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HomeMy WebLinkAbout20220310Aschenbrenner Direct.pdf 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 WITH BLACK MESA ENERGY, LLC. ) ) ) ) ) ) CASE NO. IPC-E-22-06 IDAHO POWER COMPANY DIRECT TESTIMONY OF CONNIE G. ASCHENBRENNER ASCHENBRENNER, DI 1 Idaho Power Company Q. Please state your name, business address, and 1 present position with Idaho Power Company (“Idaho Power” or 2 “Company”). 3 A. My name is Connie G. Aschenbrenner. My 4 business address is 1221 West Idaho Street, Boise, Idaho, 5 83702. I am employed by Idaho Power as the Rate Design 6 Senior Manager in the Regulatory Affairs Department. 7 Q. Please describe your educational background. 8 A. In May of 2006, I received a Bachelor of 9 Business Administration degree in Finance from Boise State 10 University in Boise, Idaho. In December of 2011, I earned 11 a Master of Business Administration degree from Boise State 12 University. In addition, I have attended the electric 13 utility ratemaking course The Basics: Practical Regulatory 14 Training for the Electric Industry, a course offered 15 through New Mexico State University’s Center for Public 16 Utilities. 17 Q. Please describe your work experience with 18 Idaho Power. 19 A. In 2012, I was hired as a Regulatory Analyst 20 in the Company’s Regulatory Affairs Department. My primary 21 responsibilities included support of the Company’s 22 Commercial and Industrial customer class’s rate design and 23 general support of tariff rules and regulations. In 2015, 24 I assumed responsibilities associated with Residential and 25 ASCHENBRENNER, DI 2 Idaho Power Company Small General Service rate design, as well as regulatory 1 support associated with demand-side management (“DSM”) 2 activities. In 2016, I was promoted to a Senior Regulatory 3 Analyst, and my responsibilities expanded to include the 4 development of complex cost-related studies. In 2017, I 5 was promoted to Rate Design Manager for Idaho Power, and in 6 2019 I was promoted to my current role as Rate Design 7 Senior Manager. I am currently responsible for the 8 management of the rate design strategies of the Company, as 9 well as oversight of all tariff administration. In my 10 current role, I am one of the Company representatives at 11 its Energy Efficiency Advisory Group (“EEAG”) meetings. 12 Q. What is the Company requesting in this case? 13 A. Idaho Power is requesting the Idaho Public 14 Utilities Commission (“Commission”) approve: 1) a revised 15 Special Contract for Idaho Power to provide retail electric 16 service to Micron Technology, Inc. (“Micron”), which is 17 inclusive of pricing elements that facilitate a Renewable 18 Resource arrangement to support Micron’s desire to contract 19 for a dedicated renewable energy project(s) to support its 20 renewable energy goals; and 2) a 20-year Power Purchase 21 Agreement (“PPA”) between Idaho Power and Black Mesa 22 Energy, LLC (“Black Mesa”), which was negotiated with the 23 expectation of assigning the associated energy to Micron 24 under the ESA. 25 ASCHENBRENNER, DI 3 Idaho Power Company The revised Special Contract is intended to fully 1 replace the current Special Contract between Idaho Power 2 and Micron, which has been in effect since December 29, 3 2009 (the “Current Agreement”) and is hereinafter referred 4 to as the Micron Energy Services Agreement (“ESA”). Under 5 the terms of the Black Mesa PPA, Black Mesa will build, 6 own, operate and maintain a 40 megawatt (“MW”) alternating 7 current (“AC”) solar photovoltaic generation facility 8 (“Renewable Resource”) and will supply the output to Idaho 9 Power’s system. 10 Q. Please provide a brief history of Micron’s 11 Special Contract with Idaho Power. 12 A. Idaho Power and Micron have operated under a 13 Special Contract agreement since August 31, 1995. Since the 14 original Agreement between Micron and Idaho Power was 15 initially approved by the Commission in 1995, there were a 16 number of amendments and extensions, with that initial 17 contract ultimately being replaced by the Current Agreement 18 in 2009.1 Idaho Power has provided energy services to Micron 19 under the Current Agreement since 2009. 20 Q. Please describe what prompted Idaho Power and 21 Micron to discuss modifications to the Current Agreement. 22 1 In the Matter of Idaho Power Company’s Application for Approval of a replacement Special Contract with Micron Technology, Inc., Case No. IPC-E-09-35, filed December 31, 2009. ASCHENBRENNER, DI 4 Idaho Power Company A. Micron has publicly announced a goal that it 1 will source renewable energy to meet its goal of using 100 2 percent renewable energy to support its U.S. manufacturing 3 operations by calendar year 2025. Micron initiated 4 discussions with Idaho Power in 2021 to determine what, if 5 any, arrangements could be facilitated in Idaho Power’s 6 service area to take steps towards achieving their 7 corporate renewable goal. As a result of those 8 conversations, Idaho Power and Micron have entered into the 9 proposed ESA, which envisions Idaho Power procuring an 10 initial Renewable Resource of 40 MW on behalf of – and to 11 be paid for by - Micron. As explained in more detail below, 12 Micron’s ESA encompasses pricing associated with retail 13 electric service from Idaho Power, cost and credit 14 components associated with new Renewable Resources, and 15 terms and conditions governing the structure of the new 16 arrangement, including provisions necessary to prevent cost 17 shift to other Idaho Power customers for the cost of the 18 Renewable Resources. 19 Q. Is the framework presented in the Micron ESA 20 consistent with the Clean Energy Your Way (“CEYW”) – 21 Construction option, as outlined in Idaho Power’s recent 22 application with the Commission (Case No. IPC-E-21-40)? 23 A. Yes. The Micron ESA reflects the CEYW 24 framework for large customers as outlined in the Company’s 25 ASCHENBRENNER, DI 5 Idaho Power Company application and in the accompanying proposed Schedule 62 1 tariff schedule. In that application, Idaho Power states 2 its belief that it can work with existing Special Contract 3 customers to integrate renewables into their service 4 agreement with the Company. Accordingly, while the Micron 5 ESA is customized to align with Micron’s specific 6 requirements, the structure is consistent with the 7 Renewable Construction Agreement envisioned under the CEYW 8 – Construction option. For Micron, the Renewable 9 Construction Agreement is incorporated into their proposed 10 Special Contract, in this case the Micron ESA. 11 Q. What are the major components of the Company’s 12 requested regulatory framework related to the ESA in this 13 matter? 14 A. The specific components of the regulatory 15 framework for which Idaho Power respectfully requests 16 explicit approval are the following: 1) modifications to 17 Schedule 26 Electric Service Rate for Micron Technology, 18 Inc. Boise, Idaho (“Schedule 26”) necessary to incorporate 19 the hourly reconciliation of Micron’s energy requirement 20 and the Renewable Resource(s), 2) the derivation of the 21 capacity credit associated with the Renewable Resource(s) 22 and compensation structure for excess renewable energy 23 generation, 3) authorization to treat bill credits provided 24 to Micron under the proposed compensation structure as 25 ASCHENBRENNER, DI 6 Idaho Power Company prudently incurred expenses for ratemaking purposes, and 4) 1 the cost recovery mechanisms necessary to protect existing 2 Idaho Power customers from cost shifting and ensure Idaho 3 Power has an opportunity to recover its cost of service. 4 Q. How is your testimony organized? 5 A. First, I will provide an overview of the 6 renewable resource arrangement proposed in the Micron ESA 7 to support Micron’s clean energy goals, including the 8 initial agreement to procure 40 MW of renewable energy from 9 the Black Mesa project. Next, I will describe the 10 circumstances that led to Idaho Power entering into the 11 Black Mesa PPA and the pertinent terms of that agreement. 12 Finally, I will describe the pricing structure contained 13 within the proposed Micron ESA and Black Mesa PPA and the 14 no-harm analysis conducted to demonstrate that the proposal 15 will not negatively impact Idaho Power’s other retail 16 customers. 17 Q. Have you prepared any exhibits to accompany 18 your testimony? 19 A. Yes. The Micron ESA is presented as Exhibit 20 No. 1. The fully executed PPA between Idaho Power and Black 21 Mesa for procurement of renewable energy on behalf of 22 Micron is included as Confidential Exhibit No. 2 to my 23 testimony. Finally, the no-harm analysis is presented as 24 Exhibit No. 3 to my testimony. 25 ASCHENBRENNER, DI 7 Idaho Power Company I. Summary of Renewable Resource Arrangement 1 Q. Please provide an overview of the elements 2 necessary to incorporate a Renewable Resource arrangement 3 into the Micron ESA. 4 A. Under the proposed Micron ESA, Idaho Power 5 will procure, on Micron’s behalf, Renewable Resources to 6 assist Micron in meeting a portion of its annual energy 7 requirements with energy generated by those resources. The 8 ESA envisions an initial Renewable Resource – the Black 9 Mesa project – and provides flexibility for Idaho Power to 10 work with Micron to develop additional renewable resources 11 in Idaho Power’s service area, if mutually agreeable, to 12 support Micron’s corporate renewable goal. The associated 13 Renewable Energy Certificates (“RECs”) will be retained and 14 retired by Idaho Power on behalf of Micron. 15 Q. Will the Renewable Resources serve Micron 16 directly? 17 A. No. It is expected that the resources will be 18 procured on Micron’s behalf by Idaho Power and connected 19 directly to the Company’s transmission system. Micron will 20 pay for the renewable output at the PPA contract rate and 21 will also be credited for any value those resources bring 22 to Idaho Power’s system. 23 Q. Do the new Renewable Resources affect how 24 Micron will be billed for taking service from Idaho Power? 25 ASCHENBRENNER, DI 8 Idaho Power Company A. Yes. Rather than simply being charged for 1 retail electric service as it is under the Current 2 Agreement, Micron will be charged for standard services 3 (i.e., services exclusive of the Renewable Resource) it 4 requires from Idaho Power, pay for the costs of the 5 Renewable Resource(s), and be credited for any system 6 benefits derived from those resources. This treatment is 7 consistent with the structure outlined in the Clean Energy 8 Your Way – Construction option in Idaho Power’s Case No. 9 IPC-E-21-40. 10 Q. How will Micron be billed under the proposed 11 ESA? 12 A. The specific pricing components are more fully 13 explained later in my testimony, but at a high level, Idaho 14 Power will reconcile Micron’s energy use against the Black 15 Mesa production (and any future Renewable Resources) on an 16 hourly basis to identify the amount of service required 17 from Idaho Power versus the amount of generation from the 18 Renewable Resource(s). 19 More specifically: 20  When the Renewable Resource is not generating, 21 Micron will continue to take fully bundled 22 service from Idaho Power at its standard 23 Schedule 26 Monthly Energy Charge. 24 ASCHENBRENNER, DI 9 Idaho Power Company  When the Renewable Resource is generating, 1 Micron will pay for all output at the PPA 2 contract rate. Micron will also be assessed the 3 Embedded Fixed Cost of Energy for all kilowatt-4 hours (“kWhs”) of consumption met by the 5 Renewable Resource. 6  A capacity value associated with the Renewable 7 Resource’s contribution to peak capacity will 8 be credited to Micron. 9  In any given hour, if the renewable generation 10 exceeds Micron’s energy use, Idaho Power will 11 credit Micron for the value of that excess 12 generation. 13  Micron will continue to pay all fixed costs in 14 their energy rate, as well as standard rates, 15 charges, and fees for fully bundled service 16 provided by Idaho Power. 17 Q. Does the Micron ESA contain any provisions 18 intended to financially protect Idaho Power and its 19 customers if Micron were to default? 20 A. Yes. Section 12.1 of the Micron ESA outlines 21 requirements for Micron to provide credit support. The 22 amount of support is intended to cover the energy costs 23 associated with the PPA (included as Exhibit No. 2) that is 24 the greater of $90 per kilowatt (“kW”) of renewable 25 ASCHENBRENNER, DI 10 Idaho Power Company resource PPA nameplate capacity or the difference between 1 market price and the PPA price. This provision protects 2 Idaho Power’s customers in the unlikely event of default by 3 Micron and when the remaining cost of the renewable 4 resource exceeds its market value. The term of the Micron 5 ESA is proposed to remain in effect until the expiration or 6 termination of the PPA. 7 Q. Does the ESA contemplate if a portion of the 8 Black Mesa PPA output is dedicated to another Idaho Power 9 customer? 10 A. Yes. Micron has agreed that 10 MW of the Black 11 Mesa PPA output may be reserved for and dedicated to 12 another Idaho Power customer who would like to participate 13 in the CEYW – Construction option, at the election of Idaho 14 Power. If this occurs, the Renewable Resource output, 15 associated credit support, and respective pricing 16 components may be impacted on a pro-rata basis to reflect a 17 30 MW portion remaining dedicated to Micron. 18 II. Pricing 19 Q. Is Idaho Power proposing to modify the rates 20 Micron pays for consumption as part of this filing? 21 A. No. Micron’s load requirements are not 22 changing as part of this request and, as such, the Company 23 is not proposing to modify Micron’s revenue requirement 24 associated with service it takes from Idaho Power. There 25 ASCHENBRENNER, DI 11 Idaho Power Company are, however, necessary changes proposed to Schedule 26 1 that will ensure Idaho Power continues to have an 2 opportunity to collect all costs associated with providing 3 service to Micron, while recognizing that certain costs 4 will be avoided when Micron takes service from the 5 Renewable Resource. 6 Q. Please describe the pricing elements proposed 7 in the ESA. 8 A. Overall, there will be charges associated with 9 Idaho Power-provided service and charges/credits associated 10 with the Renewable Resource. These pricing elements are 11 detailed in Exhibit 1 – Pricing of the Micron ESA. 12 Micron will continue to pay the currently approved 13 Monthly Contract Demand Charge, Monthly Billing Demand 14 Charge, and Daily Excess Demand Charge based on the metered 15 consumption at the Points of Delivery (“POD”), as they do 16 under their Current Agreement. Idaho Power is not proposing 17 to modify these charges as part of this case. Micron will 18 also pay the existing Schedule 26 Monthly Energy Charge for 19 the amount for each hour by which energy output from the 20 Renewable Resource is less than Micron’s energy requirement 21 – this amount is defined as “Supplemental Energy” in the 22 Micron ESA. 23 When the Renewable Resource is generating, Micron 24 will pay the full cost of the output from the Renewable 25 ASCHENBRENNER, DI 12 Idaho Power Company Resource and will pay the Embedded Energy Fixed Cost Charge 1 for the portion of Micron’s hourly energy requirement met 2 by the Renewable Resource as defined in the Micron ESA and 3 included in the proposed Schedule 26. These pricing 4 elements are important to ensure Micron pays the full cost 5 associated with the Renewable Resource on Idaho Power’s 6 system and that it continues to contribute its allocated 7 share of fixed costs on Idaho Power’s system. 8 In terms of credits, Idaho Power proposes Micron 9 receive a Renewable Capacity Credit to recognize the 10 capacity value the Renewable Resource brings to Idaho 11 Power’s system. And while Idaho Power believes it is 12 unlikely the initial Renewable Resource – the Black Mesa 13 project - will generate energy in excess of Micron’s hourly 14 usage, the Micron ESA also proposes a compensation 15 structure in the event this does occur. 16 Q. Please describe how the hourly energy 17 requirements will be determined. 18 A. Micron’s consumption will be metered and 19 measured on an hourly basis. Usage net of the Renewable 20 Resource’s production will determine the amount of 21 Supplemental Energy delivered to Micron. In the event 22 supply from the Renewable Resource exceeds Micron’s total 23 metered consumption, the amount in excess would be 24 ASCHENBRENNER, DI 13 Idaho Power Company considered “Excess Generation” under the contract and would 1 be compensated as such. 2 Q. When the Renewable Resource is generating, 3 what costs will Micron pay to Idaho Power for energy usage? 4 A. Micron will pay the Monthly Energy Charge for 5 all metered usage, net of the Renewable Resource 6 generation, referred to as the “Supplemental Energy.” 7 Micron will also continue to pay the Embedded Energy Fixed 8 Cost Charge of $.002662 for each kWh of energy generated 9 from the Renewable Resource and subsequently matched 10 against Micron’s hourly usage. This rate is determined by 11 reducing Micron’s Monthly Energy Charge by costs classified 12 as energy-related through the Company’s class cost-of-13 service methodology. For the proposed rate in this case, 14 the Company calculated the embedded energy-related costs by 15 starting with the cost-of-service study most recently 16 reviewed by the Commission,2 updated to incorporate 17 subsequent Commission-approved revenue requirement changes 18 that impact the authorized level of energy-related cost 19 recovery. The Embedded Energy Fixed Cost was then 20 calculated by removing the embedded energy-related costs 21 from the fully bundled Monthly Energy Charge. 22 2 In the Matter of the Application of Idaho Power Company for Authority to Increase its Rates and Charges for Electric Service in Idaho, Case No. IPC-E-11-08, Order No. 32426 (Dec 30, 2011). ASCHENBRENNER, DI 14 Idaho Power Company Q. Why is it appropriate to assess the Embedded 1 Energy Fixed Cost Charge to Micron? 2 A. Assessing the Embedded Energy Fixed Cost 3 Charge to Micron will ensure that Micron continues to 4 contribute to system fixed costs the Commission previously 5 authorized to be paid for by Micron. This element is 6 important to prevent cost shifts to other customers. 7 Q. Please describe what the Renewable Capacity 8 Credit represents and how it was derived. 9 A. The Renewable Capacity Credit represents the 10 levelized capacity cost of a surrogate avoided capacity 11 resource, adjusted to reflect the Renewable Resource’s 12 Capacity Contribution Factor. Under the proposed Micron 13 ESA, both components are based on the 2019 IRP. To 14 determine when Micron would be eligible to receive the 15 credit, the Company took into consideration the next 16 capacity deficiency date based on the current load and 17 resource balance. 18 Based on a Renewable Capacity Contribution of 36.42 19 percent, a Renewable Capacity Credit Rate of $121.19/kW-20 year, the Company proposes Micron receive a Renewable 21 Capacity Credit of $147,124.66, monthly. The crediting will 22 not actually begin until the month of the project’s 23 Renewable Capacity Credit Eligibility Date or the month 24 following the respective project’s commercial operation 25 ASCHENBRENNER, DI 15 Idaho Power Company date, whichever is later, and will remain in effect for the 1 duration of the Renewable Resource term. It is expected the 2 crediting will start in July 2023 (the next capacity 3 deficiency date) as the Black Mesa project’s commercial 4 operation date is June 2023. 5 Q. How did Idaho Power determine the proposed 6 capacity deficiency year to be relied on? 7 A. The Company looked to the most recently 8 acknowledged IRP – the 2019 Second Amended IRP – however, 9 in recognition of the changed circumstances that have taken 10 place with regard to the date of first capacity deficit 11 since the 2019 IRP was acknowledged, Idaho Power proposes 12 to use the capacity deficiency year proposed in Case No. 13 IPC-E-21-09. 3 Aligning the date in this case will result in 14 Micron receiving a capacity credit starting in July 2023, 15 consistent with the Company’s recommendation for capacity 16 deficiency to be utilized for other Avoided Cost 17 Calculations. When future Renewable Resources are 18 contemplated, those future resources would be eligible to 19 receive the capacity credit starting with the next capacity 20 deficiency date based on the load and resource balance from 21 the then most recently acknowledged IRP. This method aligns 22 3 In the Matter of Idaho Power Company’s Application for Approval of the Capacity Deficiency to be Utilized for Avoided Cost Calculations, Idaho Power Company’s Motion and Amended Application, pg. 4-5, filed February 4, 2022. ASCHENBRENNER, DI 16 Idaho Power Company with how sellers are compensated for capacity under PURPA 1 agreements. 2 Q. Does Idaho Power propose to include any other 3 adjustments to the Renewable Capacity Credit? 4 A. Yes. Idaho Power has proposed to include a 5 “Renewable Capacity Credit Adjustment” in Schedule 26. This 6 adjustment is a factor, between 0 and 1, that will be 7 applied to the Renewable Capacity Credit and will take into 8 account the adjustment necessary to ensure costs are not 9 shifted to other customers as a result of future Renewable 10 Resource additions. 11 Q. Did Idaho Power consider whether a Renewable 12 Capacity Credit Adjustment was necessary for the Black Mesa 13 PPA? 14 A. Yes. As described later in my testimony, the 15 Company performed a no-harm analysis to ensure the addition 16 of the Renewable Resource, inclusive of the proposed 17 compensation structure, did not result in increased costs 18 being shifted to other customers. That analysis 19 demonstrated no adjustment was necessary. 20 Q. How does Idaho Power propose to compensate 21 Micron for Excess Generation? 22 A. Idaho Power proposes to compensate Micron at a 23 price commensurate to the value of any excess generation on 24 Idaho Power’s system. The proposed Micron ESA defines this 25 ASCHENBRENNER, DI 17 Idaho Power Company price as the hourly Mid-Columbia (“Mid-C”) price forecast 1 used in Idaho Power’s most recently acknowledged IRP, with 2 a non-firm adjustment from Idaho Power’s Schedule 86 – 3 Cogeneration and Small Power Production Non-Firm Energy 4 (“Schedule 86”), currently 82.4 percent, applied to each 5 hour’s price. The Mid-C forecast will be updated over time 6 with each subsequent IRP acknowledgement, and the non-firm 7 adjustment will be updated to reflect any future changes to 8 Schedule 86, which will ensure the price paid to Micron for 9 excess generation is reflective of conditions present at 10 any given point in time. 11 Q. Does Idaho Power expect the Black Mesa 12 generation to exceed Micron’s energy needs on an hourly 13 basis? 14 A. No. Upon reviewing Micron’s 2021 hourly energy 15 usage and the estimated generation from the Black Mesa PPA, 16 there were no hours where the renewable production would 17 have exceeded Micron’s usage. 18 Q. If Idaho Power does not expect the Renewable 19 Resource to generate more than Micron’s energy needs on an 20 hourly basis, why is it proposing to include a provision 21 for Hourly Excess Energy compensation? 22 A. While it is not expected, nor likely to occur 23 with Black Mesa as the sole Renewable Resource project, in 24 the event the Renewable Resource generates more than 25 ASCHENBRENNER, DI 18 Idaho Power Company Micron’s energy usage, it is fair and reasonable to 1 compensate Micron for that excess energy as Micron will pay 2 for all of the PPA output – regardless of their usage. 3 Further, establishing the compensation structure for Hourly 4 Excess Energy as part of the Current Agreement will ensure 5 Micron receives compensation for Excess Energy from future 6 Renewable Resource projects. 7 Q. Please summarize the timing and source of 8 updates for each of the pricing elements. 9 A. Idaho Power proposes to update the charges 10 Micron is assessed for standard Idaho Power service (i.e., 11 the portion of Micron’s energy needs not supported by the 12 Renewable Resource) only as part of a revenue requirement 13 proceeding in which all rates for consumption are reviewed. 14 The Renewable Capacity Credit associated with the Black 15 Mesa project is envisioned to be approved as part of this 16 proceeding and will not adjust through the duration of the 17 PPA. Finally, the Excess Generation Price will be 18 established and updated with the acknowledgement of future 19 IRPs, and the non-firm adjustment will mirror Schedule 86. 20 Q. Will Idaho Power seek Commission approval to 21 incorporate pricing elements into Schedule 26 associated 22 with additional Renewable Resources procured or constructed 23 on behalf of Micron? 24 ASCHENBRENNER, DI 19 Idaho Power Company Q. Yes. If Idaho Power enters into a future 1 agreement to develop additional Renewable Resources in 2 Idaho Power’s service area, Idaho Power will submit a 3 filing to update Tables 1 and 2 in Schedule 26. As part of 4 that filing, Idaho Power will present a no harm analysis, 5 which will be the basis for any proposed Renewable Capacity 6 Credit Adjustment. 7 Q. Please describe the applicability of Schedule 8 55, Power Cost Adjustment (“PCA”), Schedule 91, Energy 9 Efficiency Rider, and Schedule 95, Adjustment for Municipal 10 Franchise Fees, to the Micron ESA and Schedule 26. 11 A. The PCA will continue to be assessed against 12 all Supplemental Energy supplied to Micron; however, the 13 PCA will not be assessed against energy supplied by the 14 Renewable Resource in a given hour. This treatment 15 appropriately recognizes that Micron will be fully 16 responsible for the cost of the PPA when it is generating. 17 The Energy Efficiency Rider (Schedule 91) charge will be 18 assessed against all Idaho Power base rate charges assessed 19 for Idaho Power-supplied energy (inclusive of the Embedded 20 Energy Fixed Cost Charge) contained within Schedule 26 net 21 of Renewable Resource credits. The Adjustment for Municipal 22 Franchise Fees (Schedule 95) charge is computed by 23 multiplying the applicable fee percentage by the sum of all 24 billed amounts received from Micron, which will include the 25 ASCHENBRENNER, DI 20 Idaho Power Company PCA and the Renewable Resource pass-through payment and be 1 net of the Renewable Resource credits. 2 Q. What PCA treatment does the Company propose 3 for the Micron ESA? 4 A. Idaho Power proposes that all costs and 5 revenues related to energy output from the Renewable 6 Resource be excluded from the PCA, as those amounts will 7 net to zero under the proposed ESA as Micron pays for the 8 full Renewable Resource output. Further, any energy 9 requirements met by the Renewable Resource will not be 10 included in the PCA sales based adjustment (SBA) and will 11 not be used in the derivation of the future PCA rates. All 12 Supplemental Energy supplied to Micron will be included in 13 the PCA, SBA and used for PCA rate derivation purposes. 14 Renewable Resource Excess Generation and Renewable Capacity 15 Credit payments provided to Micron will be included in the 16 PCA as a net power supply cost at 100 percent, consistent 17 with treatment for Public Utility Regulatory Policies Act 18 of 1978 (“PURPA”) resources. 19 Q. Please describe the accounting treatment for 20 the proposed charges and credits. 21 A. Idaho Power’s payments for the Renewable 22 Resource PPA will be recorded in Account 555 but will not 23 be included in the PCA. Conversely, Micron’s payments to 24 ASCHENBRENNER, DI 21 Idaho Power Company Idaho Power for the Renewable Resource PPA will be recorded 1 in Account 442 and will not be included in the PCA. 2 Excess Generation and Renewable Capacity Credit 3 payments provided to Micron will be recorded in Account 555 4 and included in the PCA. Micron’s payments for Supplemental 5 Energy and all Idaho Power base rate charges assessed for 6 Idaho Power-supplied energy (inclusive of the Embedded 7 Energy Fixed Cost Charge) will be recorded in Account 442 8 and treated in the same manner as standard retail sales. 9 Q. Is Idaho Power proposing any modifications to 10 Schedule 26? 11 A. Yes. Attachment No. 1 to the Application in 12 this matter contains the proposed modifications to Schedule 13 26 (the tariff schedule associated with Micron’s special 14 contract). As described more fully in my testimony, Idaho 15 Power proposes several adjustments necessary to incorporate 16 the CEYW - Construction option framework into the service 17 schedule. 18 III. Black Mesa PPA 19 Q. How did Idaho Power determine that the Black 20 Mesa solar project was a good fit for the Micron ESA? 21 A. At the time Idaho Power was evaluating the 22 Request For Proposal (“RFP”) project bids for meeting the 23 ASCHENBRENNER, DI 22 Idaho Power Company 2023 capacity deficit,4 the Company was simultaneously 1 negotiating with Micron to incorporate a CEYW – 2 Construction option agreement into its special contract. 3 Idaho Power viewed the timing of Micron’s interest 4 in a new Renewable Resource and Idaho Power’s system 5 capacity needs as a potential “win-win” opportunity. That 6 is, the PPA with Black Mesa will provide for the earliest 7 Renewable Resource option available to meet Micron’s 8 renewable energy supply needs, while allowing Idaho Power 9 to utilize the energy output from Black Mesa’s solar PV 10 facility to fuel a future energy storage project to meet 11 peak capacity needs, with 100 percent of the solar output 12 costs being paid for by Micron. Because of the relationship 13 of the special contract and the PPA, the Company is 14 requesting approval of both Micron’s ESA and the Black Mesa 15 solar PPA in this case. 16 Q. Please provide an overview of the PPA 17 between Idaho Power and Black Mesa. 18 A. On February 16, 2022, Idaho Power and Black 19 Mesa entered into a PPA for the sale and purchase of 40 MW 20 4 On May 20, 2021 Idaho Power released a public Notice of Intent to industry developers and media outlets noticing the Company’s intent to release an RFP. On June 30, 2021, Idaho Power issued a formal request for competitive proposals focused on the acquisition of resources of up to 80 MW of wind, solar, and storage combinations to meet the 2023 capacity deficiency. ASCHENBRENNER, DI 23 Idaho Power Company AC of renewable solar electric generation from the Black 1 Mesa project for the period of twenty years from a 2 commercial operation date of June 1, 2023. An executed copy 3 of the PPA is attached to my testimony as Confidential 4 Exhibit No. 2. The PPA contains non-levelized, fixed 5 pricing that escalates at 2.0 percent annually during the 6 term. Exhibit 5 to the PPA sets forth the Contract Price 7 for Contract Years 1 through 20 on a dollars per megawatt-8 hour ("MWh") basis. The PPA is similar in many ways to the 9 numerous energy sales agreements approved by the Commission 10 pursuant to the Company's obligations under PURPA, but also 11 contains additional other terms and conditions consistent 12 with industry standard, non-PURPA power purchase agreements 13 including pricing, security, and other terms of service. 14 Q. Does the PPA provide for any assurances or 15 guarantees related to the commercial operation date of June 16 1, 2023, and ongoing operation of the solar facility? 17 A. Yes. The PPA provides for a Guaranteed 18 Commercial Operation Date, which is 180 days after the 19 Scheduled Operation Date under Section 1.59. Section 9 of 20 the Agreement contains provisions requiring the Seller to 21 post and maintain security, both Project Development 22 Security and Default Security. A Project Development 23 Security in the amount of $90 per kW of Nameplate Capacity 24 Rating must be in place within 30 days of a final order of 25 ASCHENBRENNER, DI 24 Idaho Power Company the Commission approving the Agreement and will remain in 1 place to ensure the project meets its Commercial Operation 2 Date. A Default Security in the initial amount of $45 per 3 kW of Nameplate Capacity Rating must be in place at the 4 Commercial Operation Date and must be maintained through 5 the entire term of the Agreement. The amount of Default 6 Security reduces to $35 per kW of Nameplate Capacity Rating 7 starting in Contract Year 11. Default Security may be used 8 for any Deficit Damages if the project is brought online at 9 less than the Expected Nameplate Capacity or for any other 10 damages Idaho Power suffers if the Agreement is terminated 11 because of the Seller's default. 12 Q. Does the PPA contain any performance 13 guarantees? 14 A. Yes. The Agreement contains a performance 15 requirement in the form of an Output Guarantee. Section 16 7.12. Under the Output Guarantee, the Seller is obligated 17 to deliver 90 percent of the Estimated Monthly Output of 18 the Facility on a monthly basis. Similar to recent 19 provisions from PURPA agreements, the PPA allows the Seller 20 an adjustment of Estimated Monthly Net Output Amounts by 21 the 25th day of the preceding month in Section 7.12.1.2. If 22 the project delivers less than the Output Guarantee during 23 any month, the Seller must pay the Output Shortfall for 24 that month multiplied by Idaho Power's Cost to Cover as 25 ASCHENBRENNER, DI 25 Idaho Power Company liquidated damages in Section 7.12.2. If the delivered Net 1 Output is equal to or greater than the Output Guarantee, 2 then the Seller is deemed to have satisfied the Output 3 Guarantee in Section 7.12.2.1.9. Section 7 of the Agreement 4 contains standard provisions for operation and control of 5 the project. These include such things as planned outages, 6 forced outages, and maintenance outages, as well as 7 scheduling, forecasting, generator output limit control 8 (“GOLC”), and metering. For forecasting, the PPA provides 9 the same allocated portion of the total cost of Idaho 10 Power's Solar Energy Production Forecast model that is used 11 for all solar projects that are under contract to provide 12 energy to Idaho Power. 13 Q. Will Idaho Power take ownership of any Green 14 Tags or Environmental Attributes associated with the 15 Facility? 16 A. Yes. Under the PPA, Idaho Power will own 100 17 percent of the Green Tags or Environmental Attributes 18 associated with the Facility and will retire such 19 attributes on behalf of Micron under the proposed ESA. 20 Q. When will the PPA become effective? 21 A. Section 3.1.1 provides that the PPA will not 22 become effective unless the Commission has approved all of 23 the PPA's terms and conditions and declared that all 24 payments Idaho Power makes to Seller for purchases of 25 ASCHENBRENNER, DI 26 Idaho Power Company energy will be allowed as prudently incurred expenses for 1 ratemaking purposes. The obligation of Idaho Power to 2 purchase energy under the PPA will not become finally 3 effective should it be disapproved by either the IPUC or 4 the OPUC. This section provides that subsequent to 5 execution of the PPA, Idaho Power will seek a final order 6 regarding approval or rejection of the Agreement from the 7 IPUC prior to August 1, 2022, and that if Commission 8 approval is not obtained by August 1, 2022, the Scheduled 9 Commercial Operation Date and Guaranteed Commercial 10 Operation Date may be extended on a day-for-day basis until 11 approval is obtained. Should Commission approval not be 12 obtained by November 1, 2022, then the Seller has the right 13 to terminate the Agreement. 14 IV. No-Harm Financial Analysis 15 Q. Please describe the analysis Idaho Power 16 undertook to evaluate whether the revenue collected under 17 the proposed Micron ESA would cover any incremental costs 18 incurred by Idaho Power’s system to incorporate the 19 acquisition of the Renewable Resource. 20 A. Idaho Power completed a present-value revenue 21 requirement analysis for two scenarios and evaluated the 22 difference in incremental system resource and power supply 23 cost from Micron’s participation in the CEYW – Construction 24 ASCHENBRENNER, DI 27 Idaho Power Company option and the addition of the Black Mesa PPA to test any 1 cost shift to Idaho Power’s other customers is avoided. 2 Q. Please describe how the two scenarios were 3 developed. 4 A. The first scenario may be considered the 5 “without” Black Mesa scenario and is Idaho Power’s 2021 IRP 6 preferred portfolio. The second portfolio may be considered 7 the “with” Black Mesa scenario and adjusts to include the 8 Black Mesa PPA. 9 For the “without” scenario, the incremental revenue 10 requirement for resource additions (solar, storage and 11 wind) is allocated to Micron and all other customers by 12 load-ratio share. In the “without” scenario net power 13 supply expense (“NPSE”) is allocated between Micron and all 14 other customers based on a proportional share of energy in 15 the 2021 IRP load forecast. The sum of all other customers’ 16 load ratio share of incremental resource revenue 17 requirement and share of NPSE becomes the floor in the 18 comparative analysis. 19 For the “with” scenario, 2021 IRP is adjusted to 20 include the Black Mesa PPA in 2023 as a must-take resource, 21 and an offsetting adjustment to 2023 storage additions is 22 made in recognition of the capacity value of the Black Mesa 23 solar resource. An AURORA power cost run is completed 24 including those resource changes in the “with” scenario. 25 ASCHENBRENNER, DI 28 Idaho Power Company The “with” scenario also applies a load-ratio share to 1 incremental resource revenue requirement, and an energy-2 ratio share to NPSE expense, with recognition that energy-3 ratio for Micron is slightly reduced from the energy 4 requirement met by the PPA. 5 Because there is no Excess Generation in any hour, 6 there is no impact from that pricing component. However, 7 the Renewable Capacity Credit is included in the “with” 8 scenario as a cost which is allocated to all customers 9 including Micron, based on energy-ratio share. This is 10 consistent with the proposed treatment of the Renewable 11 Capacity Credit to flow through the PCA. 12 Consistent with the “without” scenario, all other 13 customers’ load ratio share of incremental resource revenue 14 requirement and NPSE share, including Renewable Capacity 15 Credit, is summed and is the basis of the comparison back 16 to the “without” scenario floor. 17 Q. Why are only incremental resource costs 18 compared? 19 A. Revenue requirement assumptions related to the 20 Company’s existing generation fleet and known or other 21 expected future plant additions, such as the Boardman to 22 Hemingway transmission line addition and addition of Hells 23 Canyon relicensing costs being included in rate base, are 24 the same between the two scenarios, therefore would have no 25 ASCHENBRENNER, DI 29 Idaho Power Company impact on the result. 1 Q. Did Idaho Power consider the impact of imputed 2 debt as part of its evaluation of the Micron ESA? 3 A. Yes, because the Renewable Resource is in the 4 form of a PPA, Idaho Power calculated the potential imputed 5 debt impact for the PPA 20-year term. The Company’s 6 analysis concluded that the estimated cost of imputed debt 7 is less than the resulting 20-year net present value 8 (“NPV”) revenue requirement benefit from Micron supporting 9 its operations through participation in the CEYW - 10 Construction option. Thus, any ultimate imputed debt costs 11 would not be borne by other Idaho Power customers. This 12 result also provides evidence the Company’s proposed 13 Renewable Capacity Credit Adjustment of 1.0 is appropriate. 14 Q. Please describe the results. 15 A. In each scenario, the load-ratio share of 16 incremental resource revenue requirement, energy-ratio 17 share of NPSE, and in the “with” scenario the energy-ratio 18 share of Renewable Capacity Credit are combined to inform a 19 theoretical annual revenue requirement for all customers as 20 if the Company had a rate case each year. On a NPV basis 21 for a 20-year period, the revenue requirement is lower by 22 $2.5 million, including the estimated cost of imputed debt, 23 representing a benefit to all customers in the “with” 24 ASCHENBRENNER, DI 30 Idaho Power Company scenario where Micron participates in the CEYW – 1 Construction option. 2 Q. Will Idaho Power complete a no-harm analysis 3 when future Renewable Resource projects are contemplated? 4 A. Yes. Prior to entering into additional 5 Renewable Resource agreements to procure renewable energy 6 on behalf of Micron, Idaho Power will perform an analysis 7 to ensure the addition of the proposed project, when 8 considered under the proposed pricing structure, does not 9 result in any cost shift to Idaho Power’s other customers. 10 As more fully described above, the Company’s proposed 11 Renewable Capacity Credit Adjustment in Schedule 26 will 12 reflect any needed adjustment. 13 V. Conclusion 14 Q. Do you believe that approval of the Micron ESA 15 and the Black Mesa PPA is in the public interest? 16 A. Yes. Idaho Power and Micron have worked 17 together to establish a framework that will take a 18 meaningful step towards accomplishing Micron’s renewable 19 energy goals, while ensuring the related pricing 20 appropriately assigns the costs and benefits of procuring 21 the Renewable Resource to Micron. The structure presented 22 in this case is also consistent with the elements presented 23 in the CEYW – Construction option, as more fully 24 articulated in my testimony. 25 ASCHENBRENNER, DI 31 Idaho Power Company Finally, all costs associated with the Black Mesa 1 PPA will be passed onto Micron, which ensures other 2 customers are not harmed by the arrangement. 3 Q. Please summarize the Company’s request in this 4 case. 5 A. The Company respectfully requests the 6 Commission issue an order approving: 1) the replacement 7 Special Contract between Idaho Power and Micron; 2) the 20-8 year PPA between Idaho Power and Black Mesa, which was 9 negotiated with the expectation of assigning that energy to 10 Micron under the replacement Special Contract; 3) 11 modifications to Schedule 26 necessary to incorporate the 12 hourly reconciliation of Micron’s energy requirement and 13 the Renewable Resource(s); 4) the derivation of the 14 capacity credit associated with the Renewable Resource(s) 15 and compensation structure for excess renewable energy 16 generation; 5) authorization to treat bill credits provided 17 to Micron under the proposed compensation structure as 18 prudently incurred expenses for ratemaking purposes; and 6) 19 the Company’s proposed accounting treatment. 20 Q. Does this conclude your testimony? 21 A. Yes. 22 ASCHENBRENNER, DI 32 Idaho Power Company DECLARATION OF CONNIE G. ASCHENBRENNER 1 I, Connie G. Aschenbrenner, declare under penalty of 2 perjury under the laws of the state of Idaho: 3 1. My name is Connie G. Aschenbrenner. I am 4 employed by Idaho Power Company as the Senior Manager of 5 Rate Design in the Regulatory Affairs Department. 6 2. On behalf of Idaho Power, I present this 7 pre-filed direct testimony and exhibits in this matter. 8 3. To the best of my knowledge, my pre-filed 9 direct testimony is true and accurate. 10 I hereby declare that the above statement is true to 11 the best of my knowledge and belief and that I understand 12 it is made for use as evidence before the Idaho Public 13 Utilities Commission and is subject to penalty for perjury. 14 SIGNED this 10 day of Month 2022, at Boise, Idaho. 15 16 17 Connie G. Aschenbrenner 18 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-06 IDAHO POWER COMPANY ASCHENBRENNER TESTIMONY EXHIBIT NO. 1 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 1 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 2 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 3 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 4 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 5 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 6 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 7 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 8 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 9 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 10 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 11 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 12 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 13 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 14 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 15 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 16 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 17 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 18 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 19 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 20 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 21 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 22 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 23 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 24 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 25 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 26 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 27 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 28 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 29 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 30 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 31 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 32 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 33 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 34 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 35 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 36 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 37 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 38 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 39 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 40 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 41 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 42 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 43 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 44 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 45 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 46 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 47 of 48 Exhibit No. 1 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 48 of 48 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-06 IDAHO POWER COMPANY ASCHENBRENNER TESTIMONY CONFIDENTIAL EXHIBIT NO. 2 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-22-06 IDAHO POWER COMPANY ASCHENBRENNER TESTIMONY EXHIBIT NO. 3 MICRON NO-HARM ANALYSIS (a)(b)(c)(d)(e)(f)(g) [(d + i) x e](h) [(d + i) x f](i) [c + h] Year Revenue Requirement Share Buildout Revenue Requirement Share NPSE Ratio Share % All Other Customer Energy Ratio Share % Capacity Credit Share Share All Other Customer Total 2021 -$ -$ 392,927,166$ 3.52%96.48%13,814,888$ 2022 - - 402,420,743 3.81%96.19%15,313,568 2023 22,266,322 713,056 490,721,424 4.15%95.85%20,342,153 2024 125,596,918 5,088,110 389,570,463 4.65%95.35%18,103,513 2025 137,699,440 5,369,279 404,781,334 4.62%95.38%18,687,168 2026 133,607,304 5,058,238 412,315,342 4.50%95.50%18,573,220 2027 131,385,452 4,831,658 441,000,856 4.41%95.59%19,434,099 2028 133,299,653 4,764,524 450,082,128 4.34%95.66%19,519,942 2029 175,844,532 6,132,640 446,712,020 4.31%95.69%19,255,987 2030 177,472,406 6,134,547 462,130,735 4.28%95.72%19,788,242 2031 179,886,767 6,157,607 467,486,717 4.26%95.74%19,923,812 2032 181,302,237 6,143,994 483,832,917 4.23%95.77%20,489,487 2033 188,219,332 6,305,195 470,576,713 4.22%95.78%19,840,062 2034 260,837,904 8,784,835 479,706,688 4.18%95.82%20,071,221 2035 305,715,431 10,127,528 486,451,436 4.15%95.85%20,185,519 2036 307,653,327 10,079,125 484,911,165 4.11%95.89%19,941,297 2037 314,994,096 10,192,333 476,174,864 4.07%95.93%19,393,689 2038 329,296,102 10,558,284 477,374,891 4.03%95.97%19,238,836 2039 325,639,685 10,335,603 505,128,512 3.99%96.01%20,171,993 2040 315,916,413 9,936,297 536,521,594 3.95%96.05%21,201,995 20-Year Total 3,746,633,320$ 9,160,827,709$ 12,397,457,487$ 1,554,541,757$ 4,677,710,276$ 2021 IRP Preferred Portfolio ("Without" Scenario) Page 1 of 2 Exhibit No. 3 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 1 of 2 MICRON NO-HARM ANALYSIS (a)(b)(c)(d)(e)(f)(g) [(d + i) x e](h) [(d + i) x f](i)(j) [c + h] Year Revenue Requirement Share Buildout Revenue Requirement Share NPSE (Excludes PPA Cost)Ratio Share % All Other Customer Energy Ratio Share % Capacity Credit Share Share Capacity Credit All Other Customer Total (Benefit)/Cost 2021 -$ -$ 392,927,166$ 3.52%96.48%13,814,888$ 2022 - - 402,420,743 3.81%96.19%15,313,568 2023 20,322,091 650,794 488,878,335 3.73%96.27%18,257,211 2024 122,252,366 4,758,617 386,573,217 4.10%95.90%15,904,035 2025 134,368,097 5,055,980 402,777,212 4.08%95.92%16,493,834 2026 130,308,508 4,755,714 411,231,986 3.98%96.02%16,427,526 2027 128,195,885 4,540,646 440,532,567 3.89%96.11%17,208,426 2028 130,137,562 4,487,360 449,484,877 3.83%96.17%17,260,351 2029 172,685,864 5,843,720 444,477,578 3.80%96.20%16,976,309 2030 174,374,587 5,853,681 459,523,639 3.78%96.22%17,436,915 2031 176,849,508 5,886,790 464,122,558 3.76%96.24%17,527,916 2032 178,325,241 5,883,090 481,660,161 3.74%96.26%18,064,409 2033 185,302,295 6,055,080 468,120,222 3.72%96.28%17,479,101 2034 257,980,513 8,436,335 476,429,742 3.69%96.31%17,649,097 2035 302,917,367 9,772,333 484,061,923 3.66%96.34%17,788,128 2036 304,914,262 9,736,338 482,276,714 3.63%96.37%17,565,656 2037 312,313,694 9,859,989 472,372,348 3.59%96.41%17,042,605 2038 329,296,102 10,295,297 472,878,532 3.56%96.44%16,880,605 2039 325,639,685 10,081,427 499,752,198 3.52%96.48%17,665,609 2040 315,916,413 9,689,076 533,081,027 3.49%96.51%18,641,994 20-Year Total 3,702,100,039$ 9,113,582,744$ 12,383,685,638$ (13,771,848)$ 1,531,067,362$ 4,657,325,065$ Micron Clean Energy Your Way with Black Mesa PPA ("With" scenario) (Benefit)/Cost - Net Imputed Debt Impact Page 2 of 2 Exhibit No. 3 Case No. IPC-E-22-06 C. Aschenbrenner, IPC Page 2 of 2