20230725IPC to Staff 19-43 - Amended_Redacted .pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

July 25, 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-23-05
In the Matter of Idaho Power Company’s Application for a Certificate of
Public Convenience and Necessity to Acquire Resources to be Online by
2024 and Approval of a Power Purchase Agreement with Franklin Solar LLC

Dear Ms. Noriyuki:

Attached for electronic filing, please find Idaho Power Company’s Redacted
Amended Response to Staff’s Confidential Second Production Request to Idaho Power
Company in the above matter.

The confidential version will be provided to the parties who have executed the
Protective Agreement.

Please feel free to contact me directly with any questions you might have about
this filing.

Very truly yours,

Donovan E. Walker
DEW:sg
Enclosures
RECEIVED
2023 JULY 25, 2023 4:54PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 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 TO
ACQUIRE RESOURCES TO BE ONLINE
BY 2024 AND FOR APPROVAL OF A
POWER PURCHASE AGREEMENT WITH
FRANKLIN SOLAR LLC.
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CASE NO. IPC-E-23-05

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

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Confidential Second Production Request of the Commission Staff
(“Commission” or “Staff”) dated June 15, 2023, herewith submits the following
information:

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 19: Table 3 of the 2022 All Source Request
for Proposals ("RFP") shows that power purchase agreements ("PPAs") were not allowed
for the storage components of the products "Battery Energy Storage (BESS)", "Solar +
BESS", and "Wind +BESS"; only asset purchases are allowed for the storage
components. Please respond to the following:
a. Please explain why PPAs are not allowed for the storage components and
provide evidence to support your answer.
b. Please reconcile the statement made in Hackett, DI, page 34 that "[t]he RFP did
not restrict ownership structure or resources," with the fact that PPA-based storage
projects were not allowed for submission in the RFP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: As described in the
Direct Testimony of Mr. Hackett, respondent ownership of a standalone BESS was
allowed. Specifically, on April 13, 2022, with Addendum No. 7, the Company notified all
prospective respondents of an addendum to the product table which was revised to clarify
that respondents had the opportunity to submit proposals for a respondent owned battery
energy storage resource type with a subsequent Battery Storage Agreement product
type. This was in addition to the battery energy storage resource type with a subsequent
Build Transfer Agreement product type with Idaho Power ownership as initially identified
in the product table. Column 10.a of Table 3 – Storage Products in the Key Product
Specification Tables included as Exhibit No. 3 reflects the clarification. While this did not
directly address the PPA-based storage component of the Solar + BESS and Wind +
BESS resource types presented in Table 3 of Exhibit No. 3, it did allow for a BESS
structure. Further, although not explicitly identified, some respondents provided proposals

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
for PPA-based storage as a component of the Solar + BESS resource options. These
projects, identified in Confidential Exhibit No. 4 as those proposals that included a Battery
Storage Agreement option, were evaluated accordingly.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO. 20: Page 21 of Mr. Hackett's Testimony
states that the Inflation Reduction Act of 2022 ("2022 IRA") provides for extension of the
current investment tax credits ("ITC") and production tax credits ("PTC") and a new ITC
for standalone energy storage. Please respond to the following:
a. Please confirm that the 100 MW solar project paired with the 60 MW BESS is
eligible for the current, extended ITC, while the 12 MW standalone BESS is
eligible for the new ITC provided in the 2022 IRA.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Idaho Power’s
assumption is that Duke Energy Renewables Solar, LLC (“Duke”) has included the benefits
associated with a PTC or ITC for the solar project and that has been reflected in their PPA
pricing. The PPA between Duke and the Company, however, is not contingent upon
Duke’s eligibility for the PTC or ITC. Pursuant to Section 4.8 of the PPA, included as
Confidential Exhibit No. 5, Duke will notify Idaho Power whether PTCs or ITCs were
claimed on or before the commercial operation date. Regarding the Company-owned 12
MW and 60 MW BESS projects, Idaho Power anticipates that the projects will qualify for
ITCs under the 2022 IRA.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 21: Please confirm that for "gas-fired
convertible to hydrogen" products, the gas-fired plant component can be a reciprocating
gas engine, a combined cycle combustion turbine, a simple cycle combustion turbine, or
an aeroderivative listed on Exhibit N of the 2022 RFP. Also, please explain why gas-fired
plants not convertible to hydrogen are not considered in the 2022 RFP.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: The 2022 RFP was not
intended to be exclusionary or specific and relied on respondents to propose an
appropriate “gas-fired convertible to hydrogen” product. Consistent with the resource
assumptions used in the 2021 Integrated Resource Plan, Idaho Power believed it was
important to ensure gas-fired products could convert to clean hydrogen to provide greater
long-term operational viability of the resources considering the uncertainty of future clean
energy policies and/or requirements.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION NO. 22: Please explain why liquidated damages
due to Output Shortfall (Section 7.12.2.3 of PPA) does not consider transmission costs
(see detailed discussions in Staff's comments and Idaho Power's reply comments in Case
No. IPC-E-22-29).
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: Transmission costs
have not traditionally or historically been called out separately in the liquidated damages
calculation for the monthly output guarantee shortfall. The Output Shortfall is the
incremental difference, or “shortfall”, of not delivering at least 90 percent of the Estimated
Monthly Output for the month. As explained in the referenced Pleasant Valley solar case,
it may or may not be the case, as the question presumes, that there would be transmission
costs. In many instances, a true “cover” or replacement power would be unlikely to be
delivered to the Project’s Point of Delivery. Liquidated damages are applied in situations
where actual damages are difficult or impossible to predict with certainty, and the parties
agree to an approximation as being reasonable in the circumstances. The difficulties in
predicting if, when, how, and to what extent there may be an Output Shortfall below the
Output Guarantee, and if so, if, when, how, and to what extent Idaho Power may be
covering the lost generation or applying replacement power, make liquidated damages
appropriate, and the estimation based upon the difference between market and contract
price, including Green Tags, is a typical, industry standard kind of liquidated damage
calculation for this circumstance. The liquidated damages are based on Idaho Power’s
cost to cover, which itself is based on the difference between market price and contract
price, plus the cost of Green Tags, not received with the generation. It is an amount that
is applied as liquidated damages without regard to what actual damages may or may not

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
be.
The response to this Request is sponsored by Donovan Walker, Lead Counsel,
Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
REQUEST FOR PRODUCTION NO. 23: Please respond to the following regarding
Seller's Cost to Cover (Section 1.147 of PPA):
a. Please confirm that Seller's Cost to Cover is intended to compensate the Seller in
case Idaho Power does not accept the Seller's energy and the Seller has to sell
the energy somewhere else at a lower price.
b. If confirmed, please explain whether the Seller can sell both energy and Green
Tags.
c. If the Seller can sell both energy and Green Tags, please explain why Seller's
Cost to Cover does not consider the values of Green Tags.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23:
a. Yes, please see (c) below.
b. Yes, please see (c). below.
c. The amount Idaho Power would pay, if the Company wrongfully failed to purchase
under the PPA is set out in Section 12.2.2, included as Confidential Exhibit No. 5.
The Seller’s Cost to Cover is multiplied by the Net Output so not purchased, less
any amounts received by Seller in sales to someone else under its duty to mitigate.
There is no value specified for Green Tags in Idaho Power’s purchase price in the
PPA. If Seller were to sell Green Tags, then those amounts would be deducted
along with energy sales.
The response to this Request is sponsored by Donovan Walker, Lead Counsel,
Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST FOR PRODUCTION NO. 24: Section 4.1 of PPA states the contract
term is years. Please provide the life expectancy of the 100 MW solar panels. Also,
please explain whether the Company or the Seller plans to maintain performance and
capacity over the contract term and/or extend the life expectancy of the solar panels, if
the life expectancy is shorter than the contract term?
RESPONSE TO REQUEST FOR PRODUCTION NO. 24: Idaho Power has not
evaluated the expected life of the solar panels as the Seller has full responsibility to
maintain the solar panels and the entire system for the term of the PPA. In particular,
Exhibit 4 of the PPA identifies the expected energy output anticipated over the term of the
PPA.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10
REQUEST FOR PRODUCTION NO. 25: Please answer the following regarding
the 60 MW BESS and the12 MW BESS:
a. Please provide the life expectancy of the two BESS systems.
b. Please explain whether the Company plans to maintain performance and
capacity of the BESS projects over the expected life of the battery and/or contract term
of the solar PPA.
RESPONSE TO REQUEST FOR PRODUCTION NO. 25:
a. The design life expectancy as evaluated for each of the two BESS systems is
twenty years.
b. Idaho Power will maintain the performance and capacity of each BESS system
over the design life, and potentially longer through ongoing and routine
maintenance and capacity augmentation.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
REQUEST FOR PRODUCTION NO. 26: Page 30 of Mr. Hackett's Testimony
states that besides the Build Transfer Agreement, Idaho Power will enter into a Shared
Facilities Agreement and a Long-Term Services Agreement for O&M Services performed
by the energy storage project following commercial operation of the project. Please
respond to the following:
a. Please explain the purpose of the Shared Facilities Agreement and list all the
parties committing to the agreement.
b. Please explain the purpose of the Long-Term Services Agreement for O&M
Services and list all the parties committed to the agreement.
c. Will the Long-Term Services Agreement for O&M Services ensure that the
performance capabilities and capacities of the project will be maintained over
their useful life?
d. Will there be a separate Long-Term Services Agreement for O&M Services for
the 12 MW BESS? Please explain.
e. Does the Company plan to seek Commission approvals of the Shared Facilities
Agreement and the Long-Term Services Agreement for O&M Services after they
are signed?
f. Does the Shared Facilities Agreement involve any extra costs? If so, please
provide the workpaper that lists each cost and explain whether each cost is
included in the bidding price.
g. Does the Long-Term Services Agreement for O&M Services involve any extra
costs? If so, please provide the workpaper that lists each cost and explain whether
each cost is included in the bidding price.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12
RESPONSE TO REQUEST FOR PRODUCTION NO. 26:
a. The Shared Facilities Agreement is a co-tenancy agreement between the Project
Company (which will eventually be owned by Idaho Power), Franklin Solar, and
Duke Energy Renewable Services as defined in the Build Transfer Agreement,
included as Confidential Exhibit No. 6. The intent is to generally define the
infrastructure, ownership, and use rights of the step-up substation that will be
utilized by the 100 MW solar photovoltaic (“PV”) facility and the 60 MW Battery
Energy Storage System (“BESS”) to interconnect to the Idaho Power grid.
b. Idaho Power will negotiate a Long-Term Services Agreement (“LTSA”) in which
quarterly and annual preventative maintenance, warranty work, corrective
maintenance, performance monitoring, and other services will be performed to
ensure ongoing reliable performance. Idaho Power will enter into the LTSA likely
with the battery supplier or an authorized service provider prior to commercial
operation.
c. Yes.
d. Yes. An LTSA as described in part (b) above will be executed for both the 12 MW
Hemingway BESS and the 60 MW BESS (Franklin BESS). Generally, each project
site requires a unique LTSA that conforms to the specific performance and
capacity requirements and will likely be with different service providers.
e. No. The Company plans on including its request for recovery of the expenses
associated with any Shared Facility Agreements or LTSA’s as part of a future rate
proceeding.
f. The Shared Facilities Agreement has not yet been executed; however, Idaho

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 13
Power does not anticipate any additional costs. Historically, Shared Facilities
Agreements executed by the Company have had very small annual payments to
share in maintenance activities.
g. The LTSA has not been executed and thus, the costs are unknown. However, an
LTSA cost was included in the evaluation on all BESS projects for equal
comparison based on historical knowledge and industry estimates.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
REQUEST FOR PRODUCTION NO. 27: Page 33 of Mr. Hackett's Testimony
states that the Company estimates the 12 MW storage project is and the 72
MW storage is .
Please respond to the following:
a. Are the two costs all-in costs? What services and products do these costs include?
b. How are the amounts determined? Please provide a cost breakdown.
c. In the second LTCE analysis, the 60 MW BESS was originally 20 MW with a
cost of (equal to ). However, in the Build
Transfer Agreement, the 60 MW BESS costs (equal to
). Please explain the factors contributing to the price reduction.
d. In the second LTCE analysis, the 12 MW BESS was originally 46 MW with a
cost of (equal to ). However, the Company
estimates the cost associated with the 12 MW BESS is (equal to
). Please explain the factors contributing to the price increase.
RESPONSE TO REQUEST FOR PRODUCTION NO. 27:
a. These costs represent total all-in costs to bring 12 MW and 72 MW to commercial
operation by June 1, 2024, including purchase and installation of the batteries and
ancillary equipment such as transformers, inverters, cables, networking
equipment, foundations, structures, etc. These costs include full turn-key
implementation from design and engineering to procurement and construction.
b. The contract associated with the 60 MW of battery storage provides for full turn-
key installation, therefore a lump sum payment for the base purchase price, as
outlined in Section 2.5 of the Build Transfer Agreement provided as Confidential

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15
Exhibit No. 6, will be made by Idaho Power. At the time the Company’s request in
this case was prepared, the cost estimate provided for the 12 MW of battery
storage was performed at a high level using the 80 MW Hemingway BESS costs
as a basis. Please see the Company’s Response to Production Request No. 43
for a detailed breakdown of the most recent estimate of costs associated with the
12 MW of battery storage.
c. Idaho Power does not have insight into the $/MW cost conclusions and the
attributable factors that influence those costs as lump sum values provided by the
respondents were converted to a levelized cost and utilized in the LTCE modeling
in AURORA. The assumption is that both economies of scale and impacts of the
Inflation Reduction Act of 2022 likely changed the $/MW proposals offered by the
respondents.
d. See part (c) above.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
REQUEST FOR PRODUCTION NO. 28: Section 9.2.2. of PPA states the Default
Security is per kW of Nameplate Capacity Rating for the first ten years and per
kW of Nameplate Capacity Rating for the remainder term. Please explain why the
per kW used in the Pleasant Valley Solar contract in Case No. IPC-E-22-29 is not used.
RESPONSE TO REQUEST FOR PRODUCTION NO. 28: Both the referenced
Pleasant Valley Solar PPA and this PPA (Franklin) contain $90 per kW of Project
Development Security pursuant to Section 9.1 of each PPA. However, Pleasant Valley
Solar accepted the Company’s starting position to keep the same amount of security in
place ($90 per kW) for ongoing Default Security pursuant to Section 9.2.2, whereas
Franklin Solar was not willing to do so, and the $45/kW for the first 10 years and $35/kW
for the remainder of the PPA was negotiated. The security in the Pleasant Valley Solar
PPA at $90 per kW provides more security than the lower, negotiated amounts in the
Franklin Solar PPA, but that does not mean that the Franklin Solar PPA is insufficient. It
was the best position the Company was able to negotiate, and still provides $90 per kW
to cover the biggest risk and obstacle, i.e., constructing the project and bringing it online.
Once the project is constructed, operational, and meets the commercial operation date,
it is much more likely to continue to operate, and therefore less risky.
The response to this Request is sponsored by Donovan Walker, Lead Counsel,
Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 17
REQUEST FOR PRODUCTION NO. 29: Section 12.2.2 Remedy for Idaho
Power's Failure to Purchase states "...less amounts received by Seller pursuant to
Section 12.7." Please confirm that Section 12.7 should have been Section 12.6.
RESPONSE TO REQUEST FOR PRODUCTION NO. 29: This appears to be a
typographical error. Section 12.2.2 is referring to the duty to mitigate, and should have
referenced Section 12.6, Duty/Right to Mitigate, rather than Section 12.7, Security.
The response to this Request is sponsored by Donovan Walker, Lead Counsel,
Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18
REQUEST FOR PRODUCTION NO. 30: Section 2.5 of Build Transfer Agreement
lists a Base Purchase Price of . Please describe the specific products and
services included in the Base Purchase Price.
RESPONSE TO REQUEST FOR PRODUCTION NO. 30: The Base Purchase
Price provides all Membership Interests to Idaho Power as defined in the Build Transfer
Agreement, included as Confidential Exhibit No. 6. In general, this is a turn-key
commercially operational 60 MW battery energy storage system to be owned and
operated by Idaho Power. The Base Purchase Price does not include any ongoing
maintenance costs.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
REQUEST FOR PRODUCTION NO. 31: Page 31 of Build Transfer Agreement
states that Jackpot-Franklin Shared Facilities Agreement shall have been amended and
restated. Please explain in detail why the agreement needs to be amended.
RESPONSE TO REQUEST FOR PRODUCTION NO. 31: The referenced
language is condition (j) to Section 2.9 of the Build Transfer Agreement, which lists the
Conditions Precedent to Developer’s Obligation to Complete the Closing. Section 2.9(j)
states in its entirety that, “The Jackpot-Franklin SFA shall have been amended and
restated to (i) remove Franklin Interconnection, LLC as a party thereto and (ii) add
Franklin Solar and the Project Company as parties thereto.” This same Condition
Precedent appears in Section 2.8(v) as an identical condition to the Buyer’s obligation to
complete the closing.
The Agreement needs to be amended to do exactly what is referenced: remove
Franklin Interconnection, LLC (which is an entity that was created by the developer and
executed the current Shared Facilities Agreement with Jackpot Solar) and to add in its
stead Franklin Solar (for the interconnection of the solar photovoltaic facility) and the
Project Company, which is the battery storage company that is being purchased by Idaho
Power pursuant to the Build Transfer Agreement.
The response to this Request is sponsored by Donovan Walker, Lead Counsel,
Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 20
REQUEST FOR PRODUCTION NO. 32: Response No. 11 in Case No. IPC-E-22-
13 states that the installation of a battery storage system at a distribution substation this
year will provide the Company first-hand experience with operation and maintenance of
a smaller-scale system.
Please respond to the following:
a. Has the battery storage system been installed?
b. Has the Company gained any first-hand experience from the smaller-scale
system? If so, what has been learned?
c. Has the Company gained any first-hand experience from the 40 MW and the 80
MW projects with Powin? If so, what has been learned?
d. Based on what has been learned, did the Company consider performing the O&M
in-house rather than through a 3rd party? Please provide the cost/benefit analysis
for the two alternatives.
RESPONSE TO REQUEST FOR PRODUCTION NO. 32:
a. Due to supply chain delays, the anticipated smaller-scale battery systems as well
as the 40 MW and 80 MW energy storage projects, for which the Company
received a CPCN in Case No. IPC-E-22-13, have not yet been commissioned and
therefore are not operational. However, Idaho Power anticipates more than 100
MW of battery storage will be fully operational throughout the summer 2023.
b. As described in part (a), no operational experience has been gained to date.
However, lessons learned from the construction side include the importance of
collaboration and coordination of site deliveries, installation practices, foundation
and conduit design standards, and development of commissioning procedures, all

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 21
of which will support the completion of the 12 MW Hemingway energy storage
project proposed in this case.
c. See parts (a) and (b) above.
d. Due to Idaho Power’s lack of experience and the lack of trained personnel to
operate energy storage systems, an LTSA was required to ensure reliable
performance. Therefore, a cost/benefit analysis was not feasible. Idaho Power will
have the opportunity to train internal personnel and evaluate the cost/benefit of
establishing an internal workforce capable of maintaining the battery systems in
the future.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 22
REQUEST FOR PRODUCTION NO. 33: Page 10 of the Application states the
Company intends on adding the 12 MW storage to the contract executed with Powin on
February 28, 2022 through a change order. Or, in the alternative, use a different supplier
the Company has available. Please answer the following:
a. Has the Company made a decision on which option to choose?
b. If so, has the Company signed a contract for the 12 MW BESS?
c. If a contract has been signed, did the parties agree to the price submitted in the
RFP?
d. Does the Company plan to submit the contract for approval?
RESPONSE TO REQUEST FOR PRODUCTION NO. 33:
a. Idaho Power has chosen Powin to supply the 12 MW Hemingway BESS project.
b. Yes. Idaho Power and Powin executed a Battery Energy Storage Agreement
(“BESA”) on June 8, 2023. The BESA is included as Confidential Attachment 1.
c. The BESA includes a cost of for the battery supply and the total
cost for turn-key installation is estimated to be , which is less than
the initially anticipated value described in the Company’s Response to Request for
Production No. 27. Note, that the BESA is based on the purchase of 36 MW of
battery storage which includes the 12 MW Hemingway BESS project as well as
the 24 MW of battery storage described in the Company’s request in Case No.
IPC-E-23-20.
d. No. However, Idaho Power will request a prudence determination of the 12 MW
and 24 MW battery storage systems as part of a future rate proceeding.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 23
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 24
REQUEST FOR PRODUCTION NO. 34: Page 22 of Mr. Ellsworth's Testimony
states that the Company conducted a competitive solicitation through an RFP to help
meet Idaho Power's previously identified capacity needs of 85 MW in 2024 and 115 MW
in 2025. Please respond to the following:
a. When were the capacity needs of 85 MW in 2024 and 115 MW in 2025
identified?
b. Was the 100 MW solar and 20 MW BESS selected to meet this original 85 MW
deficit?
c. Please provide evidence of the capacity needs of 85 MW in 2024 and 115 MW in
2025 in the form of Load and Resource Balance ("L&R").
RESPONSE TO REQUEST FOR PRODUCTION NO. 34:
a. The capacity need of 85 MW in 2024 and 125 MW in 2025 was first identified in
the 2021 IRP load and resource balance, as seen on pages 21-22 of the 2021 IRP
- Appendix C. When the 2022 RFP was issued, the 2025 capacity deficiency
initially identified was 115 MW however shortly thereafter the Company issued
Addendum No. 3 clarifying that, consistent with the 2021 IRP, the capacity need in
2025 was an incremental 125 MW. Please see Attachment 1 for the addendum
issued on January 29, 2022.
b. Yes.
c. See part (a) above.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution, & Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 25
REQUEST FOR PRODUCTION NO. 35: Page 24 of Mr. Hackett's Testimony
states that between the time when the refreshed Long-Term Capacity Expansion
("LTCE") analysis was performed and when contract negotiations were to begin, the 2024
capacity need had increased, so the 20 MW BESS became a 60 MW BESS. Please
respond to the following:
a. Please confirm that the capacity need in 2024 before the increase was 85 MW. If
not, how much capacity was needed before the increase?
b. What was the new capacity need after the increase? What factors drove the
increase?
c. When was this increased capacity need identified?
d. Please provide evidence of the new capacity need after the increase in the form of
L&R.
RESPONSE TO REQUEST FOR PRODUCTION NO. 35:
a. Yes. As explained in the Company’s Response to Request for Production No. 34,
the 2024 capacity deficiency identified in the 2021 IRP load and resource balance,
and the basis for issuance of the 2022 RFP, was 85 MW.
b. Please see the Company’s Response to Request for Production No. 12 for the
varying 2024 capacity positions throughout the 2022 RFP evaluation process and
details regarding the methodology utilized.
c. The following table summarizes the varying capacity positions and represents the
approximate time frame they were identified:

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 26

 Scenario Details Position Identification 
20
2
4
 L&
R

Base Case (103) Capacity Shortfall January 2023
Add 100 MW PV + 20 MW BESS (37) Capacity Shortfall January 2023
Add 100 MW PV + 60 MW BESS (7) Capacity Shortfall January 2023
Add 100 MW + 60 MW BESS 
 Add 12 MW BESS 4 Capacity Length February 2023

d. See part (b) above.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 27
REQUEST FOR PRODUCTION NO. 36: Page 24 of Mr. Ellsworth's Testimony
states that Idaho Power's most recently updated L&R has identified a 2024 capacity need
of 103 MW. Please respond to the following:
a. What factors drove the increase of capacity needs to 103 MW from the previous
deficit?
b. When was the capacity need of 103 MW in 2024 identified?
c. Please provide evidence of the 103 MW capacity need in the form of L&R.
RESPONSE TO REQUEST FOR PRODUCTION NO. 36:
a. Please see the Company’s Response to Request for Production No. 12 for the
varying 2024 capacity positions throughout the 2022 RFP evaluation process and
details regarding the methodology utilized.
b. Please see the Company’s Response to Request for Production No. 35.
c. Please see the L&R below.
Load & Resource Balance 
Base Case 
    L&R Contribution 
2024 Forecasted 70th Percentile Peak Load + PRM (MW) 4,273.9 
Hydro with Storage (Hells Canyon Complex) 1,050.0 
Coal (Bridger & Valmy) 442.6 
Gas (Langley, Bennett Mountain, Danskin & Bridger) 976.7 
Variable & Energy Limited Resources 1,060.3 
Firm Transmission 453.0 
Emergency Transmission 188.4 
2024 Total Generation (MW) 4,170.9 
Annual Position (Positive is Length, Negative is Shortfall) (103) 
Reliability Threshold 0.1 event‐days/year 

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 28
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 29
REQUEST FOR PRODUCTION NO. 37: Please provide the Company's latest
L&R that is used in the AURORA model run in Response to Staff Production Request No.
15. Also, please respond to the following:
a. What was the capacity position identified in this L&R?
b. What factors drove the change of capacity needs from 103 MW to this capacity
position?
c. When was this capacity position identified?
RESPONSE TO REQUEST FOR PRODUCTION NO. 37:
a. Idaho Power is still in the process of developing its 2023 IRP and does not have a
finalized LOLE analysis ready for conversion and application to a tabulated L&R
balance. The Company currently expects to file this IRP in fall of 2023, which will
include capacity positions for the 20-year planning horizon. Therefore, the capacity
position used in the AURORA model run prepared in Response to Staff’s Request
for Production No. 15 was the finalized value for the 2024 RFP, which includes the
PPA associated with the 100 MW solar photovoltaic facility and the 60 MW BESS
project as well as the additional 12 MW of BESS, resulting in 4 MW of length.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 30
Load & Resource Balance 
Add Franklin & Add Extra 12 MW 4‐Hour BESS 
    L&R Contribution 
2024 Forecasted 70th Percentile Peak Load + PRM (MW) 4,264.1 
Hydro with Storage (Hells Canyon Complex) 1,050.0 
Coal (Bridger & Valmy) 442.6 
Gas (Langley, Bennett Mountain, Danskin & Bridger) 976.7 
Variable & Energy Limited Resources 1,157.5 
Firm Transmission 453.0 
Emergency Transmission 188.4 
2024 Total Generation (MW) 4,268.1 
Annual Position (Positive is Length, Negative is Shortfall) 4  
Reliability Threshold 0.1 event‐days/year 

b. Please see part (f) of the Company’s Response to Request for Production No. 12.
c. As explained in the Company’s Response to Request for Production No. 35, this
capacity position was identified in March 2023.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 31
REQUEST FOR PRODUCTION NO. 38: Response No. 14 (b) states that the
indicative AURORA modeling scenarios consistently selected Project Nos. 7 and 8 in the
first LTCE analysis. Please answer the following:
a. Please describe each scenario and explain why each scenario is used and how it
determines the selected resources are least-risk resources.
b. Please indicate whether these scenarios are used in the second LTCE analysis.
c. If not, please describe the scenarios used in the second LTCE analysis and explain
the reason for the change.
d. Please provide all the workpapers of the results under each scenario, showing that
the selected resources are least-cost and least-risk, compared to other resources.
RESPONSE TO REQUEST FOR PRODUCTION NO. 38:
a. The “indicative” AURORA modeling scenarios referenced were all based on the
uncertainty associated with different aspects of the Company’s load forecast and
capacity position. Therefore, Idaho Power analyzed the following four scenarios:
1. Base
2. Base + 50 MW increase to Idaho Power’s capacity position need as a
contingency
3. Base + Additional large load customer
4. Base + Additional large load customer + 50 MW increase to the Company’s
capacity position need as a contingency
b. Only scenario 3 was used in the second LTCE analysis.
c. For the second LTCE analysis, only scenario three was analyzed because
finalization of the load forecast and capacity position had occurred by this time,

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 32
thus it was unnecessary to evaluate all four scenarios. Furthermore, as discussed
with Staff following the Company’s analyses performed for Request for Production
No. 15, the same portfolio of resources was selected by the LTCE analysis in each
scenario evaluated in Idaho Power’s supplemental response, including varying gas
and carbon prices.
d. As explained in the Company’s Response to Production Request No. 14(b), under
the LTCE modeling approach, the levelized cost of all projects are input into
AURORA as potential resource additions, along with their project specific
operating characteristics. The LTCE model optimizes these potential resource
selections based on the performance of each resource within Idaho Power’s zone,
optimizing for the cost function while meeting the Company’s identified capacity
deficiency. Therefore, there are no workpapers resulting from the LTCE analysis
but rather for each scenario the resulting project identified as the most cost-
effective resource for meeting the capacity deficiency. The following is a list of
which projects were selected under the first LTCE analysis under each scenario:
1. Project No. 7
2. Project No. 7 + Project No. 8
3. Project No. 7 + Project No. 8
4. Project No. 7 + Project No. 8 + Project No. 10
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 33
REQUEST FOR PRODUCTION NO. 39: Please explain why the Company did not
open the requirements for additional 40 MW and 12 MW of storage to RFP bidders.
RESPONSE TO REQUEST FOR PRODUCTION NO. 39: The selection of the
additional 40 MW of battery storage was an extension of the most cost-effective resource
identified through solicitation in the 2022 RFP. Upon identification of the increased
capacity deficiency, the Company inquired about the feasibility of an increase in the size
of the battery storage system. The developer confirmed the battery storage pricing per
kilowatt could be maintained, and an increased system installed, for up to 60 MW of
storage. Likewise, the selection of the 12 MW of battery storage was an extension of the
next most cost-effective resource identified through solicitation in the 2022 RFP, one of
the Idaho Power battery storage benchmark resources. It was determined the Company
could economically and efficiently add 12 MW of battery storage at the Hemingway
substation without requiring infrastructure upgrades and ensuring maximum investment
tax credit benefits as installation could begin timely. The resulting levelized cost was lower
than any remaining final short list projects.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 34
REQUEST FOR PRODUCTION NO. 40: Please describe any weighting factors
the Company used in both qualitative and quantitative bid analysis and explain if these
factors were included in bid solicitation materials.
RESPONSE TO REQUEST FOR PRODUCTION NO. 40: Specific weighting
factors were not included in the bid solicitation materials. However, as described in the
2022 RFP, the qualitative evaluation ranked the proposals based on project feasibility,
project capability, counterparty profile, and community stewardship, with each category
generally weighted to ensure the evaluation process was conducted without bias and
yields results that are aligned to Idaho Power’s resource needs. Black & Veatch further
assisted Idaho Power in the consolidation and integration of final evaluations prepared by
Idaho Power subject matter experts, and overall weighting of individual factors and key
categories that influenced both quantitative and qualitative evaluation.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 35
REQUEST FOR PRODUCTION NO. 41: Response to Staff Production Request
No. 3 in Case No. IPC-E-22-13 states that Idaho Power believes the December 2021
RFP (the 2022 RFP) allows for slightly more time to determine whether the operational
needs can be met through a third-party owned battery storage agreement. Please provide
all additional information the Company has learned including the pros and cons of 3rd
party ownership since submitting this response.
RESPONSE TO REQUEST FOR PRODUCTION NO. 41: As explained in the
Company’s request for a Certificate of Public Convenience and Necessity (“CPCN”) for
procurement of resources to meet the 2023 capacity deficiency in Case No. IPC-E-22-
13, the urgency of the identified need impacted the procurement process. During this
compressed timeframe, Idaho Power was considering the risks and benefits of differing
ownership structures and operation of resources either as stand-alone projects or in
connection with energy storage projects. At the time, Idaho Power was uncertain that it
could adequately address several important operational and policy concerns with third-
party ownership of battery storage resources. One of the primary features of an owned
peak capacity resource is the ability to configure, reconfigure, maintain, operate, and
economically and operationally dispatch the unit without application of the confines of the
terms and conditions of a power purchase agreement (“PPA”) with a third party. Due to
the uncertainty at that time, the Company believed that its ownership and operation of the
battery storage resources would reduce the risk of potential operational limitations that
could exist under a PPA and ensure the resource is operational in time to meet identified
capacity deficits. While the Company acknowledged that the issues identified could
conceivably be addressed through an agreement with a third-party provider, Idaho Power

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 36
was unable to achieve such contract terms in the limited time available for the resource
procurements necessary to meet the 2023 capacity deficiency.
However, as evidenced in the Company’s request in Case No. IPC-E-23-20, the
request for a CPCN to acquire resources to be online in both 2024 and 2025 and for
approval of an Energy Storage Agreement (“ESA”), since then, Idaho Power has
developed contractual terms that alleviate concerns about potential operations limitations
associated with third party ownership of storage resources. The Company worked
extensively with Kuna BESS LLC (“Kuna BESS”), the developer of the most cost-effective
project proposals submitted as part of the 2022 RFP, to execute a 20-year ESA in which
Kuna BESS would develop, design, construct, own, and operate a battery storage
system. The ESA is a slightly different kind of agreement and is sometimes referred to in
the industry as a “tolling” agreement, acting as a type of a lease. While Kuna BESS will
own and operate the battery storage system, in accordance with the terms of the
agreement, Idaho Power has the exclusive right to dispatch and use the charging and
discharging energy in exchange for a monthly payment.
Although the ESA is required to be recorded as a lease for accounting purposes
and has an impact on the Company’s financial statements, once the Kuna BESS project
was identified as the least-cost/least-risk resource necessary for meeting Idaho Power’s
2025 capacity deficiency, the Company evaluated the financial impact of such an
agreement and the resulting effect on the levelized cost of the project. Even with the
inclusion of the additional costs associated with the lease, the project remained the least-
cost/least-risk resource. At this time, Idaho Power has not identified any additional pros
or cons associated with the third-party ownership of the resource.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 37
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 38
REQUEST FOR PRODUCTION NO. 42: Please respond to the following regarding
charging prices:
a. The RFP requires that, for proposals of solar paired with storage or wind paired
with storage where the Company owns the storage component, Respondent must
provide the price of charging the energy storage from the solar or wind resources.
What is the price of charging the 60 MW BESS in this case? Where is the price
listed in the PPA or Build Transfer Agreement?
b. Please explain how the price is modeled in AURORA.
RESPONSE TO REQUEST FOR PRODUCTION NO. 42:
a. The price of charging the 60 MW BESS is the Franklin Solar Power Purchase
Agreement (“PPA”) price, presented in Exhibit 5 of the PPA included as
Confidential Exhibit No. 5, for the first 5 years of the BESS resource life.
b. The BESS is modeled as needing to charge from Franklin Solar at the PPA price
resource for the first 5 years of its life. After the first 5 years, the BESS is modeled
such that it can be charged by the grid.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 39
REQUEST FOR PRODUCTION NO. 43: Please respond to the following regarding
all-in costs:
a. Please provide the workpaper that shows the all-in cost of the 60 MW BESS and
a breakdown of the all-in cost, and explain what cost items are considered in the
bid price.
b. Please provide the workpaper that shows the all-in cost of the 12 MW BESS and
a breakdown of the all-in cost, and explain what cost items are considered in the
bid price.
c. Please explain whether the 100 MW solar paired with the 60 MW BESS and the
12 MW standalone BESS are still the least-cost projects among all projects on the
final short list, when all the additional costs (e.g. O&M costs) outside the bid
prices are considered. Please provide evidence to support your answer.
d. Please provide the workpaper that shows the all-in costs and a cost breakdown of
the all-in cost for the storage projects proposed in Case No. IPC-E-22-13, and
compare each cost category to the same cost categories for the 60 MW BESS and
the 12 MW BESS projects in this case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 43:
a. As explained in the Company’s Response to Request for Production No. 27(b), the
$ purchase price under the Build Transfer Agreement for the 60 MW
BESS includes the purchase and installation of the batteries and ancillary
equipment such as transformers, inverters, cables, networking equipment,
foundations, structures, etc. These costs include full turn-key implementation from
design and engineering to procurement and construction. In addition to the bid
price, Idaho Power considers operations and maintenance (“O&M”) costs

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 40
associated with the project in the levelized cost calculation. Those costs include
ongoing and routine maintenance, capacity augmentation, property tax, and
insurance. Please see part (d) for a breakdown of these additional costs.
b. The 12 MW BESS system is estimated to cost approximately $,
based on the executed BESA described in the Company’s Response to
Request for Production No. 33, and includes the purchase and installation of
the batteries and ancillary equipment such as transformers, inverters, cables,
networking equipment, foundations, structures, etc. These costs include full
implementation from design and engineering to procurement and construction.
In addition to the bid price, Idaho Power considers O&M costs associated with
the project in the levelized cost calculation. Those costs include ongoing and
routine maintenance, capacity augmentation, property tax, and insurance. The
following table provides total cost estimates for the development and
construction of the 12 MW BESS at Hemingway. Engineering design
agreements are being scoped currently and costs reflect estimates based on
previous project experience at this location.
Powin Supplied BESS Equipment
Project Management, Engineering, Design, Construction
Management, Permitting, and general Administration

Civil Construction, Site Work, Underground Conduit and
Grounding, Fencing, Concrete Foundations

Electrical Construction
BESS Installation
Testing and Commissioning
Idaho Power Interconnection Facilities
TOTAL

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 41
c. As described in the Direct Testimony of Mr. Hackett, in the original evaluation
of the projects, additional costs outside of the bids such as ongoing and routine
maintenance, capacity augmentation, property tax and insurance were
considered in the levelized cost calculations. Therefore, the evaluation process
selects the least-cost resource based on all cost components of the project.
d. Please see the table below for a comparison of the cost components for the 60
MW BESS and 12 MW BESS for which the Company is requesting a Certificate
of Public Convenience and Necessity (“CPCN”) in this case with the 80 MW
BESS and 40 MW BESS for which Idaho Power received a CPCN in Case No.
IPC-E-22-13. Please note, the costs presented below for the 80 MW BESS and
40 MW BESS are the most recent cost estimates as presented most recently
in the Company’s general rate case, Case No. IPC-E-23-11:

Case No. IPC-E-22-13 Resources Case No. IPC-E-23-05 Resources
Product Type BESS - 4 hr BESS - 4 hr Storage+Solar PPA BESS - 4 hr
Bidde
Idaho Power
Company
Idaho Power
Company
Duke Energy
Renewables, Inc
Idaho Power
Company
MW 40.00 80.00 60.00 12.00
Bid Price/Cost $60,830,657 $113,969,879
First Year O&M - Base $295,000 $612,000
First Year O&M -
Augmentation 1 1
First Year O&M - Property
Tax/Insurance 1 1

Total Capital Cost per kW $1,521 $1,425
1. Costs presented are the amounts utilized for evaluation of the project as part of the 2022 RFP as these
amounts are not included or separately identified in Case No. IPC-E-23-11.

The response to this Request is sponsored by John Wonderlich, Finance Team
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 42
DATED at Boise, Idaho this 25th day of July 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S AMENDED RESPONSE TO THE CONFIDENTIAL SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 43
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 25th day of July 2023, I served a true and correct
copy of Idaho Power Company’s Amended Response to the Confidential 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
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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

City of Boise
Darrell Early
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]

Wil Gehl
Energy Program Manager
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
FTP Site
X Email [e-mail]

Stacy Gust, Regulatory Administrative
Assistant

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
CONFIDENTIAL
ATTACHMENT 1
REQUEST NO. 33
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
ATTACHMENT 1
REQUEST NO. 34

A
2022 All Source Request for Proposals (RFP) for Peak Capacity Resources and Energy Resources
1
The following items are addressed in this Addendum No. 03:
1. Clarifications and Changes:
1.1. Section 2.2 of the RFP narrative states that Idaho Power has an identified capacity need of 85
megawatts (MW) in 2024 and an incremental 115 MW in 2025. However, as further detailed in Idaho
Power’s published 2021 Integrated Resource Plan (IRP), the identified capacity and energy deficit to
reliability meet growing pressures on Idaho Power’s electrical system and serve its customers is
greater.
It is important to note, that Idaho Power’s identified capacity need is 85 MW in 2024 and an
incremental 125 MW in 2025.
For purposes of clarity, Idaho Power has updated the language in the RFP narrative, as attached to this
Addendum No. 03.

Idaho Power Company
Request for Resource Team
1221 W. Idaho St. | Boise, ID | 83702
Email [e-mail]