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HomeMy WebLinkAbout20220310Application.pdf<EHm* ,ii:;,.:"itt'ID : ;.ii iii i s Ffli h: 5u An DACORP C'omperry DONOVAN WALKER Lead Counsel dwalker@idahopower.com DEW:sg Enclosures fuzd*4 March 10,2022 VIA ELECTRONIC FILING Jan Noriyuki, Secretary ldaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, ldaho 83720-0074 Re: Case No. IPC-E-22-06 ln the Matter of ldaho Power Company's Application for Approval of a Replacement Special Contract with Micron Technology, lnc. and A Power Purchase Agreement with Black Mesa Energy, LLC Dear Ms. Noriyuki: Attached for electronic filing, pursuant to Order No. 35058, please find ldaho Power Company's Application in the above matter. ln addition, please find aftached the DirectTestimony of ConnieAschenbrennerfiled in support of the Application. A Word version of the testimony will also be sent in a separate email for the convenience of the Reporter. Also attached is a protective agreement. Exhibit No. 2 to the testimony of Connie Aschenbrenner contains confidential information and will be provided separately via an encrypted emailto parties who sign the protective agreement. Please feel free to contact me directly with any questions you might have about this fi!ing Very truly yours, Donovan E. Walker DONOVAN E. WALKER (lSB No. 5921) ldaho Power Company 1221 West ldaho Street (83702) P.O. Box 70 Boise, ldaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker@ idahopower.com Attorney for ldaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR APPROVAL OF A REPLACEMENT SPECIAL CONTRACT WITH MICRON TECHNOLOGY, INC. AND A POWER PURCHASE AGREEMENT WTH BLACK MESA ENERGY, LLC. CASE NO. IPC-E-22-06 APPLICATION ldaho Power Company ("ldaho Power" or "Company'), in accordance with RP 52 and ldaho Code SS 61-502 and 61-503, hereby requests that the ldaho Public Utilities Commission ("Commission") issue an order: 1) approving the revised Special Contract for electric service between Idaho Power and Micron Technology, lnc. ("Micron'), which includes new pricing elements to facilitate the provision of Renewable Resources consistent with ldaho Powe/s proposed Clean Energy Your Way proposed tariff; and 2) approving the 20-year Power Purchase Agreement ('PPA") between ldaho Power and Black Mesa Energy, LLC ("Black Mesa") entered into with the expectation of assigning the associated energy to Micron under the revised Specia! Contract. ldaho Power's Application is based on the following: ) ) ) ) ) ) ) ) APPLICATION - 1 I. BACKGROUND 1. The Commission has broad authority to regulate and fix the rates and charges assessed by ldaho Power. ldaho Code SS 61-502, 61-503. Large Power Service customers that receive service in excess of 20,000 kilowatts fkw') are required to make specialcontract arrangements with the Company. ldaho Power's Schedule 19.1 For rate setting purposes, "each special contract customer is considered a separate class with different conditions and contract terms affecting their rates..." Order No. 33038 at 11. Differentiation between classes of customers is permissible when it is based on cost of service, quantity of electricity used, differences in conditions of service, or the time, nature, and pattern of the customers' use.2 2. Micron is a current Special Contract customer of ldaho Power. ldaho Power and Micron have operated under a Special Contract agreement since August 31, 1995. Since the original Agreement between Micron and ldaho Power was initially approved by the Commission in 1995, there have been a number of amendments, extensions, and one replacement agreement approved by the Commission in 2009. The revised Special Contract is intended to fully replace the current Special Contract between ldaho Power and Micron, which has been in effect since December 29, 2009, (the "Current Agreement") and is hereinafter referred to as the Micron Energy Services Agreement ("ESA"). Under the terms of the Black Mesa PPA, Black Mesa will build, own, operate, and maintain a 40 megawatt ("MW') alternating current ("AC') solar photovoltaic 1 See l.P.U.C. No. 29, Tariff No. 10'1, Schedule 19. 2 Building Contructors Associafrbn of Southwestem ldaho, lnc. v. ldaho Public Utilities Comm'n, 128 ldaho 534, 539, 916 P.2d '1259, 1264 (1996); Agicultunl Prducts Corp. v. Utah Power & Light Co., 98 ldaho 23,557 P.2d617 (1976); and ldaho State Homebuilders v. Washington Water Power, 107 ldaho 415,420,690 P.2d 350, 355 (1984). APPLICATION - 2 generation facility ("Renewable Resource') and will supply the output to ldaho Power's system. The ESA is provided as Exhibit No. 1 to the Direct Testimony of Connie G. Aschenbrenner ("Aschenbrenner Direct') filed contemporaneously with this Application and incorporated herein by this reference. 3. Micron, in addition to its large load service requirements in excess of 20 MW, has a renewable energy goal of using 100 percent renewable energy to support its U.S. manufacturing operations by calendar year 2025. Micron initiated discussions with ldaho Power in2021to determine what, if any, arrangements could be facilitated in ldaho Power's service area to take steps towards achieving their corporate renewable goal. As a result of those conversations, ldaho Power and Micron have entered into the proposed ESA, which envisions ldaho Power procuring an initial Renewable Resource of 40 MW on behalf of - and to be paid for by - Micron. As explained in more detail in Aschenbrenner's Direct, Micron's ESA encompasses pricing associated with retai! electric service from ldaho Power, cost and credit components associated with new renewable resources, and terms and conditions governing the structure of the new arrangement, including provisions necessary to prevent cost shift to other ldaho Power customers for the cost of the renewable resources. 4. The Micron ESA is consistent with and reflects the regulatory framework set forth in the Clean Energy Your Way - Construction option, as outlined in ldaho Power's recent Application with the Commission (Case No. IPC-E-214O) to establish new clean energy offerings for customers under the Clean Energy Your Way Program. ln that Application, ldaho Power states its belief that it can work with existing or future Specia! Contract customers to integrate renewables into their service agreement with the Company. Under the Clean Energy Your Way - Construction option, ldaho Power will APPLICATION - 3 work with customers to develop a Renewable Construction Agreement - the document that governs all pricing for Company electric service and the custome/s accompanying renewables. For Micron, the Renewable Construction Agreement is incorporated into its proposed Special Contract, or ESA. 5. ln addition to the ESA and the Black Mesa PPA, ldaho Power respectfully requests explicit approval of several specific components of a regulatory framework designed to implement and administer Micron's Special Contract with its accompanying renewables: 1) modifications to Schedule 26 Electric Service Rate for Micron Technology, lnc. Boise, ldaho ("Schedule 26") necessary to incorporate the hourly reconciliation of Micron's energy requirement and the Renewable Resource(s); 2) the derivation of the capacity credit associated with the Renewable Resource(s) and compensation structure for excess renewable energy generation; 3) authorization to treat bill credits provided to Micron under the proposed compensation structure as prudently incurred expenses for ratemaking purposes; and 4) the cost recovery mechanisms necessary to protect existing ldaho Power customers from cost shifting and ensure ldaho Power has an opportunity to recovery its cost of service. 6. Accompanying this Application is the Direct Testimony of Gonnie G. Aschenbrenner, which provides an overview of the renewable resource arrangement proposed in the Micron ESA to support Micron's clean energy goals, including the initial agreement to procure 40 MW of renewable energy from the Black Mesa project, describes the pertinent terms of the Black Mesa PPA, and describes the pricing structure contained within the proposed Micron ESA and BIack Mesa PPA as well as the no-harm analysis conducted to demonstrate thatthe proposalwill not negatively impact ldaho Power's other retail customers. The Micron ESA is presented as Exhibit No. 1, Aschenbrenner Direct. APPLICATION - 4 The fully executed PPA between ldaho Power and BIack Mesa for procurement of renewable energy on behalf of Micron is included as Confidential Exhibit No. 2, Aschenbrenner Direct, and the no-harm analysis is presented as Exhibit No. 3, Aschenbrenner Direct. II. SPECIAL CONTRACT TERMS AND PROVISIONS 7. ESA Overview. Under the proposed Micron ESA, ldaho Power will procure or construct, on Micron's behalf, Renewable Resources to assist Micron in meeting a portion of its annua! energy requirements with energy generated by those resources. The ESA envisions an initial Renewable Resource - the Black Mesa project - and provides flexibility for ldaho Power to work with Micron to develop additional Renewable Resources in ldaho Power's service area, if mutually agreeable, to support Micron's corporate renewable goal. The associated Renewable Energy Certificates ("RECs") will be retained and retired by ldaho Power on behalf of Micron. The Renewable Resources will not serve Micron directly but will be procured on Micron's behalf by ldaho Power and connected directly to the Company's transmission system. Micron will pay for the renewable output at the PPA contract rate and will also be credited for any value those resources bring to ldaho Powe/s system. 8. Pricino and Billino. Pricing and billing are discussed in more detail in Aschenbrenner's Direct, p 10-21, but, at a high level, rather than simply being charged for retail electric service under the Current Agreement, Micron will be charged for standard services (i.e., services exclusive of the Renewable Resources) it requires from ldaho Power, pay for the costs of the Renewable Resources, and be credited for any system benefits derived from those resources. This treatment is fully consistent with the structure outlined in the Clean Energy Your Way - Construction option in ldaho Power's APPLICATION - 5 Case No. IPC-E-2140. ldaho Power will reconcile Micron's energy use against the BIack Mesa production (and any future Renewable Resources) on an hourly basis to identify the amount of service required from ldaho Power versus the amount of generation from the Renewable Resources. More specifically: \Mren the Renewable Resource is not generating, Micron will continue to take fully bundled service from ldaho Power at its standard Schedule 26 Monthly Energy Charge. \Mren the Renewable Resource is generating, Micron will pay for all output at the PPA contract rate. Micron will also be assessed the Embedded Fixed Cost of Energy for all kilowaft-hours ('kWhs") of consumption met by the Renewable Resource. A capacity value associated with the Renewable Resource's contribution to peak capacity will be credited to Micron. ln any given hour, if the renewable generation exceeds Micron's energy use, ldaho Power will credit Micron for the value of that excess generation. Micron will continue to pay all fixed costs in their energy rate, as well as standard rates, charges, and fees for fully bundled service provided by ldaho Power. 9. Credit Suooort. The Micron ESA contains provisions intended to financially protect ldaho Power and its customers if Micron were to default. Section 12.1 of the Micron ESA outlines requirements for Micron to provide credit support. The amount of credit support is intended to cover the energy costs associated with the PPA (included as Confidential Exhibit No. 2) that is the greater of $90 per kW of renewable resource PPA nameplate capacity or the difference between market price and the PPA price. This provision protects ldaho Powe/s customers in the unlikely event of default by Micron and when the remaining cost of the renewable resource exceeds its market value. The term of the Micron ESA is proposed to remain in effect untilthe expiration or termination of the PPA. APPLICATION .6 10. No-Harm Financial Analvsis. Aschenbrenner's Direct, p 26-29, as well as Exhibit No. 3 to Aschenbrenne/s Direct, details the present value revenue requirement analysis demonstrating the Micron ESA will not financially harm other retail customers. ldaho Power completed a present-value revenue requirement analysis for two scenarios and evaluated the difference in incremental system resource and power supply cost from Micron's participation in the CEYW - Construction option and the addition of the Black Mesa PPA to ensure that any cost shift to ldaho Power's other customers does not occur. This "no-harm" analysis demonstrates that on a net present value ('NPV') basis lor a20- year period, the revenue requirement is lower by $2.5 million, including the estimated cost of imputed debt, representing a benefit to all customers in the 'with" scenario where Micron participates in the CEYW - Construction option. Aschenbrenner Direct, p 29. III. BLACK MESA PPA 11 . On February 16, 2022,ldaho Power and Black Mesa entered into a PPA for the sale and purchase of 40 MWAC of renewable solar electric generation from the Black Mesa project for the period of twenty years from a commercial operation date of June 1, 2023. An executed copy of the PPA is attached as Confidential Exhibit No. 2 to Aschenbrenner's Direct. The PPA contains non-levelized, fixed pricing that escalates at 2.0 percent annually during the term. Exhibit 5 to the PPA sets forth the Contract Price for Contract Years 1 through 20 on a dollarc per megawatt-hour ('MWh") basis. The PPA is similar in many ways to the numerous energy sales agreements approved by the Commission pursuant to the Company's obligations under Public Utility Regulatory Policies Act of 1978 ("PURPA"), but also contains additional other terms and conditions consistent with industry standard, non-PURPA power purchase agreements including pricing, security, and other terms of service. APPLICATION - 7 12. The PPA provides for a Scheduled Commercial Operation Date of June 1, 2023,just priorto ldaho Power's currently projected first capacity deficit in July 2023. The PPA provides for a Guaranteed Commercial Operation Date, which is 180 days after the Scheduled Operation Date under Section 1.59. Section 9 of the PPA contains provisions requiring the Seller to post and maintain security, both Project Development Security and Default Security. Project Development Security in the amount of $90 per "kW of Nameplate Capacity Rating must be in place within 30 days of a final order of the Commission approving the Agreement. Project Development Security is to remain in place to ensure the project meets its Commercial Operation Date. Default Security in the initial amount of $45 per kilowatt ('kW') of Nameplate Capacity Rating must be in place at the Commercia! Operation Date and must be maintained through the entire term of the Agreement. The amount of Default Security reduces to $35 per kW of Nameplate Capacity Rating starting in Contract Year 1 1 . Default Security may be used for any Deficit Damages if the project is brought online at less than the Expected Nameplate Capacity or for any other damages ldaho Power suffers if the Agreement is terminated because of the Selle/s default. 13. The PPA also contains a performance requirement in the form of an Output Guarantee. Section 7.12. Under the Output Guarantee, the Seller is obligated to deliver 90 percent of the Estimated Monthly Output of the Facility on a monthly basis. Similar to recent provisions from PURPA agreements, the PPA allows the Seller an adjustment of Estimated Monthly Net Output Amounts by the 25th day of the preceding month in Section 7.12.1.2. lf the project delivers less than the Output Guarantee during any month, the Seller must pay the Output Shortfall for that month multiplied by ldaho Power's Cost to Cover as liquidated damages in Section 7.12.2. If the delivered Net Output is equal to or APPLICATION - 8 greater than the Output Guarantee, then the Seller is deemed to have satisfied the Output Guarantee in Section 7.12.2.1.9. Section 7 of the PPA contains standard provisions for operation and control of the project. These include such things as planned outages, forced outages, and maintenance outages, as we!!as scheduling, forecasting, generator output limit contro! ("GOLC'), and metering. For forecasting, the Agreement provides the same allocated portion of the total cost of ldaho Power's Solar Energy Production Forecast mode! that is used for all solar projects that are under contract to provide energy to ldaho Power. Under the PPA, ldaho Power will own 100 percent of the Green Tags or Environmental Attributes associated with the Facility and will retire such aftributes on behalf of Micron under the proposed ESA. 14. Section 3.1.1 provides that the PPA will not become effective unless the Commission has approved all of the PPA's terms and conditions and declared that all payments ldaho Power makes to Seller for purchases of energy will be allowed as prudently incurred expenses for ratemaking purposes. The obligation of ldaho Power to purchase energy under the PPA will not become finally effective should it be disapproved by either the Commission or the Public Utility Commission of Oregon. This section provides that subsequent to execution of the PPA, ldaho Power will seek a final order regarding approval or rejection of the Agreement from the Commission prior to August 1, 2022, and that if Commission approval is not obtained by August 1,2022, the Scheduled Commercial Operation Date and Guaranteed Commercial Operation Date may be extended on a day-for-day basis untilapproval is obtained. Should Commission approva! not be obtained by November 1 , 2022, then the Seller has the right to terminate the Agreement. APPLICATION - 9 IV. MODIFIED PROCEDURE 15. ldaho Power believes that a hearing is not necessary to considerthe issues presented herein and respectfully requests that this Application be processed under Modified Procedure; i.e., by written submissions rather than by hearing. RP 201, ef seg. Additionally, the Black Mesa PPA is needed online prior to ldaho Power's July 2023 capacity deficit, and the developer of the Black Mesa project requires sufficient lead time for financing, procurement, and construction once Commission approval of the PPA is obtained in order to meet the Scheduled Commercial Operation date of June 1 ,2023. The PPA provides for day-for-day extension of the June 1 ,2023, Scheduled Commercial Operation if Commission approval of the PPA is not obtained by August 1, 2022. Consequently, ldaho Power respectfully requests the Commission consider a procedural schedule that would allow for a final Order prior to August 1,2022. V. 16. Communications and service of pleadings with reference to this Application should be sent to the following: Donovan E. Walker Tim Tatum Regulatory Dockets Connie Aschenbrenner ldaho Power Company ldaho Power Company 1221 West ldaho Street (83702) 1221 West ldaho Street (83702) P.O. Box 70 P.O. Box 70 Boise, ldaho 83707 Boise, ldaho 83707 dwalker@idahopower.com ttatum@idahopower.com dockets@idahopower.com caschenbrenner@idahopower.com VI. CONCLUSION 17. Approval of the Micron Special Contract and the BIack Mesa PPA is in the public interest. ldaho Power and Micron have worked together to establish a framework that will take a meaningful step towards accomplishing Micron's renewable energy goals, APPLICATION - 1O while ensuring the related pricing appropriately assigns the costs and benefits of procuring the Renewable Resource to Micron. The structure presented in this case is also consistent with the elements presented in the CEYW- Construction option. All costs associated with the Black Mesa PPA will be paid for by Micron, which ensures other customers are not harmed by the arrangement. The rates are just, reasonable, consistent with past cost-of-service determinations, and in the public interest. THEREFORE, ldaho Power respectfully requests that the Commission issue an Order before August 1, 2022 approving: 1) the replacement Special Contract between ldaho Power and Micron; 2) the 2O-year PPA between ldaho Power and Black Mesa, which was negotiated with the expectation of assigning that energy to Micron under the replacement Special Contract; 3) modifications to Schedule 26 necessary to incorporate the hourly reconciliation of Micron's energy requirement and the Renewable Resource(s); 4) the derivation of the capacity credit associated with the Renewable Resource(s) and compensation structure for excess renewable energy generation; 5) authorization to treat bill credits provided to Micron under the proposed compensation structure as prudently incurred expenses for ratemaking purposes, and 6) the Company's proposed accounting treatment. Respectfully submitted this 1Oh day of March 2022. fuzda!/<- DONOVAN E. WALKER Aftorney for ldaho Power Company APPLICATION - 11 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-06 IDAHO POWER COMPANY ATTACHMENT 1 TARIFF SCHEDULE 26 (Glean and Legislative Formats) ldaho Power Company Fifteenth Revised Sheet No. 26-1 Cancels |.P.U.C. No. 29. Tarffi No. 101 Fourteenth Revised Sheet No. 2&1 SCHEDULE 26 IDAHO PO\A/ER COMPANY ELECTRIC SERVICE RATE FOR MICRON TECHNOLOGY. INC. BOISE. IDAHO SPECIAL CONTRACT DATED MARCH 9. 2022 MONTHLY CHARGE The Monthly Charge is the sum of the following charges, and may also include charges as set forth in Schedule 55 (Power Cost Adjustment), Schedule 91 (Energy Efficiency Rider), and Schedule 95 (Adjustment for Municipal Franchise Fees). Terms used below have the meanings given to them in the Special Contract referenced above. Monthlv Contract Demand Charoe $1.64 per kW of Contract Demand. Monthlv Billino Demand Charge $10.79 per kW of Billing Demand but not less than Minimum Monthly Billing Demand. Minimum Monthlv Billino Demand The Minimum Monthly Billing Demand will be 25,000 kilowatts. Dailv Excess Demand Charoe $0.286 per each kW over the Contract Demand. Monthlv Enerov Charoe 2.76580, per kWh of Supplemental Energy Embedded Enerov Fixed Cost Charoe 0.26620, per k\Mr of Renewable Resource On-Site Usage Renewable Capacitv Credit(s) See Tables 1 and 2. Renewable Resource Cost As defined in Exhibit 1 of Micron's Special Contract, dated March 9,2022 Excess Generation Credit As defined in Exhibit 1 of Micron's Special Contract, dated March 9,2022 IDAHO lssued per Order No Effective - Issued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho ldaho Power Company !.P.U.C. No. 29. Tariff No. 101 OrioinalSheet No. 26-2 SCHEDULE 26 IDAHO PO\A/ER COMPANY ELECTRIC SERVICE RATE FOR MICRON TECHNOLOGY. INC. BOISE. IDAHO SPECIAL CONTRACT DATED MARCH 9. 2022 (Continued) RENEWABLE RESOURCE AGREEMENTS Calculation of the Renewable Capacity Credit for each Project is quantified in the tables below. The Renewable Capacity Credit will be provided to Micron monthly, starting the month of the Project's Renewable Capacity Credit Eligibility Date (as defined in Table 2) or the month following the respective Project's commercial operation date, whichever is later, and will remain in effect for the duration of the term of the Renewable Resource PPA or the period of time during which the ldaho Power-owned Renewable Resource will provide Project Output to Micron, as applicable. *Table 2 denotes each project's date of eligibility for the Renewable Capacity Credit TABLE l: RENEWABLE CAPACIW CREDIT (a)(b)(c)(d)(e)(fl Project Most Recently Acknowledged IRP Project Nameplate (kwAc) Capacity Contribution Fac{or Renewable Capacity Contribution (a. b) Renewable Capacity Credit Rate ($/kw-Y4 Renewable Capacity Credit Adjustment Renewable Capacity Credit; monthly' ((c.d*e) / 12) Black Mesa Energy LLC 2019 40,000 o.fi42 '14,568 $121.19 1.0 $147,124.66 TABLE 2: ELIGIBILITY DATE FOR RENEWABLE CAPACITY CREDIT Proiect PPA Execution Date Capacitv Deficiencv Year Renewable Caoacitu Credit Elioibilitu Date Black Mesa Energy LLC 2t16t2022 2023 7t1t2023 IDAHO lssued per Order No Effective - lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho ldaho Power Company@Revised Sheet No. 26-1 Cancels |.P.U.C. No. 29. Tariff No. 1O1Thi*eenttr Fourteenth Revised Sheet No. 26-1 SCHEDULE 26 IDAHO PO\A,ER COMPANY ELECTRIC SERVICE RATE FOR MICRON TECHNOLOGY. INC. BOISE. IDAHO SPECIAL CONTRACT DATED DEGEMSERMARCH 299. 2O22Og MONTHLY CHARGE The Monthly Charge is the sum of the following charges, and may also include charges as set forth in Schedule 55 (Power Cost Adjustment), Schedule 91 (Energy Efficiency Rider), and Schedule 95 (Adjustment for Municipal Franchise Fees). Special Contract referenced above. Monthlv Contract Demand Charoe $1.64 per kW of Contract Demand Monthlv Billino Demand Charoe $10.79 per kW of Billing Demand but not less than Minimum Monthly Billing Demand. Minimum Monthlv Billinq Demand The Minimum Monthly Billing Demand willbe 25,000 kilowatts. Dailv Excess Demand Charoe $0.286 per each kW over the Contract Demand Monthlv Enerov Charoe 2.76580, per kWh of Supplemental Enerov. Embedded Enerov Fixed Cost Charoe 0.2662d per kWh of Renewable Resource On-Site Usaoe Renewable Capacity Credit(s) See Tables 1 and2 Renewable Resource Cost As defined in Exhibit 1 of Micron's Soecial Contract- dated March 9.2022. Excess Generation Credit As defined in Exhihit I of [tlicron's Soecial Contract- dated March I 2022- IDAHO lssued per Order No. 34.885 Effective - Jent eFf++g2j+ lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho ldaho Power Company LP.U.C. No. 29. Tariff No. 101 OrioinalSheet No. 26-2 SCHEDULE 26 IDAHO PO\A/ER COMPANY ELECTRIC SERVICE RATE FOR MICRON TECHNOLOGY. INC. BOISE. IDAHO SPECIAL CONTRACT DATED MARCH 9.2022 (Continued) RENEWABLE RESOURCE AGREEMENTS Calculation of the Renewable Capacifu Credit for each Proiect is ouantified in the tables below. The Renewable Caoacitv Credit will be orovided to Micron monthlv. startino the month of the Proiect's Renewable Capacitv Credit Eliqibilitv Date (as defined in Table 2) or the month followinq the respective Proiect's commercial operation date. whichever is later. and will remain in effect for the duration of the term of the Renewable Resource PPA or the period of time durino which the ldaho Power-owned Renewable Resource will provide Proiect Output to Micron. as aoolicable. *Table 2 denotes each proiect's date of elioibility for the Renewable Capacitv Credit TABLE 1: RENEWABLE CAPACITY CREDIT (a)(b)(c)(d)(e)(f) Proiect Most Recentlv Acknowledqed IRP Proiect Nameplate(kwAc) Capacitv Contribution Factor Renewable Caoacitv Contribution(a*b) Renewable Caoacitv Credit Rate ($/kW-vr) Renewable Caoacitv Credit Adiustment Renewable Caoacitv Credit: monthlv* ((c*d'e) / 12) Black Mesa Enerov LLC 2019 40,000 0.36/.2 14.s68 $121.19 1.0 $147.124.66 TABLE 2: ELIGIBILITY DATE FOR RENEWABLE CAPACITY CREDIT Proiect PPA Execution Date Caoacitv Deficiencv Year Renewable Capacitv Credit Eliqibilitv Date Black Mesa Enerov LLC 2t16t2022 2023 7t1t2023 IDAHO lssued per Order No. Effective - lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho