20230913IPC to Staff Supplemental 3_6-7_12-13_22-23 Redacted.pdf

DONOVAN WALKER
Lead Counsel
[e-mail]

September 13, 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 a redacted version of Idaho Power
Company’s Second Supplemental Response to the Second Production Request of the
Commission Staff in the above matter. Please be aware that Idaho Power Company has
included a response to Production Request No. 13d as it was inadvertently left off the
original response.

Idaho Power Company’s Second Supplemental Response to the Second Production
Request of the Commission Staff contains confidential information within the response and
attachments. A confidential version of the response and 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:cd
Enclosures
RECEIVED
2023 SEPTEMBER 13, 2023 3:22PM
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 Second Supplemental
Response to the Second Production Request of the Commission Staff to Idaho Power
Company, dated September 13, 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 13, 2023.

Donovan Walker
Counsel for Idaho Power Company

IDAHO POWER COMPANY’S SECOND 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
SECOND 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 submits the following
information:

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2

STAFF REQUEST FOR PRODUCTION NO. 3: The following sources show an
incremental capacity deficit of 125 MW in 2025:
· The 2021 Integrated Resource Plan ("2021 IRP") at 142 and 170;
· Hackett's Direct Testimony at 8;
However, the following sources show an incremental capacity deficit of 115 MW in
2025:
· Application at 6;
· Ellsworth's Direct Testimony at 23; and
Please reconcile the numbers.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 3: The incremental capacity deficiency in 2025 of 115 MW that was the basis for
issuance of the RFP was the result of the 2025 deficiency position identified through the
Valmy Unit 2 closure analysis performed as directed by Order No. 34349. Subsequent to
that analysis, the load and resource balance utilized for preparation of the 2021 IRP
identified a 2025 capacity deficiency of 125 MW therefore the Company issued
Addendum No. 3 clarifying that, consistent with the 2021 IRP, the capacity need in 2025
was an incremental 125 MW.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3

STAFF REQUEST FOR PRODUCTION NO. 6: The Application states that at the
time the proposals for 2022 Request For Proposals ("2022 RFP") were being evaluated,
the 2025 capacity deficiency had increased, so Idaho Power selected the next most cost-
effective resource to meet the 2025 capacity deficiency. Application at 9. Page 18 of
Ellsworth's Direct Testimony states that the updated capacity deficiency in 2025 is 178
MW. Please respond to the following:
a. When did the 2025 capacity deficiency increase to 178 MW?
b. Please provide the Load and Resource Balance ("L&R") for the 178 MW;
c. Please confirm that reasons listed on Pages 10 and 11 of Ellsworth's Direct
Testimony are all the reasons that caused the deficit increase from the previous
2025 capacity deficiency identified in the 2021 IRP to the updated incremental 178
MW deficit in 2025. If not, please provide additional reasons; and
d. Please provide the updated L&R that shows the updated capacity position of 13 MW
of capacity length in 2024, after the proposed resources are added.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 6: Following clarification from Staff, please see Attachment – Response to Staff
Request No. 6 for a description of the updates to the Reliability & Capacity Assessment
Tool (“RCAT”) that led to the changes in the 2024 and 2025 annual capacity positions.
The first page summarizes the updates made to the RCAT since completion of the 2021
Integrated Resource Plan (“IRP”) while the second and fourth pages present the 2024
and 2025 RCAT inputs, respectively. The third and fifth pages present the changes to the
annual capacity position through each derivation of input updates for 2024 and 2025,
respectively, since the 2021 IRP.

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4

The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, Idaho Power Company.

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

STAFF REQUEST FOR PRODUCTION NO. 7: The Application states that during
preparation of the 2023 IRP, as the load and resource balance was refreshed, it was
determined that a capacity shortfall still exists in 2024, so the Company added a 24 MW
BESS to meet the 2024 capacity deficiency. Application at 10. Page 18 of the Ellsworth's
Direct Testimony states that the shortfall is 8 MW. Please respond to the following:
a. Please explain when it was determined that the 8 MW shortfall still existed in 2024;
b. Please provide the L&R for the 8 MW shortfall;
c. Please explain what caused the 8 MW shortfall since the last deficit of 103 MW was
met by resources proposed in Case No. IPC-E-23-05. In your answer, please rule
out factors that have contributed to the determination of the 103 MW deficit; and
d. Please provide the updated L&R that shows the updated capacity position of 6 MW
of capacity length in 2025, after the proposed resources are added.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 7: Please see the Company’s Supplemental Response to Staff’s Request for
Production No. 6.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, Idaho Power Company.

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6

STAFF REQUEST FOR PRODUCTION NO. 12: The 77 MW is a reduced capacity
size from the original bid size. Is the levelized cost of capacity for the original size kept
the same for the 77 MW? If not, how can the Company guarantee this resource is the
second least-cost resource?
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 12: While the levelized cost of capacity of Project No. 15 was essentially
proportionally scalable between the 150 MW bid and the 77 MW project, the total project
costs of approximately and , respectively, is not scalable
because the costs of the 150 MW project are based on the bid evaluation price adjusted
for the overbuild, as footnoted in Confidential Exhibit No. 5 to the direct testimony of Mr.
Hackett, and the cost of the 77 MW project is based on the price including
the overbuild. To be precise, the evaluated levelized cost of capacity for the 150 MW
project was $ per kW-month whereas the 77 MW project was $ per kW-month.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7

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
d. Please provide the final result that combined the quantitative evaluation and the
qualitative evaluation, including the score of each project.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 13:
d. Please see the response to part (c). There is no score associated with the
quantitative evaluation of each project therefore there is no combined quantitative
evaluation and qualitative evaluation score.
The response to this Request is sponsored by Eric Hackett, Projects and Design
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8

STAFF REQUEST FOR PRODUCTION NO. 22: Footnote Nos. 21 and 23 in Exhibit
No. 5 of Hackett's Direct Testimony mention price adjustments due to overbuilds.
a. Please explain what the bidders proposed regarding overbuilds in their bids; and
b. Please explain how and why overbuilds affect pricing.
SUPPLEMENTAL RESPONSE TO STAFF’S REQUEST FOR PRODUCTION
NO. 22: The project costs of both the 77 MW and 24 MW project costs of $
and $ , respectively, include the overbuild costs associated with day one
batteries that will ensure the full 77 MW and 24 MW capacity and 308 megawatt-hours
(“MWh”) and 96 MWh of energy, respectively, is available for five years. Batteries degrade
as a function of time and usage. By including additional battery segments at the beginning
of life, Idaho Power can ensure reliable operation at full nameplate capacity (77 MW and
24 MW) for a minimum of 4 hours through the first five years of operation before
necessitating a decision to augment the BESS if the then current capacity is below the
nameplate capacity after year five. If the BESS system is not cycled daily, the longevity
and assurance of performing above the nameplate capacity beyond five years is likely
and thus deferral of future augmentation investments can occur. Therefore, the available
capacity of each project is approximately 94.25 MW (377 MWh) and 29.8 MW (119 MWh).
However, it important to note that only 77 MW and 24 MW of capacity of each BESS is
dispatched at any given time.
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader, Idaho Power Company.

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

STAFF REQUEST FOR PRODUCTION NO. 23: Please provide the overall
levelized cost and annual cost and benefit streams with a breakdown of the cost and
benefit components for Project Nos. 6, 13, and 17 on the short list, in addition to the
separate levelized costs for the solar, wind, or BESS components already provided in the
Application.
RESPONSE TO STAFF’S REQUEST FOR PRODUCTION NO. 23: Each
component of combined technology projects has different characteristics (e.g. solar
provides primarily energy and a BESS provides capacity). Therefore, Idaho Power
calculates the levelized cost of energy or capacity for each project component (e.g.,
BESS, solar, etc.) rather than calculating an overall levelized cost for each project as a
whole. The levelized cost of each project component and the specific operational
characteristics of the project component are then entered into AURORA. In the AURORA
modeling, the combined project technology types must all be selected. The AURORA
modeling considers the overall cost of the projects and the operational characteristics to
select the least cost portfolio.
The response to this Request is sponsored by John Wonderlich, Finance Team
Leader, Idaho Power Company.

DATED at Boise, Idaho this 13th day of September 2023.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S SECOND SUPPLEMENTAL RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 10

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 13th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Second 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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Christy Davenport
Legal Administrative Assistant