20230901IPC to Staff Supplemental 13.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]
September 1, 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-23-20
In the Matter of Idaho Power Company’s Application for a Certificate of
Public Convenience and Necessity to Acquire Resources to be Online in
Both 2024 and 2025 and for Approval of an Energy Storage Agreement with
Kuna Bess, LLC
Dear Ms. Noriyuki:
Attached for electronic filing please find Idaho Power Company’s Supplemental
Response to the Second Production Request of the Commission Staff in the above
matter.
The confidential attachments will be provided separately via an encrypted email to
parties who sign 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
Friday, September 1, 2023 1:51:29 PM
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

Idaho Power Company’s Application for a Certificate of Public Convenience and
Necessity to Acquire Resources to be Online in Both 2024 and 2025 and for
Approval of an Energy Storage Agreement with Kuna Bess, LLC

Case No. IPC-E-23-20

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the attachments to Idaho Power Company’s Supplemental Response to the
Second Production Request of the Commission Staff to Idaho Power Company, dated
September 1, 2023, contain information that Idaho Power Company and a third party
claims is a confidential trade secret and/or trade secret as described in Idaho Code § 74-
101, et seq., and/or § 48-801, et seq in that the redacted information contains confidential
negotiated terms and conditions, confidential bidder information and competitive bid
submissions, as well as confidential financial information about the Company. As such, it
is protected from public disclosure and exempt from public inspection, examination, or
copying.

DATED: September 1, 2023.

Donovan Walker
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S SUPPLEMENTAL 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 TO ACQUIRE
RESOURCES TO BE ONLINE IN BOTH
2024 AND 2025 AND FOR APPROVAL OF
AN ENERGY STORAGE AGREEMENT
WITH KUNA BESS LLC.
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CASE NO. IPC-E-23-20

IDAHO POWER COMPANY’S
SUPPLEMENTAL 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 (“Commission” or
“Staff”) to Idaho Power Company dated August 22, 2023, herewith supplements the
following information:

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 2
STAFF REQUEST FOR PRODUCTION NO. 13: The Company's Reply
Comments in Case No. IPC-E-23-05 state that "Idaho Power performed a quantitative
and qualitative evaluation with an objective scoring methodology to reasonably evaluate
the price and non-price attributes of each project proposal submitted through the RFP
process." Please respond to the following:
a. Please describe the scoring methodology;
b. Please provide the result of the qualitative evaluation, including the score of each
project;
c. Please provide the result of the quantitative evaluation, including the score of each
project; and
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 13:
b. Please see Confidential Attachment 1 – Response to Staff Request No. 13(b) for the
results of the qualitative evaluation of the 2025 projects submitted in response to
Idaho Power’s All Source Request for Proposals (RFP) for Peak Capacity and
Energy Resources issued December 30, 2021 (“2022 RFP”). The results are
compiled on the tab labeled Summary. In addition, the Company has added a
column to the Summary tab identifying the corresponding Project Number assigned
in Confidential Exhibit No. 5 with the bid evaluation results. Note, Project Nos. 31
through 34 were the result of Addendum No. 8 to the 2022 RFP which provided
respondents to submit proposals for a Battery Energy Storage System resource type
with a Battery Storage Agreement ownership structure. As such, the qualitative
evaluation of those projects was performed on the original project submittal and,

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 3
because the qualitative evaluation of the projects would not change as a result of
the additional ownership structures, was not identified a second time on the
Summary tab.
In addition, Project Nos. 31 and 32 were submitted as part of the projects to
meet both the 2024 capacity deficiency and the 2025 capacity deficiency therefore
their qualitative evaluation was performed as part of the evaluation of the 2024
projects, which is included as Confidential Attachment 2 – Response to Staff
Request No. 13(b). The results of the evaluation can be found on the Summary tab.
Because of the complexity of the models used to perform the qualitative evaluation,
the Company has also created a summary of the results, included as Confidential
Attachment 3 – Response to Staff Request No. 13(b), with the corresponding Project
Number as assigned in Confidential Exhibit No. 5.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 4
DATED at Boise, Idaho this 1st day of September 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S SUPPLEMENTAL RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 1st day of September 2023, I served a true and
correct copy of Idaho Power Company’s Supplemental Response to the Second
Production Request of the Commission Staff upon the following named parties by the
method indicated below, and addressed to the following:

Commission Staff
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

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Stacy Gust
Regulatory Administrative Assistant