Confidential Exhibit No. 2 identified
as Agreement 4. The Purchase, Sale and Security Agreement was subsequently
executed on March 24, 2023. In general, payments will commence after BPA’s wheeling
volume exceeds 400 MW. If the wheeling volume is met during the first ten years,
monthly payments will commence with the tenth anniversary of B2H’s energization,
starting at $40,000 for the first twelve-month interval, and escalating by $40,000 for
each successive twelve-month interval. If the wheeling volume is not met, the
payments will not commence.
The Company expects to receive sufficient revenues from BPA utilizing the
capacity associated with the additional 24 percent investment in B2H from Open Access
Transmission Tariff (“OATT”) services to support both the reimbursements of permitting
costs to BPA and assuring retail customers are held harmless over the term of the BPA
contract.
The response to this Request is sponsored by Bruce MacMahon, Business Unit
Finance Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 19
REQUEST FOR PRODUCTION NO. 35: Company witness Ellsworth testifies
that the extra 24% of B2H transmission capacity the Company will acquire from BPA
"will primarily be used to provide BPA network transmission service under Idaho
Power's Open Access Transmission Tariff ('OATT')." Ellsworth Direct at 11.
a. Please provide the forecasted annual OATT revenue that the Company expects to
receive from BPA for this service, including the underlying wheeling volume and
tariff rates;
b. Please provide any data supplied by BPA concerning its forecasted wheeling
requirements across B2H; and
d. Please provide the Company's analysis for recovering its additional 24% capital
cost and the additional 24% operation and maintenance cost.
RESPONSE TO REQUEST FOR PRODUCTION NO. 35:
a. Please see column (4) of Confidential Attachment 1 to the Company’s Response
to Staff’s Request for Production No. 34 for the forecasted annual OATT revenue
derived from BPA. This file also includes the underlying wheeling volumes
(column (2)) and forecasted OATT rates (column (3)).
b. Please see Confidential Attachment 1. The first tab, NITSA – FY Monthly detail
includes BPA’s forecasted southeast Idaho loads that are expected to be moved
to Idaho Power’s system, as provided to PacifiCorp, BPA’s current network
service provider.
c. Please see Confidential Attachment 1 to the Company’s Response to Staff’s
Request for Production No. 34. Column (5) presents the incremental capital costs
and O&M expenses attributable to the additional 24 percent ownership. The

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 20
recovery of these incremental costs will primarily occur through revenues
received from BPA’s Network Integration Transmission Service Agreements
(“NITSA”) under Idaho Power’s OATT (see column (4)), starting with an under-
collection in the earlier years of the 20-year NITSA timeframe, and growing to a
sufficiency in the later years of the agreement (see column (6)). Idaho Power will
request in a future proceeding authorization from the Commission for accounting
treatment that will address the timing issue on the collection of OATT revenue
over the contract with BPA, ensuring the Company’s retail customers are not
harmed by the arrangement.
The Company expects to receive sufficient revenues from BPA utilizing
the capacity related to the additional 24 percent investment in B2H from OATT
services to support both the reimbursements of permitting costs to BPA and
ensuring retail customers are held harmless over the term of the BPA
contract. Idaho Power’s current forecast is based on the estimated final cost for
Idaho Power’s share of B2H costs compared to an updated estimated cost of
B2H under a 21.21 percent ownership scenario. The forecast is also based on
load assumptions provided by BPA and the Company’s forecast of the OATT rate
over the next 20 years. All of these assumptions will be revaluated as time
passes with actual results updating the provided schedule. While Idaho Power
expects the actual results will vary from the forecast, the Company believes the
additional revenues from the larger ownership in B2H will not harm customers
and likely will reduce costs for customers as compared to the 21.21 percent
ownership.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 21
The response to this Request is sponsored by Bruce MacMahon, Business Unit
Finance Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 22
REQUEST FOR PRODUCTION NO. 36: Company witness Ellsworth testifies
that there are several other transactions that are necessary for B2H, but not directly
related to construction and operation of the B2H project. Ellsworth Direct at 19. For the
four proposed asset exchanges, please provide the following:
a. Please explain why each one of these is necessary for B2H; and
b. Please explain the Company's contingency plans if any of the asset exchanges
are prevented or not implemented.
RESPONSE TO REQUEST FOR PRODUCTION NO. 36:
a. Asset Exchange #1: the transfer to PacifiCorp by Idaho Power of transmission
assets between Midpoint and Borah to facilitate 300 MW of west-to-east
capacity. This exchange is necessary to provide PacifiCorp with a west-to-east
ownership path across southern Idaho so PacifiCorp can utilize their planned 300
MW west-to-east B2H capacity without a transmission wheel.
Asset Exchange #2: the transfer to PacifiCorp by Idaho Power of transmission
assets between Borah and Hemingway to enable an additional 600 MW of east-
to-west capacity, increasing from the current capacity of 1,090 MW to 1,690 MW.
This exchange is necessary to provide PacifiCorp with an increased east-to-west
ownership across southern Idaho so PacifiCorp can utilize their planned 600 MW
east-to-west B2H capacity without a transmission wheel.
Asset Exchange #3: the transfer to Idaho Power by PacifiCorp of transmission
assets between Populus, Mona, and Four Corners to allow for 200 MW of
bidirectional capacity. This exchange is necessary to provide Idaho Power with a
consideration for the assets being conveyed by Idaho Power in Asset Exchanges

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 23
#1 and #2 described above. The Four Corners capacity provides Idaho Power
valuable firm transmission access to a market hub diverse from the Pacific
Northwest.
Asset Exchange #4: the transfer by PacifiCorp to Idaho Power of an ownership
interest in identified Goshen area assets. This exchange is necessary to provide
BPA consideration for providing PacifiCorp increased transmission service to the
Central Oregon load service area. The Company requires ownership of these
transmission assets to provide BPA a single network transmission wheel across
Idaho Power’s transmission system to the BPA customer loads in Southeast
Idaho.
b. The Company has not identified any contingency plans in the event the above
exchanges are prevented or not implemented.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 24
REQUEST FOR PRODUCTION NO. 37: In Case No. PAC-E-23-01, PAC
witness Link described the United States Environmental Protection Agency's proposed
Ozone Transport Rule ("Rule") that would restrict Nitrous Oxide ("NOx") emissions from
power plants and other industrial sources. See Case No. PAC-E-23-01, Link Direct at
15. Please answer the following:
a. Please explain the Company's assessment of the Rule and likely impacts to the
Company; and
b. Please explain if the Company incorporated any of the economic implications from
this rule into its analysis of the project, and if so, please explain how.
RESPONSE TO REQUEST FOR PRODUCTION NO. 37:
a. On April 6, 2022, the U.S. Environmental Protection Agency (“EPA”) issued a
proposed rule under the Clean Air Act called the Federal Implementation Plan
Addressing Regional Ozone Transport for the 2015 National Ambient Air Quality
Standards, or Good Neighbor Plan. Being a proposed rule, the Company
evaluated potential impacts to the Jim Bridger and North Valmy power plants.
Idaho Power submitted comments to the proposed rule in June 2022. The final
rule, released on March 15, 2023, includes the state of Nevada (North Valmy),
but does not include Wyoming (Jim Bridger) which will be addressed at a later
date. At this time, the Company is still assessing the potential impacts of the
recently issued Rule.
b. The Company did not incorporate specific economic implications from the Rule
(which restricts NOx emissions) into the 2021 Integrated Resource Plan (“IRP”)
analysis or any other analysis included in this case. At the time the 2021 IRP was

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 25
developed, it was not yet a proposed Rule. However, the Company did assess a
range of potential CO2 cost forecasts in the IRP, providing a robust analysis of
the project under various emission policy scenarios.
The response to this Request is sponsored by John Carstensen, Joint Projects
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 26
DATED at Boise, Idaho this 27th day of March 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 27
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 27th day of March 2023, I served a true and
correct copy of Idaho Power Company’s Response to the Second Production Request of
the Commission Staff to Idaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
Riley Newton
Michael Duval
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X E-mail [e-mail]
[e-mail]
FTP Site

Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & Olsen, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X E-mail [e-mail]
__ FTP Site

Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X E-mail [e-mail]
_ FTP Site

Industrial Customer of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X EMAIL [e-mail]
_ FTP Site

Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X EMAIL [e-mail]
_FTP Site

IDAHO POWER COMPANY’S RESPONSE TO THE SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 28
City of Boise
Ed Jewell
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X EMAIL [e-mail]
[e-mail]
[e-mail]
FTP Site

Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X EMAIL [e-mail]
FTP Site

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202

Hand Delivered
U.S. Mail
Overnight Mail
FAX
X EMAIL [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
FTP Site

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X EMAIL [e-mail]
FTP Site

Idaho Conservation League
Marie Callaway Kellner
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X EMAIL
[e-mail]
[e-mail]
FTP Site

______________________________________
Stacy Gust, Regulatory Administrative Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

REQUEST NO. 26

ATTACHMENT NO. 1

U m a t i l l aU m a t i l l a
U n i o nU n i o n
B a k e rB a k e r
M o r r o wM o r r o w
M a l h e u rM a l h e u r
O w y h e eO w y h e e
CS-04
CS-06
CS-05
CS-01
CS-07
CS-02
CS-08
CS-03
Hemingway
Longhorn
Pa
t
h
:

\
\
1
0
.
1
5
2
.
1
2
6
.
1
1
\
c
a
d
\
2
1
0
2
1
\
I
d
a
h
o
P
o
w
e
r
_
B
2
H
\
M
X
D
\
B
2
H
_
C
o
m
m
S
i
t
e
O
v
e
r
M
a
p
.
m
x
d
Legend:
#0
! ! ! ! ! ! ! ! ! ! ! ! ! !
Substation
Communication Station Distribution Lines
Routes
Communication Stations
Counties
Map Coordinate System: NAD 1983 UTM Zone 11N
BOARDMAN TO HEMINGWAY 500Kv TRANSMISSION LINEMORROW, UMATILLA, UNION, BAKER, MALHEUR COUNTIESOREGON AND OWYHEE COUNTY, IDAHO
COMMUNICATION SITE LOCATIONS ALONG ROUTE
Page 1 of 1
#0
#0
I
1:570,240 when printed on 34x22 inch sheet (1 in = 9.0 Miles)1:1,140,480 when printed on 17x11 inch sheet (1 in = 18.0 Miles)
40 0 40
1" = 40 Miles
3/9/2023Rev 0
SCALE: 1" = 9.00 Miles
9.00 0 9.00 18.00
CS-##

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

REQUEST NO. 29

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

REQUEST NO. 32

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

REQUEST NO. 33

ATTACHMENT NO. 1
Department of Energy
Bonneville Power Administration P.O. Box 3621 Portland, Oregon 97208-3621

POWER SERVICES
In reply refer to: P-6
To parties interested in B2H and Southeast Idaho Load Service: This notice announces that the Bonneville Power Administration, Idaho Power, and PacifiCorp have concluded negotiations on final agreements that memorialize and effectuate the Boardman to Hemingway, or B2H, with Transfer Service plan of service to southeast and southern Idaho loads. The proposed plan of service would deliver significant benefits for BPA and its customers,
including essential congestion relief and removal of the dependence on conditional firm point-to-point service; consolidation of network integration transmission service from a single transfer service provider for all of BPA’s deliveries to southeast and southern Idaho loads; and improved costs compared with today’s interim service approach.

BPA now proposes to execute the contracts for the B2H with Transfer Service plan of service. Before making a final decision to execute the contracts, BPA is providing regional stakeholders with more information about the contracts and an opportunity to comment.
Attachment A includes background information, an overview of the contracts that BPA is
proposing to execute for the B2H with Transfer Service plan of service, and information for how to submit comments.
We look forward to continued discussions with regional stakeholders on this important topic.
Sincerely,

Attachments

3
ATTACHMENT A
Updated BPA Letter to the Region re: B2H and Southeast Idaho Load Service
I. Background In a Letter to the Region dated January 18, 2022 (“2022 Letter”), BPA announced its signature of
a non-binding term sheet (“Term Sheet”) that clarified and updated BPA’s role in Idaho Power
and PacifiCorp’s potential future construction of their new transmission line from Boardman, Oregon to Hemingway, Idaho (the “Boardman to Hemingway Project” or “B2H”). The 2022 Letter provided background on the B2H negotiations, the history of BPA’s load service to the six preference customers in Idaho (“Southeast Idaho Load Service” or “SILS customers”), and
challenges with the current interim plan of service to these customers’ loads. BPA explained
how the proposed B2H project could provide BPA a long-term plan of service for the SILS customers that includes BPA taking network transfer service from Idaho Power (“B2H with Transfer Service”). BPA also explained the related challenges associated with BPA’s long term service to the 15 preference customers in Southern Idaho, many located near Burley, Idaho, and
the benefits that the B2H with Transfer Service plan of service provides to these customers.
BPA noted that Idaho Power, PacifiCorp, and BPA intended to negotiate binding contracts to memorialize and effectuate the B2H with Transfer Service plan of service. The 2022 Letter and the Term Sheet are available at Southeast Idaho Load Service - Bonneville Power Administration (bpa.gov). BPA is pleased to share that negotiations have concluded. BPA now proposes to execute binding
contracts for the B2H with Transfer Service plan of service. Before making a final decision to
execute the contracts, BPA is providing regional stakeholders with more information about the contracts and an opportunity to comment. BPA is also conducting appropriate National Environmental Policy Act (“NEPA”) processes before making a final decision. Under the B2H with Transfer Service plan of service, BPA’s role as permitting partner and
potential future partial owner of the B2H project would be removed from the B2H ownership structure. BPA would transfer its B2H permitting interest share to Idaho Power in a Purchase, Sale, and Security Agreement. Idaho Power and PacifiCorp would jointly own and construct the B2H project pursuant to separate agreements between them. To serve the SILS customers’ loads, BPA would enter into a network integration transmission service agreement (“NITSA”)
with Idaho Power under its Open Access Transmission Tariff (“OATT”) for service to the five SILS customers in the Goshen area and a second NITSA for service to Idaho Falls. These NITSAs would provide BPA with a single leg of network integration transmission service (“NITS”) from Idaho Power to deliver resources from the BPA transmission system to the SILS customers’ various points of delivery.
To facilitate Idaho Power’s ability to serve the SILS customers’ loads as network loads, PacifiCorp would transfer assets to Idaho Power in an agreement between PacifiCorp and Idaho Power. This asset transfer allows the SILS customers’ loads currently served on PacifiCorp’s southeast Idaho transmission system to be served fully on Idaho Power’s transmission system.
In consideration of PacifiCorp transferring assets to Idaho Power and with other stipulations, BPA would provide point-to-point (“PTP”) transmission service in central Oregon to PacifiCorp
4
through the redirect of existing PTP service paired with a conversion of legacy scheduling rights
in central Oregon to PTP service. Additionally, BPA would provide Idaho Power with PTP
service to the B2H interconnection at the proposed BPA Longhorn substation near Boardman, Oregon. PacifiCorp and Idaho Power would take and pay for the PTP services pursuant to BPA’s OATT and rate schedules. BPA would also enter into contracts with Idaho Power and PacifiCorp associated with the B2H interconnection at the proposed BPA Longhorn substation.

For BPA, the construction of B2H by Idaho Power and PacifiCorp in conjunction with the transfer of assets between Idaho Power and PacifiCorp means that BPA would receive firm network transmission service for its SILS customer loads using only one wheel of transmission beyond the BPA transmission system (as opposed to two wheels, which is part of the current
interim plan of service). By stepping out of the B2H ownership structure, BPA also avoids the
complexity and foregone revenue of other previously considered plans of service. This letter announces the final terms of the B2H with Transfer Service plan of service. Section II describes the agreements that BPA proposes to execute. Section III provides an explanation of
BPA’s business case for this plan of service, including the quantitative and qualitative benefits.
Key benefits include elimination of today’s reliance on conditional firm PTP service for deliveries of BPA resources to the SILS customers’ loads, migration of SILS customer loads to firm network transmission service, financial benefits of having a single wheel of transmission for service to the SILS customer and incremental revenues from new PTP sales, congestion relief
that benefits BPA’s deliveries for all Southern and Southeast Idaho customers, and eliminating
today’s interim service’s reliance on market purchases that carry cost, availability, and carbon-content risks. Finally, this letter initiates the start of a public comment period that will conclude on February 9,
2023. Section IV provides information for how stakeholders may submit comments. BPA will
answer stakeholder questions and discuss aspects of the business case associated with the B2H with Transfer Service plan of service at the January 23, 2023, workshop. BPA intends to make a final decision regarding whether to execute the agreements for the B2H with Transfer Service plan of service in a Closeout Letter to the region on or about March 23, 2023.

II. Final Terms for the B2H with Transfer Service Plan of Service
A. Arrangements to effectuate long-term firm transfer service for the SILS customers’ loads
Under the B2H with Transfer Service plan of service, BPA would not become an owner or participate in the construction of the B2H project. Instead, BPA would sell its B2H permitting interest share (around 24%) and its right to future ownership in B2H to Idaho Power. Together with Idaho Power’s existing rights to the B2H project, this sale of BPA’s permitting interest
would allow Idaho Power to fund construction and hold a 45.45% ownership share in the B2H project. PacifiCorp would continue to fund construction and hold a 55.55% ownership share in the B2H project.
5
To serve the SILS customers’ loads after the B2H project is constructed, BPA would purchase
long-term firm NITS from Idaho Power. Currently, service to the SILS customers’ loads uses
transmission facilities that are owned by PacifiCorp. In order to facilitate Idaho Power’s ability to serve the SILS customers’ loads entirely from its transmission system after the B2H project is constructed, PacifiCorp would transfer an ownership interest to Idaho Power in the PacifiCorp facilities that are presently used to serve BPA’s SILS loads (the “asset exchange”). In addition,
BPA would pay Idaho Power $10 million upon execution of the NITSAs as security for Idaho
Power’s construction of the B2H project to provide BPA with the NITS service. The security would allow Idaho Power to provide assurances to its regulatory bodies that its retail rate payers were insulated from risk associated with Idaho Power purchasing BPA’s share of the B2H permitting interest.

Following execution of the Term Sheet, Idaho Power and BPA merged the terms for the sale of BPA’s permitting interest and the NITSA security payment into a single agreement, the Purchase, Sale, and Security Agreement, because the subject matters were interrelated. The key provisions of the Purchase, Sale, and Security Agreement, NITSAs, and agreements between
Idaho Power and PacifiCorp needed to serve the SILS loads are described below. If BPA’s final
decision is to proceed with the B2H with Transfer Service plan of service, BPA would execute these agreements concurrent with issuing the Closeout Letter.
1. Purchase, Sale, and Security Agreement
In the Purchase, Sale, and Security Agreement, BPA would transfer its permitting interest share to Idaho Power in exchange for payment to BPA for the costs BPA incurred towards permitting the B2H project (around $30 million). BPA would also pay Idaho Power the $10 million security payment. The payment for the value of the permitting interest and the security is the
Purchase Price. The agreement sets forth the requirements associated with the reimbursement of the Purchase Price to address the risks and uncertainties associated with Idaho Power taking on a larger ownership share in the B2H project and constructing a major new transmission line to provide BPA with NITS service.
If Idaho Power successfully completes construction and energization of the B2H project by the milestones in the Purchase, Sale, and Security Agreement, Idaho Power would return the $10 million security to BPA within 60 days of energization of the B2H project. The remaining amount of the Purchase Price would be paid in installments based on a 20 year payment schedule. The first installment of the Purchase Price payment would begin 10 years after B2H is
energized, provided that BPA takes the NITS service from Idaho Power during those 10 years. Additionally, during those 10 years of NITS service, BPA’s NITS loads must reach 400 MW or more on the hour of Idaho Power’s transmission system peak on a twelve-month rolling average basis. If BPA’s NITS loads do not reach the 400 MW threshold during the initial 10 years of service, Idaho Power would begin repaying BPA the Purchase Price on the next year after the
400 MW threshold is met. The Purchase, Sale, and Security Agreement also addresses reimbursement of the Purchase Price to BPA if problems arise with Idaho Power completing construction and energization of the B2H project:
6

• If Idaho Power does not receive the necessary governmental authorizations and, as a result, cannot complete the B2H project to provide NITS service to BPA, Idaho Power would not be obligated to pay the Purchase Price to BPA. BPA is agreeing to accept this financial risk because Idaho Power would be funding a higher percentage of B2H costs in
order to provide BPA with NITS service under the B2H with Transfer Service plan of
service.
• If Idaho Power does not receive governmental authorization by January of 2025, and has
not commenced construction by January of 2026, or other timeline as mutually agreed to
by BPA and Idaho Power, BPA would have the option to terminate the NITSAs. The option to terminate the NITSAs allows BPA to pursue an alternative plan of service for the SILS loads if there is substantial risk that the B2H project would not be completed.
o If BPA exercises the option to terminate the NITSAs and Idaho Power ultimately
receives governmental authorizations and completes the B2H project, Idaho Power would return the security to BPA and pay the remaining amount of the Purchase Price. If Idaho Power does not complete the B2H project, then Idaho Power is relieved of the obligation to pay BPA the Purchase Price.

o If BPA does not exercise the option to terminate the NITSAs and Idaho Power ultimately completes the B2H project, then Idaho Power would pay BPA the Purchase Price based on the installment payment schedule described above.
• If Idaho Power receives all necessary governmental authorizations by January of 2025, but decides to no longer proceed with constructing and energizing the B2H project, Idaho Power would return the security to BPA. Additionally, Idaho Power must attempt to market the transferred permitting interest. Idaho Power would then pay BPA for its proportional share of the sale proceeds.
The Purchase, Sale, and Security Agreement generally reflects the deal and structure envisioned in the Term Sheet. The 400 MW limit is a new term that the parties negotiated after execution of the Term Sheet to allow Idaho Power to provide assurances to its regulatory bodies that its retail ratepayers were insulated from risk associated with Idaho Power purchasing BPA’s share of the
B2H permitting interest. The Term Sheet also contemplated that Idaho Power would return security amounts as credits offsetting BPA’s NITSA bills. The Purchase Price payments will be independent of the NITSA billing.
2. NITS Agreements with Idaho Power
For the B2H with Transfer Service plan of service, BPA would enter into two new long-term firm NITSAs with Idaho Power. One new NITSA would provide for service to the Goshen area customers (Lower Valley, Soda Springs, Fall River, Lost River, and Salmon River) (“Goshen NITSA”). A second new NITSA would provide service for Idaho Falls (“Idaho Falls NITSA”).
The Goshen and Idaho Falls NITSAs, together with the asset exchange between Idaho Power and PacifiCorp, would allow BPA to deliver energy to the SILS customers’ loads from BPA’s
7
transmission system on a single leg of firm network transmission service across Idaho Power’s
system as opposed to relying on the conditional firm service under the interim plan of service.
Finally, BPA would update three existing NITSAs that support service to BPA’s Southern Idaho customers. Service under the Goshen and Idaho Falls NITSAs would commence after two conditions
precedent are satisfied. First, Idaho Power must complete construction and energization of the
B2H project. Second, Idaho Power and PacifiCorp must exchange assets sufficient to enable Idaho Power to deliver resources from the BPA transmission system across the Idaho Power system on a single leg of transmission to the SILS customers’ loads (see subsection 3 below). Commensurate with the asset exchange, the SILS customers’ loads under the Goshen NITSA
would move from the PacifiCorp Balancing Authority Area to the Idaho Power Balancing
Authority Area. Arrangements for the Idaho Falls NITSA are described below. After these conditions precedent are met, service under the Goshen and Idaho Falls NITSAs would commence upon energization of B2H, or a later date if specified by the Federal Energy
Regulatory Commission (Idaho Power must obtain regulatory approval from the Commission for
the NITSAs). Service under the NITSAs would terminate on July 1, 2046, and could be rolled over for additional terms consistent with Idaho Power’s OATT. The NITSAs also include an assignment provision that would allow BPA to request assignment
of some or all of the service under the NITSA to the wholesale customers that are served by the
NITSA. Idaho Power may not unreasonably withhold its consent to such assignment, provided the wholesale customer qualifies as an Eligible Customer consistent with Idaho Power’s OATT and assumes BPA’s rights and obligations under the assigned NITSA.
Idaho Falls would be served under a separate NITSA because of its unique supply arrangements
with other parties. Idaho Falls currently purchases BPA’s slice/block product and is responsible for managing its hourly balancing needs. Idaho Falls contracts with Utah Associated Municipal Power Systems (“UAMPS”) for this balancing service, which UAMPS provides under a legacy transmission service agreement with PacifiCorp to balance the Idaho Falls load in the PacifiCorp
Balancing Authority Area. Due to this unique arrangement and after discussion with Idaho Falls,
BPA determined that it was reasonable to negotiate a separate NITSA for Idaho Falls. One of BPA’s objectives in negotiating the Idaho Falls NITSA was to ensure that there was no impact to the existing relationship between Idaho Falls and UAMPS, or the legacy agreement between UAMPS and PacifiCorp. Accordingly, the Idaho Falls NITSA would only serve the portion of
Idaho Falls load served by BPA resources.
With regard to the updates to existing NITSAs, BPA has three existing NITSAs with Idaho Power. BPA uses these NITSAs to serve 15 preference customers, including the customers in the Burley area, and to deliver reserve power to the United States Bureau of Reclamation and
irrigation customers. Idaho Power has identified transmission constraints associated with serving
increased loads under these NITSAs. One of the key benefits associated with the completion and energization of the B2H project is that B2H increases the capacity on Idaho Power’s system that could be used to serve future load growth for these customers. After B2H is energized, these existing NITSAs would be updated to include a new B2H point of receipt that BPA can use to
8
deliver resources from the BPA transmission system to BPA’s customers located on Idaho
Power’s system.

3. Agreements between Idaho Power and PacifiCorp As noted above, concurrently with BPA executing the Purchase, Sale, and Security Agreement to
divest BPA of any interest in the B2H project, Idaho Power and PacifiCorp would enter into
agreements for the continued funding of the B2H project, including permitting, preconstruction, and construction (with Idaho Power funding 45.45% of all further costs associated with the B2H project). Idaho Power and PacifiCorp would also enter into other agreements necessary for ownership and the ongoing operation and maintenance of the B2H project. In addition, Idaho
Power and PacifiCorp would proceed with obtaining all state and federal regulatory approvals
applicable to them. With regard to the asset exchange that is a key feature of the B2H with Transfer Service plan of service, Idaho Power and PacifiCorp would enter into an agreement to transfer Goshen area
assets from PacifiCorp to Idaho Power. In many instances, these assets are already jointly owned by Idaho Power and PacifiCorp, so the asset exchange would adjust the ownership share of the jointly owned facilities to increase Idaho Power’s share. The asset exchange would commence upon the energization of B2H and the NITSAs between BPA and Idaho Power.
BPA is not a party to the agreements between Idaho Power and PacifiCorp. If BPA’s final decision is to proceed with B2H with Transfer Service, Idaho Power and PacifiCorp would execute the contracts they would be party to concurrent with BPA executing the contracts that BPA would be party to. Questions or comments about the agreements between Idaho Power and PacifiCorp or about the permitting and construction of the B2H project should be directed to
Idaho Power and PacifiCorp. For more information about Idaho Power and PacifiCorp’s B2H transmission line project, please visit Boardman to Hemingway - Idaho Power.
B. Transmission Agreements with PacifiCorp and Idaho Power
Under the B2H with Transfer Service plan of service, BPA would provide PTP transmission
service to PacifiCorp and Idaho Power pursuant to BPA’s OATT and rate schedules. Additionally, BPA would enter into other transmission arrangements with Idaho Power and PacifiCorp related to the interconnection of the B2H project with the proposed BPA Longhorn substation. This section describes these transmission arrangements.

1. BPA providing PTP service to PacifiCorp The 2022 Letter explained that, in consideration for PacifiCorp transferring its Goshen assets to Idaho Power, BPA and PacifiCorp would evaluate options for BPA to provide PacifiCorp with
680 MW of firm PTP service at or near the 230kV side of the Ponderosa substation (Ponderosa
230) in central Oregon. BPA’s evaluation would be consistent with BPA’s OATT and business practices and would consider a 2021 joint study. The preferred option included conversion of PacifiCorp’s legacy bidirectional scheduling rights over BPA’s Buckley-Summer Lake line to PTP service. The transmission capacity associated with the conversion would be combined with
9
PacifiCorp requesting to redirect existing PTP service. PacifiCorp would pay for the PTP
service pursuant to BPA’s OATT and posted transmission rates. The second, back-up, option
involved changes to how PacifiCorp scheduled the legacy bidirectional scheduling rights with other limitations. As noted above, the Term Sheet provided that BPA’s evaluation would take into consideration a
2021 joint study performed by BPA, Idaho Power, and PacifiCorp as well as two series capacitor
projects identified in the study that Idaho Power and PacifiCorp intended to install. For one of the projects, Idaho Power and PacifiCorp would install a series capacitor around the midpoint of the B2H line and develop a remedial action scheme (“Midline Series Capacitor Project”). For the other project, PacifiCorp would upgrade the existing series capacitor at the Meridian
substation or install an electrically equivalent series capacitor (“Meridian Series Capacitor
Project”). The joint study demonstrated that these series capacitor projects would improve performance of the transmission system with B2H in service and would allow BPA to accommodate the PTP service PacifiCorp sought as compared to the existing system configuration. The Midline and Meridian Series Capacitor Projects enhance system stability and
allow flows to be shifted from more constrained transmission facilities to less constrained
parallel facilities. Both of these factors help to optimize the utilization of the overall transmission system. The 2021 joint study provides useful information, but does not serve as a replacement for PacifiCorp submitting transmission requests and BPA evaluating those requests consistent with BPA’s OATT and applicable business practices. Therefore, the Term Sheet
specified that PacifiCorp would need to submit transmission service requests so that BPA could
do the OATT evaluation. Following execution of the Term Sheet, BPA and PacifiCorp aligned on the details for the PTP redirect requests that would be paired with the conversion of the legacy scheduling rights under
the preferred option. The second, back-up option was determined to be unworkable and did not
receive further consideration. In April and June, 2022, PacifiCorp submitted the PTP redirect requests over BPA’s OASIS. The following table describes the requests: Parent (Existing) Reservation Redirect Reservation

BPA evaluated the redirect requests consistent with its OATT and the standard evaluation processes, which are described in BPA’s business practices including the Transmission Service Request Evaluation Business Practice. BPA’s standard evaluation processes take into consideration existing obligations and higher queued requests. BPA evaluated the availability of
10
capacity to accommodate the conversion of the scheduling rights to PTP service based on the
existing bidirectional capacity over the Buckley-Summer Lake line that PacifiCorp has been
scheduling under the legacy contract (340 MW in the north-to south direction and 340 MW in the south-to-north direction). In order to pair the conversion with the redirect requests, BPA applied this bidirectional capacity to the redirected service. BPA then considered whether there were other impacts to the transmission system not reflected in the redirect and conversion
analysis. Finally, BPA’s consideration took into account the 2021 joint study and the installation
of the series capacitor projects. BPA concluded that the PTP service (the preferred option) can be accommodated with stipulations that are consistent with the Term Sheet. The PTP stipulations include the
energization of the B2H project to include the Midline Series Capacitor Project, the installation
of the Meridian Series Capacitor Project pursuant to a construction agreement between PacifiCorp and BPA, the transfer of the Goshen area assets between PacifiCorp and Idaho Power, and the commencement of BPA’s Goshen and Idaho Falls NITSAs with Idaho Power.
Accordingly, BPA is proposing to execute several agreements with PacifiCorp concurrent with
the issuance of the final decision in the Closeout letter. The PTP agreements with PacifiCorp reflect the service shown in the Redirect Reservation column of the table above and include conditions precedent to reflect the PTP stipulations. After the conditions precedent have been met, the service would commence upon energization of B2H. BPA also would execute an
amendment to the legacy agreement with PacifiCorp to remove PacifiCorp’s bidirectional
scheduling rights upon commencement of the PTP service (as noted, this amendment reflects the conversion to the PTP service). PacifiCorp is required to file the amendment to the legacy agreement with the Commission for approval. Finally, BPA would execute a construction and coordination agreement with PacifiCorp which sets forth PacifiCorp’s obligations to design,
coordinate with BPA, and install at its sole expense the Meridian Series Capacitor Project.
Following the February 8, 2022 workshop, several stakeholders asked how the proposed PacifiCorp transmission service would affect the constrained transmission system in central Oregon. Customers also asked whether BPA was considering additional upgrades in central
Oregon as part of the B2H negotiations and, if so, whether there was an opportunity for BPA’s
customers to share the costs and benefits for those upgrades. As BPA explained in its April 1, 2022, response to the workshop comments, the conversion paired with the redirected service does not affect the transmission service BPA provides to other customers in central Oregon. As described above, BPA evaluated the service consistent with its business practices which take into
account existing obligations and higher queued requests. Further, the 2021 joint study
undertaken by BPA, PacifiCorp, and Idaho Power identified the Midline and Meridian Series Capacitor Projects as upgrades that would improve system performance with B2H in service. However, these projects and the B2H project do not increase the capacity available to BPA’s other customers in central Oregon.

2. BPA providing PTP Service to Idaho Power The 2022 Letter explained that, in lieu of a previously considered asset exchange between BPA and Idaho Power under the B2H with Asset Swap proposal, Idaho Power would acquire 500 MW
11
of PTP service from BPA for delivery of northwest resources to the B2H connection at the
proposed BPA Longhorn substation. Before execution of the Term Sheet, Idaho Power
submitted a transmission request seeking this service. BPA evaluated the request as part of the 2021 TSEP Cluster Study. Following the study, BPA determined that the request could be accommodated with stipulations. The stipulations include the energization of the B2H project and the interconnection of the B2H project to the proposed BPA Longhorn substation (see
subsection 3 for discussion about the proposed B2H interconnection). Idaho Power would pay
for the PTP service pursuant to BPA’s OATT and posted transmission rates. BPA is proposing to execute the PTP agreement with conditions precedent reflecting these stipulations concurrent with the issuance of the final decision in the Closeout letter.
3. B2H Interconnection to the Proposed BPA Longhorn Substation
The northern terminus for the B2H project and the point of interconnection with BPA’s system would be BPA’s proposed Longhorn substation near Boardman, Oregon. The 2022 Letter explained that to facilitate the B2H interconnection at the proposed BPA Longhorn substation,
BPA, Idaho Power, and PacifiCorp would develop line and load interconnection and related funding and construction agreements. In February of 2022, Idaho Power as project manager for the B2H project, submitted a line and load interconnection request (L0515) for the B2H interconnection. BPA is currently studying this request, which will include environmental review, and intends to offer additional agreements and make decisions on design, advance
funding, and construction in accordance with BPA’s line and load interconnection business practice. BPA is not making a final decision to construct the proposed Longhorn substation as part of B2H with Transfer Service decision. Prior to Idaho Power’s B2H interconnection request L0515,
Umatilla Electric Cooperative (“UEC”) submitted a load interconnection request (L0482) (“UEC project”) and the construction of the proposed Longhorn substation has been identified as a need for the UEC project. At this time, the UEC project is further along in the study process than the proposed B2H interconnection. BPA has completed the technical studies for the UEC request and is currently in the process of completing environmental review of the potential impacts to the
human and natural environments (e.g.., physical, biological, and cultural resources) under NEPA. The NEPA documentation for the UEC interconnection request will be made available to the public on BPA’s website. After BPA completes the environmental studies, which is expected in February, 2023, BPA will make a final decision about the construction of the Longhorn substation in response to the UEC interconnection request. Accordingly, BPA’s decision to
construct the proposed Longhorn substation would be in response to the UEC request and would not be driven by the final decision for the B2H with Transfer Service plan of service. While BPA’s final decision to construct the Longhorn substation will be in response to the UEC request and not the B2H with Transfer Service plan of service, BPA would design the proposed
Longhorn substation to accommodate the B2H interconnection request and other future interconnection requests. Equipment specific to the UEC project and the B2H interconnection request, such as an additional 500 kV terminal for the proposed B2H interconnection, 500/230 kV transformers, and a 230 kV yard for the UEC project, would be designed, funded, and developed in accordance with BPA’s line and load interconnection business practice. BPA
12
anticipates allocating advance funding responsibilities between the UEC project and the B2H
interconnection in accordance with BPA’s line and load interconnection business practices.
Consistent with the Term Sheet in recognition of the benefits exchanged, BPA would require advance funding from the B2H project, subject to repayment through transmission credits on OATT service, for costs associated with the B2H interconnection at the proposed BPA Longhorn substation.

4. Removal of a segment of BPA’s Boardman-to-Ione transmission line A portion of BPA’s Boardman-to-Ione 69-kV transmission line is located in a right-of-way crossing the U.S Navy’s (“Navy”) Naval Weapons Systems Training Facility Boardman Property
in Umatilla County, Oregon. BPA uses this line to serve Columbia Basin Electric Cooperative,
Inc. (“Columbia Basin”). Idaho Power and PacifiCorp need a segment of this right-of-way for B2H construction. For B2H to be constructed on the right-of-way, BPA’s Boardman-Ione transmission line must be removed first. Additionally, BPA would need to find an alternative to serve Columbia Basin.
In 2019, BPA decided to enter into an amended Boardman-to-Ione transmission line land use agreement with the Navy to allow for the removal of the line from the Navy property so that the B2H project could repurpose a segment of the right-of-way, with the remaining segment to be removed to the benefit of cultural and natural resources in the area. See Bonneville Power
Administration, Record of Decision, Boardman-to-Ione 69kV Transmission Line (May 13, 2019), available at https://www.bpa.gov/-/media/Aep/efw/nepa/active/boardman-to-hemingway/board-ione-lua-nepa-rod-05-13-2019-final.pdf. BPA’s decision was contingent on multiple considerations, including BPA entering an agreement with Idaho Power and PacifiCorp to ensure that BPA would be reimbursed in full for all costs associated with removing the
Boardman-to-Ione line and providing an alternative to service Columbia Basin’s load. In the event the B2H project is not constructed, BPA will retain its right-of-way on the Navy property. On March 18, 2020, BPA, Idaho Power, and PacifiCorp executed an agreement for PacifiCorp and Idaho Power to pay or reimburse BPA for its costs associated with removing and replacing
the Boardman-to-Ione line if the B2H project is constructed. BPA’s costs include providing replacement service for Columbia Basin’s loads, which would include studies and design, environmental review, building a step down substation, tap line and tap, and other necessary construction or reconfigurations to accommodate the removal. These reimbursement commitments were acknowledged in the section of the Term Sheet describing Idaho Power and
PacifiCorp’s intent for the B2H construction funding agreement. The commitments have also been incorporated into agreements with Idaho Power, as project manager for B2H, associated with BPA’s removal and replacement of the Boardman-to-Ione line. With regard to BPA finding an alternative to serve Columbia Basin, BPA intends to request
transmission service from UEC to serve Columbia Basin’s load. As an initial step, BPA has submitted a line interconnection request to UEC. This request starts the process for BPA to construct a new step down substation and transmission facilities to connect the UEC end point of service to Columbia Basin’s system. At this time, BPA is siting, designing, and studying these proposed facilities. As planning progresses, BPA would conduct environmental review of the
13
potential impacts to the human and natural environments that could be expected from
implementing the Boardman-to-Ione line relocation. As noted above, pursuant to the March 18,
2020, agreement, BPA will recover costs associated with the Boardman-to-Ione line relocation from PacifiCorp and Idaho Power. Energization of the proposed alternative service would need to be completed by spring of 2025, to allow time to remove the old line and build the new B2H line by spring of 2026.

5. Operational agreement with Idaho Power and PacifiCorp The 2022 Letter described BPA, Idaho Power, and PacifiCorp’s intent to develop an operational agreement covering various facilities and agreements that affect Path 14 (Idaho to Northwest, the
WECC transmission path that will include B2H), Path 75 (Hemingway-Summer Lake 500kV),
and the Northwest AC Intertie. Following execution of the Term Sheet, BPA, PacifiCorp, and Idaho Power prioritized negotiation of the contracts described above. Negotiation of the operational agreement will begin this winter.
C. Assignment Agreement with PacifiCorp
The 2022 Letter explained that BPA currently purchases 200 MW of conditional firm PTP service from Idaho Power to wheel power over Idaho Power’s system for ultimate delivery to SILS customers on PacifiCorp’s system. With the construction of the B2H project, the NITSAs,
and associated asset exchanges between Idaho Power and PacifiCorp, BPA will no longer need
to procure these conditional firm PTP services. The 2022 Letter described BPA’s intent to assign its conditional firm PTP service agreements on Idaho Power’s system to PacifiCorp, subject to certain stipulations. Prior to the assignment, BPA would submit redirect requests to the points of receipt and points of delivery selected by PacifiCorp. PacifiCorp would be
responsible for all costs associated with the redirect and assignment. This redirect and
assignment is to PacifiCorp’s benefit for the B2H deal, but would not result in any increased costs to BPA. Following execution of the Term Sheet, BPA and PacifiCorp negotiated a Letter Agreement
setting out the terms for the future redirect and assignment of BPA’s conditional firm PTP
service. BPA is proposing to execute the Letter Agreement concurrent with issuing the final decision in the Closeout Letter. Pursuant to the Letter Agreement, BPA would submit redirect requests pursuant to Idaho Power’s OATT for the two conditional firm service agreements on Idaho Power’s system. BPA would request the redirected service to commence following the
energization of B2H and commencement of BPA’s NITSAs with Idaho Power. PacifiCorp
would reimburse BPA for all study costs and fees assessed by Idaho Power.
14
Following Idaho Power’s evaluation of the redirect requests, PacifiCorp would determine if the
redirected service, including any conditions Idaho Power might assess, is acceptable to
PacifiCorp. If the service is acceptable to PacifiCorp, then BPA would confirm the requests and assign the redirected reservations to PacifiCorp. If PacifiCorp determined that the redirected service was not acceptable, then BPA would withdraw the requests and, if directed by PacifiCorp, submit alternative redirect requests. If B2H is energized and BPA’s NITSAs have
commenced but PacifiCorp has not yet accepted assignment of the conditional firm PTP service
agreements, PacifiCorp would reimburse BPA for all rates and charges that Idaho Power assesses to BPA for the two 100 MW conditional firm PTP service agreements, until such time as the service is assigned to or waived by PacifiCorp.
III. Business Case for the B2H with Transfer Service Plan of Service
The 2022 Letter described BPA’s business case for the B2H with Transfer Service plan of service at a high level, noting that the proposal would provide a firm, stable, and long-term transmission path to deliver resources from the BPA transmission system to the SILS customers’ loads at an economical cost. During the February 8, 2022, workshop, BPA explained that the
estimated benefits of B2H with Transfer Service is a 35% to 52% improvement in net present
value (“NPV”) over the interim plan of service. Now that contract negotiations are complete, BPA has updated the assumptions in the business case. This letter provides an overview of BPA’s business case.
Quantitatively, BPA analyzed the costs associated with the B2H with Transfer Service plan of
service and the current interim plan of service using a NPV methodology over a 30-year horizon and with a discount rate of 2.81%. Notably, there are significant uncertainties associated with the assumptions used for a 30-year period. Therefore, BPA evaluated numerous rate, cost, and revenue assumptions to determine a range of cost savings that could be expected over a 30-year
period. On average over 30 years, the B2H with Transfer Service plan of service yields an
estimated cost of around $520 million. Over that same time period, the continuation of the current interim plan of service yields an estimated cost of around $1.24 billion. Accordingly, the B2H with Transfer Service provides an estimated $720 million of cost savings as compared to the interim plan of service.

Each of the scenarios evaluated in the business case includes significant complexity, with many factors driving cost, savings, and relative value. However four primary drivers account for the majority of the significant financial benefit associated with the B2H with Transfer Service plan of service over the current interim plan of service. First, the B2H with Transfer Service plan of
service eliminates the need to acquire two legs of transmission that BPA currently uses to serve
the SILS customers’ loads. Eliminating one leg of transmission yields an expected value of approximately $250 million in cost savings over the 30-year period. Second, Idaho Power is expected to have lower rates for NITS as compared to PacifiCorp’s rates
for NITS under the interim plan of service. As such, taking NITS from Idaho Power is expected
to have a lower cost compared to the PacifiCorp NITS costs BPA anticipates if BPA were to continue the current interim plan of service. BPA’s analysis of Idaho Power’s expected rates took into account projected increases following its construction of B2H, as well as the implications of such rate increases on BPA’s costs under the existing NITSAs for service to
15
BPA’s other preference customers in southern Idaho. The NITS service from Idaho Power is
expected to yield approximately $190 million in cost savings over the 30-year period.
Third, BPA expects $45 million in lower overall Energy Costs over the 30-year period by reducing BPA’s reliance on market power in the vicinity of the SILS customers.
Lastly, the B2H with Transfer Service plan of service yields incremental revenue for BPA
associated with 500 MW of PTP service that BPA would provide to Idaho Power. This PTP service is estimated to yield an expected value of approximately $200 million in revenue over a 30-year period.
BPA also expects $40 million in the recovery of sunk cost (the sunk cost is the Purchase Price
for the sale of BPA’s permitting interest, which includes the payment of the $30 million BPA incurred towards permitting plus the $10 million security). BPA anticipates the costs associated with purchasing transmission service from UEC to serve Columbia Basin’s load to be modest.
In addition to these quantitative financial benefits, BPA expects other substantial benefits. As
noted above, BPA’s current interim plan of service relies on a leg of transmission over Idaho Power’s system that is “conditional firm” PTP service. Conditional firm PTP service is a type of transmission service that can be curtailed more readily under certain system conditions. The conditions associated with this service are reviewable by Idaho Power every two years,
increasing the risk of additional conditions for curtailment of BPA’s PTP service over time.
With Idaho Power’s construction of B2H, BPA would receive long-term firm network transmission to serve its southeast Idaho loads. Network transmission is redispatched rather than curtailed like PTP, substantially reducing BPA’s risk of service to its loads.
Additionally, the increase in transmission capacity across Idaho Power’s system from the
construction of B2H would enhance BPA’s ability to serve its other existing preference customers currently served by NITSAs over Idaho Power’s transmission system. BPA uses these existing NITSAs to serve 13 preference customers in the Burley, Idaho area, Oregon Trail Electric Cooperative in eastern Oregon, and the City of Weiser in western Idaho. BPA also uses
an existing NITSA to deliver reserve power from the federal system to the United States Bureau
of Reclamation and irrigation customers. The completion of the B2H project would create capacity on Idaho Power’s system that could be used to serve the load growth of these existing customers. Accordingly, potential transmission system congestion on federal power deliveries to these customers over Idaho Power’s system would be alleviated.

The B2H with Transfer Service plan of service also reduces BPA’s reliance on market power in the vicinity of the SILS customers. The current interim plan of service has BPA sourcing market power from the desert Southwest, which carries with it resource adequacy considerations and negative implications for the carbon content of BPA’s fuel mix. Reduced market reliance
alleviates these negative effects and generally reduces BPA’s cost risk in a region where resource
retirements loom and BPA has already observed reduced liquidity. Additionally, while providing PacifiCorp with PTP service in central Oregon would not result in additional revenues for BPA because it reflects the redirect of existing PTP service that
16
PacifiCorp currently pays for, that aspect of the B2H with Transfer Service arrangement works
to achieve BPA’s strategic objectives of converting legacy service to standard OATT service.
Idaho Power and PacifiCorp would also fund the series capacitor projects that improve system performance when B2H is in service. Lastly, the B2H with Transfer Service plan of service avoids the complexities and complications of joint ownership and asset swaps originally considered in the B2H with Asset Swap proposal (a description of the B2H with Asset Swap
proposal was provided in the 2022 Letter).
IV. Public Process and Next Steps BPA is proposing to proceed with the B2H with Transfer Service plan of service and execute binding contracts with Idaho Power and PacifiCorp. Public participation and input on the B2H
with Transfer Service plan of service is important to BPA. Before BPA makes a final decision,
BPA is seeking public comment through February 9, 2023. Comments should be submitted here. BPA will hold a workshop to answer questions about the B2H with Transfer Service plan of service on January 23, 2023. Please find details of that workshop here. BPA is also conducting appropriate NEPA processes. If BPA decides to proceed, BPA will issue a Closeout letter to the
region on or about March 23, 2023, describing its reasoning and responding to comments.
If BPA’s final decision is to proceed, BPA would execute the Purchase, Sale, and Security Agreement, the two NITSAs with Idaho Power, the PTP agreements and other related transmission agreements with PacifiCorp and Idaho Power, and the Letter Agreement with
PacifiCorp concurrent with issuing the Closeout letter to the region. The decision to execute
agreements associated with the proposed B2H interconnection to the BPA Longhorn substation and the removal and replacement of BPA’s Boardman-to-Ione transmission line would be in accordance with BPA’s line and load interconnection processes.

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

CONFIDENTIAL

REQUEST NO. 34

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

CONFIDENTIAL

REQUEST NO. 35

ATTACHMENT NO. 1
SEE ATTACHED SPREADSHEET