20230407IPC to Staff 38-41 Redacted.pdf

Donovan E. Walker
Lead Counsel
[e-mail]
April 7, 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
Third Production Request of Commission Staff.
The confidential version 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 April 7, 4:07PM
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-23-01
Idaho Power Company’s Application for a Certificate of Public Convenience and
Necessity for the Boardman to the Hemingway 500-kV Transmission Line

The undersigned attorney, in accordance with RP 67, believes that Response to
Request for Production No. 41 in Idaho Power Company’s Response to Staff’s Third
Production Request dated April 7, 2023, may contain information that Idaho Power
Company or a third party claims is confidential as described in Idaho Code § 74-101, et
seq. and § 48-801, et seq., and as such is exempt from public inspection, examination,
or copying.

DATED this 7th day of April 2023.

Donovan Walker
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD 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.
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CASE NO. IPC-E-23-01

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Third Production Request of the Commission Staff (“IPUC or
Commission”) dated March 24, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 2
REQUEST FOR PRODUCTION NO. 38: Company witness Ellsworth refers to
the 2021 Integrated Resource Plan (“IRP”) portfolios when describing how the proposed
Boardman to Hemingway (“B2H”) transmission line is the least-cost least-risk option to
fill the Company’s expected 2026 capacity deficit. Ellsworth Direct at 47. Please
provide a worksheet that includes updated cost estimates in 2023 dollars for the
portfolio alternatives listed in Table 3 of Ellsworth’s direct testimony. Ellsworth Direct at
44.
RESPONSE TO REQUEST FOR PRODUCTION NO. 38: Idaho Power does not
have comprehensive updated portfolio costs for all the portfolios identified in Table 3 as
those are being updated through development of the 2023 IRP. The Company
anticipates having preliminary 2023 IRP modeling results, which would include
preliminary portfolio costs similar to those presented in Table 3, available during the
next IRP Advisory Council meeting. It is important to note however, as explained in Mr.
Ellsworth’s direct testimony, while the total B2H costs have increased since
development of the 2021 IRP, the Preferred Portfolio net present value cost impact
results in an increase from $159.6 million to $238.9 million, a $79.3 million impact. By
inspection, a $79.3 million increase does not result in a change to the Preferred
Portfolio, as the best non-B2H portfolio from the 2021 IRP is $266 million more costly.
And, the best non-B2H portfolio would see similar increases due to increased Gateway
West costs.
In addition, if Idaho Power were to update costs of all capital projects based on
current conditions, the B2H project is not the only variable that would change. A primary
factor driving the increase in the B2H cost estimate is increased material and labor

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 3
costs due to inflation and supply chain issues—which would impact the cost of capital
projects in all portfolios studied. B2H replacement resources have also seen price
increases due to inflationary and supply chain pressures since the 2021 IRP was
published, therefore, the least-cost non-B2H portfolio would experience cost increases
as well. Even with the cost increase, the Company has sufficient information to
ascertain that the B2H project remains the least-cost, least-risk option using the
December 2022 updated estimate of $670.5 million.1
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution, & Resource Planning Director, Idaho Power Company.

1 In the Company’s initial filing made in January 2023, the $670.5 million figure was redacted as
confidential. However, since that time updated guidance for total B2H project costs has been publicly
provided. Therefore, the $670.5 million cost estimate is no longer confidential. Additionally, as discussed
in the Company’s Response to Request for Production No. 3, this figure was later revised to $669.3
million to correct for two errors that lowered the total cost of the project.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 4
REQUEST FOR PRODUCTION NO. 39: In its response to Production Request
No. 6, the Company stated, “While the Company is not seeking explicit approval of the
partnership agreements in this case, the agreements form the foundational information
necessary to derive the estimated cost of the project Idaho Power will ultimately seek to
recover from its customers.” Please provide workpapers showing the estimated 20-yr
levelized costs and revenues for each of the projects and transactions listed in
Production Request No. 6. Please summarize the net estimated impact to customers.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39: Please see
Attachment 1 for the Present Value of the Revenue Requirement (“PVRR”) calculation
file that computes the estimated levelized cost of the B2H project included in the 20-
year IRP modeling horizon, including an offset for estimated incremental transmission
wheeling revenues. The resulting levelized cost of approximately $13.75 million2 per
year is based on the total cost of the B2H project, including the NPV of the estimated
Bonneville Power Administration (“BPA”) permitting buyout. The total B2H project cost is
inclusive of the costs associated with all items for which the Company is requesting a
CPCN, and identified in the Company’s Response for Production No. 6(a), as well as
the BPA permitting buyout under the Purchase, Sale and Security Agreement. The
incremental transmission wheeling revenue computation incorporates any impacts to
Idaho Power’s Open Access Transmission Tariff transmission formula rate resulting
from the Network Integration Transmission Service Agreements with BPA, the redirect
by BPA of two point-to-point transmission service agreements from the Company to
PacifiCorp, and the 100 MW of incremental wheeling volumes from PacifiCorp.

2 See cell J94 of the “B2H 20%” tab.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 5
Attachment 1 does not reflect costs associated with the asset exchanges, if any, as
those are still under development, or costs associated with the Midpoint 500/345-kV
Transformer Project or the Kinport-Midpoint 345-kV Series Capacitor Bank Project, as
they are not dependent on B2H.
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 6
REQUEST FOR PRODUCTION NO. 40: Please quantify the expected cost of
the Idaho Power 500 MW Mid-Columbia (“Mid-C”) hub to Longhorn point-to-point
(“PTP”) Transmission Service Agreement (“TSA”) with Bonneville Power Administration
(“BPA”). Please provide supporting documents and worksheets that include the terms
of the TSA.
RESPONSE TO REQUEST FOR PRODUCTION NO. 40: Please see Attachment 1
which includes Exhibit A from the 500 MW Mid-C to Longhorn PTP TSA, describing the
terms of the reservation. Attachment 2 includes the current BPA transmission rate
schedule as of March 2023. The rates applicable to the TSA are the Long-Term PTP-22
Point-To-Point rate of $1.648/kw/mo and the Scheduling, System Control and Dispatch
Service for PTP customers rate of $0.316/kw/mo. The sum of these transmission
charges is equivalent to a transmission reservation rate of $2.69 per MWh.
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 THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 7
REQUEST FOR PRODUCTION NO. 41: As a supplement to Company
Response to Production Request No. 14:
a. For each event included in the table, please explain how the Company
maintained operations and served load for the Company’s customers.
b. For ten of the listed outage events, the Company’s actions are described as
“Limitation or reduction of scheduled energy between the Pacific Northwest and
Idaho Power (in both directions).” Please quantify the limitation or reduction for
each event.

RESPONSE TO REQUEST FOR PRODUCTION NO. 41:
a. The Company does not have detailed records of how it maintained operations
and served load for the listed Hemingway – Summer Lake 500-kV events. Idaho
Power plans and operates the system to withstand all single credible
contingencies including transmission elements that impact lines such as the
Hemingway – Summer Lake 500-kV. North American Electric Reliability
Corporation (“NERC”) standard TPL-001-4 establishes system planning
performance requirements for the Bulk Electric System. Within NERC standard
TPL-001-4, the loss of the Hemingway – Summer Lake 500-kV line is considered
a P1-2 Single Contingency of a Transmission Circuit. For P1-2 contingencies
during normal system conditions, non-consequential load loss is not allowed as a
mitigating action. Operationally, the Company continually runs Real Time

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 8
Contingency Analysis (“RTCA”) to ensure operator awareness of potential
system conditions and to prepare for the next possible contingency. Therefore, it
is an expected result that the transmission events listed in the Company’s
Confidential Response to Production Request No.14 did not result in loss of load.
b. The table below lists the Total Transfer Capability (“TTC”) of the Idaho to
Northwest path before and after the listed line loss events. Real time power
schedules needed to be adjusted to be within these TTC values.

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 9

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 THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 10
DATED at Boise, Idaho this 7th day of April 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 11
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 7th day of April 2023, I served a true and correct
copy of Idaho Power Company’s Response to the Third 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

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

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Industrial Customer of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702

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Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
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X EMAIL [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 12
City of Boise
Ed Jewell
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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Idaho Conservation League
Marie Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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IDAHO POWER COMPANY’S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF - 13
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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______________________________
Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

REQUEST NO. 39

ATTACHMENT NO. 1

SEE ATTACHED SPREADSHEET

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

REQUEST NO. 40

ATTACHMENT NO. 1

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-01

IDAHO POWER COMPANY

REQUEST NO. 40

ATTACHMENT NO. 2
Bonneville Power Administration Transmission Services
October 2021
2022 Transmission, Ancillary and Control Area Services Rates Summary
Effective October 1, 2021
Transmission Rates
1. FPT-22.1 and FPT-22.3 1/ Formula Power Transmission
[see rate schedule]
NT-22 Network Integration 2/ Rate Short Distance Discount
$2.031 /kW/mo [see rate schedule]
PTP-22 Point-To-Point 2/ 3/ Long-Term Short-Term (firm and non-firm) – Monthly, Weekly, Daily • Days 1 through 5 • Days 6 and beyond – Hourly (firm and nonfirm) Short Distance Discount Rate
$1.648 /kW/mo $0.076 /kW/day $0.054 /kW/day 4.740 mills/kWh [see rate schedule]
IS-22 Southern Intertie 2/ 3/
Long-Term Short-Term (firm and non-firm) – Monthly, Weekly, Daily • Days 1 through 5 • Day 6 and beyond – Hourly (firm and nonfirm)
$1.118 /kW/mo $0.051 /kW/day $0.037/kW/day 10.290 mills/kWh
IM-22 Montana Intertie Rate 2/ 3/ Long-Term Short-Term (firm and non-firm) – Monthly, Weekly, Daily • Days 1 through 5 • Days 6 and beyond – Hourly (firm and nonfirm)
$0.524 /kW/mo $0.024 /kW/day $0.017 /kW/day 1.510 mills/kWh
IE-22 Eastern Intertie Rate
7. Regional Compliance Enforcement and Regional Coordinator Rates Regional Compliance Enforcement Rate Regional Coordinator Rate
0.04 mills/kWh 0.04 mills/kWh

Bonneville Power Administration Transmission Services
October 2021

Ancillary and Control Area Services Rates (ACS-22)
8.
Service For NT customers For PTP customers Short-Term (firm and non-firm PTP) – Monthly, Weekly, Daily • Days 1 through 5 • Days 6 and beyond – Hourly
$0.389 /kW/mo $0.316 /kW/mo $0.015 /kW/day $0.010 /kW/day 0.910 mills/kWh
9. Reactive Supply and Voltage Control From 2/ 3/ Generation Sources Service (GSR)

Formula rate determined quarterly [see rate schedule]
Regulation and Frequency Response Service
Non-EIM Rate EIM Rate 0.47 mills/kWh 0.44 mills/kWh
Energy Imbalance Service [see rate schedule]
12. Operating Reserve – Spinning Reserve Service – Spinning – Spinning Default Energy Delivered
11.05 mills/kWh 12.71 mills/kWh [see rate schedule]
13. Operating Reserve -- Supplemental Reserve Service
– Supplemental – Supplemental Default Energy Delivered
7.22 mills/kWh 8.30 mills/kWh
[see rate schedule]
14. Generation Imbalance Service

[see rate schedule]
15.Variable Energy Resource Balancing ServiceNon-EIM and EIM VERBS Rates For Wind Resources Non-EIM VERBS Rates
• Regulating Reserves • Non-Regulating Reserves EIM VERBS Rates • Regulating Reserves • Non-Regulating Reserves Non-EIM and EIM VERBS Rates For Solar Resources Non-EIM VERBS Rates •
$0.367 /kW/mo $0.439 /kW/mo $0.358 /kW/mo $0.395 /kW/mo
Bonneville Power Administration Transmission Services
October 2021
• EIM VERBS Rates • Regulating Reserves • Non-Regulating Reserves
$0.282 /kW/mo $0.174 /kW/mo
Dispatchable Energy Resource Balancing Service Non-EIM and EIM DERBS Rates Non-EIM Rates
• Incremental Reserves
• Decremental Reserves EIM Rates
• Incremental Reserves
• Decremental Reserves
21.629/mills/kW max hrly deviation 1.230/mills/kW max hrly deviation 21.303/mills/kW max hrly deviation 1.240/mills/kW max hrly deviation
General Rate Schedule Provisions
Utility Delivery Charge
Note: Section II of the transmission rate schedules includes adjustments, charges, and special
rate provisions for transmission rates. 1/ FPT services/rates include the two required Ancillary Services--Scheduling, System Control and Dispatch (SCD) and Reactive Supply and Voltage Control from Generation Sources (GSR).
 The FPT-22.1 charges adjust quarterly for changes in the Reactive Supply and Voltage Control from Generation Sources (GSR) rate. 2/ Transmission customers must purchase the two required ancillary services—SCD and GSR—from BPA in accordance with BPA’s Open Access Transmission Tariff. 3/ PTP Transmission Service (PTP, IS, and IM rate schedules)
 Long-Term Service is one year or greater, reserved in annual increments.
 Short-Term Service is less than one year. For any reservation of short-term service, the "Days 1 through 5" rate shown above will be applied to the first 5 days of the reservation, while the "Day 6 and beyond" rate will be applied to the remaining days of the reservation.
 Charges for the two required Ancillary Services are applied in the same manner.
4/ Charges reflect errata on 2022 Transmission, Ancillary, and Control Area Service Rate Schedules and General Rate Schedule Provisions (FY 2022–2023) in Errata (BP-22-A-02-AP02-E01).