HomeMy WebLinkAbout20230217DirectEHackettExhibits(Redacted).pdf
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY TO ACQUIRE
RESOURCES TO BE ONLINE BY 2024
AND FOR APPROVAL OF A POWER
PURCHASE AGREEMENT WITH FRANKLIN
SOLAR LLC.
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CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
ERIC HACKETT
RECEIVED
2023 February 17, 4:22PM
IDAHO PUBLIC
UTILITIES COMMISSION
HACKETT, DI 1
Idaho Power Company
Q. Please state your name and business address. 1
A. My name is Eric Hackett. My business address 2
is 1221 West Idaho Street, Boise, Idaho 83702. 3
Q. By whom are you employed and in what capacity? 4
A. I am employed by Idaho Power Company (“Idaho 5
Power” or “Company”) as the Projects and Design Senior 6
Manager. 7
Q. Please describe your educational background. 8
A. I graduated in 2003 from Boise State 9
University, Boise, Idaho, receiving a Bachelor of Science 10
Degree in Civil Engineering. I am a registered 11
professional engineer in the state of Idaho. In 2010, I 12
earned a Master of Business Administration from Boise State 13
University. 14
Q. Please describe your work experience with 15
Idaho Power. 16
A. From 2005 to 2007, I was employed as an 17
engineer in Idaho Power’s Transmission Engineering 18
group. In 2007, I became a Project Manager leading 19
transmission and distribution line and station 20
infrastructure projects. In 2012 I was promoted to 21
Engineering Leader where I managed the Cost and Controls 22
group supporting project management. In 2015, I changed 23
leadership roles and managed the Stations Engineering and 24
Design group as an Engineering Leader. In 2018, I was 25
HACKETT, DI 2
Idaho Power Company
promoted to Senior Manager of Projects overseeing Project 1
Management and Cost and Controls, which later became my 2
current role of Senior Manager of Projects and Design in 3
2021, adding Power Production Design and Project 4
Management. In addition, I am currently leading a team of 5
internal employees and consultants in development and 6
evaluation of Idaho Power’s Request for Proposals for Peak 7
Capacity and Energy Resources. 8
Q. What is the purpose of your testimony in this 9
proceeding? 10
A. The purpose of my testimony is to provide an 11
overview of the competitive resource acquisition process 12
undertaken to meet Idaho Power’s identified capacity 13
deficiency in 2024. First, I will provide an overview of 14
the Request for Proposals (“RFP”) process used to evaluate 15
the various resources that competed to provide a capacity 16
resource to help meet Idaho Power’s peak electric energy 17
needs in 2024. I will then explain how the resulting 18
least-cost, least-risk capacity resources were selected 19
through the fair and competitive RFP process. 20
Q. Have you prepared any exhibits? 21
A. Yes. Exhibit No. 1 is Idaho Power’s 2022 All 22
Source Request for Proposals (RFP) for Peak Capacity and 23
Energy Resources issued on December 30, 2021 (“2022 RFP”). 24
Exhibit No. 2 includes the Proposal Entry Form that details 25
HACKETT, DI 3
Idaho Power Company
the information requested of respondents and necessary for 1
Idaho Power’s qualitative and quantitative evaluation. 2
Exhibit No. 3 details the Key Product Specifications 3
required for project proposals submitted in response to the 4
RFP. Confidential Exhibit No. 4 presents the results of 5
the project submittals evaluation. Confidential Exhibit 6
Nos. 5 and 6 are the agreements that support the 2024 7
resource acquisitions. 8
I. THE DEVELOPMENT OF THE RFP 9
Q. Why did Idaho Power initiate a competitive 10
request for proposals or RFP process to acquire the 2024 11
peak capacity and energy resources? 12
A. As explained in the direct testimony of 13
Company witness Mr. Jared Ellsworth, in the spring of 2021, 14
the Company first identified a capacity deficit beginning 15
in 2023 following modifications to the load and resource 16
balance being prepared as part of the Valmy Unit 2 exit 17
analysis, as directed by Commission Order No. 34349. The 18
capacity deficiencies subsequently increased during 19
development of the 2021 IRP to 101 MW in 2023, 186 MW in 20
2024, and 311 MW in 2025. In order to meet its obligation 21
to reliably serve customer load in a least-cost, least-risk 22
manner, a competitive solicitation for the acquisition of 23
resources was conducted through an RFP. 24
The competitive RFP process allows the Company to 25
HACKETT, DI 4
Idaho Power Company
access the broader peak capacity and energy market to 1
obtain the best resources for Idaho Power’s customers, 2
allowing for access to a spectrum of potential resources 3
and developers. Use of a formal RFP process provides 4
customers and regulatory agencies with the assurance that 5
the resource selection process was competitive, all 6
potential developers had an equal opportunity to 7
participate, and that the best resource alternative was 8
selected. 9
Q. Did Idaho Power engage a third-party to assist 10
the Company with the RFP and bid evaluation process? 11
A. Yes. On May 12, 2021, Idaho Power executed a 12
contract with Black & Veatch Management Consulting, LLC 13
(“Black & Veatch”), to receive full-service comprehensive 14
owner’s engineering and oversite services to coordinate 15
resource procurement efforts pertaining to the RFP as well 16
as the preparation and issuance of the RFP. In addition, 17
the Company leveraged Black & Veatch’s experience in 18
designing and administering the RFP evaluation processes to 19
assist Idaho Power. 20
Q. Was this the same third-party that assisted 21
with the RFP process to acquire the 2023 peak capacity 22
resources subject to the Company’s request in Case No. IPC-23
E-22-13? 24
A. Yes. The contract executed in May 2021 25
HACKETT, DI 5
Idaho Power Company
included the utilization of Black & Veatch’s consulting 1
expertise in developing the RFP requirements and requests, 2
its exhibits and the issuance of both the 2021 All Source 3
Request for Proposals (“RFP”) for Peak Capacity and Energy 4
Resources issued on June 30, 2021 (“2021 RFP”), and the 5
2022 RFP. Black & Veatch provided scheduling, editing, 6
process development, and the tools to conduct evaluations. 7
Black & Veatch further assisted Idaho Power in the 8
consolidation and integration of final evaluations prepared 9
by Idaho Power subject matter experts, and overall 10
weighting of individual factors and key categories that 11
influence both quantitative and qualitative evaluation. 12
Finally, Black & Veatch administered the bid 13
evaluation process, including proposal data processing, 14
evaluation training, rating collection, score compilation, 15
proposal ranking, and other necessary summary and reporting 16
tasks. As part of this work, Black & Veatch supported 17
responding to bidders’ questions regarding the RFP content 18
and Idaho Power evaluators’ questions regarding evaluation 19
processes, factors and criteria. 20
Q. What was the extent of Idaho Power personnel’s 21
involvement in the development of the RFP and the bid 22
evaluation process? 23
A. Upon recognizing the urgency of the Company’s 24
capacity deficits in the years 2023, 2024, and 2025, Idaho 25
HACKETT, DI 6
Idaho Power Company
Power assembled an interdisciplinary team to develop and 1
process the RFPs (“RFP evaluation team”). Black & Veatch 2
was engaged to assist the RFP evaluation team, providing 3
guidance and support of the RFP process. The RFP evaluation 4
team, in consultation with Black & Veatch, developed 5
detailed criteria and a methodology for evaluating both 6
price and qualitative attributes of a proposed resource 7
including the 57 factors which were identified in Exhibits 8
A and B to the RFP, and required submittal by respondents 9
through completion of the Proposal Entry Form. The Proposal 10
Entry Form, included as Exhibit No. 2, is Excel based and 11
identified the applicable inputs under the differing 12
product types once selected from the Resource Type drop 13
down menu. Subject matter experts within the RFP evaluation 14
team, as well as independent subject matter experts within 15
Idaho Power, were assigned those specific evaluation 16
factors and criteria related to their knowledge of the 17
factor subject matter. 18
Q. How was the detailed criteria and a 19
methodology for evaluating both price and qualitative 20
criteria determined? 21
A. The RFP evaluation team utilized knowledge 22
gained during evaluation of the 2021 RFP responses, with 23
continued reliance on Black & Veatch’s consultation and 24
experience, and expanded upon those factors necessary for a 25
HACKETT, DI 7
Idaho Power Company
robust evaluation of the projects submitted. The team 1
identified the breadth and depth of the evaluations needed 2
to support decision-making for large power supply 3
commitments. Quantitative analysis was performed through 4
production cost simulation and other costing tools to 5
forecast the capital and operating cost impacts of the 6
proposal over a future term. The evaluation of qualitative 7
aspects included rating by subject matter experts the 8
detailed qualitative factors that comprise the general 9
categories of Project Feasibility, Project Capability, 10
Counterparty Profile, and Community Stewardship. 11
Q. Did the Company notify the public of the 12
intent to issue a formal RFP? 13
A. Yes. On December 10, 2021, Idaho Power 14
released a public Notice of Intent to industry developers 15
and media outlets noticing the Company’s intent to release 16
the RFP, which was also posted on Idaho Power’s website. 17
The Notice of Intent was also directly emailed to 18
approximately 70 developers, comprised of developers 19
currently in the Company’s Generation Interconnection Queue 20
as well as developers with whom Idaho Power had 21
communicated during the 2021 RFP process. 22
Q. When were developer responses due? 23
A. Interested developers responded with an Intent 24
to Bid by December 23, 2021. During the RFP solicitation, 25
HACKETT, DI 8
Idaho Power Company
Idaho Power received three questions from developers and 1
responded accordingly. Ultimately, 41 developers responded 2
to the Notice of Intent identifying approximately 52 3
separate potential proposals and requesting to receive the 4
RFP directly when released. 5
II. THE REQUEST FOR PROPOSALS 6
Q. Please describe the issuance of the RFP. 7
A. On December 30, 2021, the RFP evaluation team 8
issued a formal request for competitive proposals for the 9
acquisition of electric energy and capacity delivered from 10
electric resources that employ certain qualifying 11
technologies under varying ownership arrangements to help 12
meet the 2024 capacity needs and required commercial 13
operation by June 2024. The RFP, included as Exhibit No. 1 14
to my testimony, set forth the process and procedure 15
utilized to solicit and evaluate the proposals. 16
The RFP solicitation identified the purpose, key 17
product specifications, electric interconnection 18
requirements, proposal format, qualitative and quantitative 19
evaluation criteria, technical specifications, and 20
additional requirements necessary to submit a qualifying 21
proposal. The submittal requirements provided the key 22
information to assess both price and non-price attributes. 23
Most importantly, the RFP solicitation focused on the 24
importance of having a project in-service by June 2024. 25
HACKETT, DI 9
Idaho Power Company
The RFP was sent directly to the 41 developers, through the 1
Zycus portal, who responded to the Notice of Intent. 2
Q. Please describe the products solicited 3
through the RFP. 4
A. The products solicited through the RFP were 5
renewables, such as solar photovoltaic (“PV”), wind or 6
geothermal, energy storage projects, and renewables plus 7
energy storage projects. In addition, the Company 8
identified gas-fired resources that are convertible to 9
hydrogen and demand response resources as eligible 10
products. Idaho Power also accepted other products if they 11
met the functionality criteria outlined in the RFP. 12
Exhibit No. 3 to my testimony includes the key product 13
specifications for each of the eligible products, including 14
the ownership structure, term, first delivery date, 15
resource status, design life, capacity requirement, 16
interconnection options, delivery point, storage duration 17
and cycles, and pricing, as outlined in the RFP. 18
Q. Were any revisions made to the products for 19
which Idaho Power solicited in the 2022 RFP? 20
A. No. However, on April 13, 2022, the Company 21
notified all prospective respondents of an addendum to the 22
product table which was revised to clarify that respondents 23
had the opportunity to submit proposals for a respondent-24
HACKETT, DI 10
Idaho Power Company
owned battery energy storage resource type with a 1
subsequent Battery Storage Agreement product type 2
(“Addendum No. 7”). This was in addition to the battery 3
energy storage resource type with a subsequent Build 4
Transfer Agreement product type with Idaho Power ownership 5
as initially identified in the product table. Column 10.a 6
of Table 3 – Storage Products in the Key Product 7
Specification Tables included as Exhibit No. 3 reflects the 8
clarification. 9
Q. The Company’s 2024 capacity deficiency was 10
again identified as first occurring in summer, similar to 11
the 2023 capacity deficiency. Did Idaho Power’s RFP 12
consider the timing of the resource availability when 13
recommending accepted products? 14
A. Yes. The Company indicated in the RFP that 15
respondents were encouraged to configure resources to 16
maximize energy delivered during hours that are most 17
valuable to Idaho Power. Exhibit D to the 2022 RFP 18
provided as Exhibit No. 1 included information related to 19
the most valuable hours. In addition, respondents were 20
advised to review the Effective Load Carrying Capability 21
(“ELCC”) factors that the Company had forecasted consistent 22
with the 2021 Integrated Resource Plan (“IRP”) for various 23
resource types as identified in Exhibit N to the 2022 RFP, 24
HACKETT, DI 11
Idaho Power Company
as the data was to be used to discount the capacity 1
proposed by respondents during the quantitative evaluation 2
process. 3
Q. Were potential respondents informed of the 4
evaluation process used by the Company? 5
A. Yes. Section 7 of the 2022 RFP discussed 6
the evaluation process Idaho Power used to rank proposals 7
received. In addition, as I discussed earlier, the 8
Proposal Entry Form, included as Exhibit No. 2 to my 9
testimony, detailed the information required for submittal 10
to enable Idaho Power’s qualitative and quantitative 11
evaluation of the projects. 12
Q. Did the Company perform any additional 13
outreach to potential respondents regarding the RFP? 14
A. Yes. Idaho Power prepared a pre-bid 15
presentation and, on January 20, 2022, made the recording 16
available to all prospective respondents via the Zycus 17
portal. The presentation detailed product requirements, 18
interconnection, an evaluation process flowchart, bid fees, 19
and a portal overview for respondents. 20
Q. In Case No. IPC-E-22-13, In the Matter of 21
Idaho Power Company’s Application for a CPCN to Acquire 22
Resources to be Online by 2023 to Secure Adequate and 23
Reliable Service to its Customers, the Commission issued 24
HACKETT, DI 12
Idaho Power Company
Order No. 35643 detailing its concerns regarding the 1
robustness of the 2023 resource RFP process. Do you believe 2
that the RFP process applied to acquire the resources at 3
issue in this case adequately addresses the Commission’s 4
concerns? 5
A. Yes. In Order NO. 35643, the Commission 6
expressed concern that the RFP process applied to acquire 7
resources for 2023 was overly restrictive.1 The RFP process 8
presented in this case did not restrict bids based on 9
resource type or ownership structure. That is, the RFP 10
allowed bids for all commercially viable resource types as 11
well as third-party ownership of those resources. 12
III. EVALUATION OF THE RESPONDENT PROPOSALS 13
Q. When were responses to the RFP due? 14
A. Original respondent proposals were due to 15
Idaho Power via the Zycus portal on March 10, 2022, and 16
April 19, 2022, following Addendum No. 7. 17
Q. How many proposals were received for 18
consideration as a 2024 resource addition? 19
A. Idaho Power received 24 proposals from 12 20
different developers spanning a variety of product types, 21
including two benchmark resources from the Company’s Power 22
Supply department. The 24 proposals were made up of 18 23
1 Case No. IPC-E-22-13, Order No. 35643, pgs. 12-13.
HACKETT, DI 13
Idaho Power Company
different projects as some of the proposals were merely 1
contract and pricing structure variations of the same 2
resource type. 3
Q. Were the Idaho Power personnel that submitted 4
the two benchmark resources part of the RFP evaluation 5
team? 6
A. No. Idaho Power maintains a Separation of 7
Functions Protocol (“Protocols”) for resource procurement 8
efforts that requires independent functioning of the RFP 9
evaluation team members and the Power Supply personnel who 10
submit benchmark resource proposals (“Internal Team”). The 11
Protocols detail the separation of duties including the 12
prohibition of sharing non-public information related to 13
the competitive bidding procedures for the procurement of 14
generation resources between the RFP evaluation team and 15
the Internal Team. 16
Q. Did all 24 proposals meet the criteria of the 17
RFP? 18
A. No. The evaluation process begins with a 19
threshold screen to identify and remove proposals that are 20
incomplete or do not comply with the basic requirements of 21
the solicitation. One of the proposals was a material only 22
proposal and was screened during the threshold screen as 23
not meeting the solicitation criteria. The remaining 17 24
projects (23 proposals) were moved forward in the 25
HACKETT, DI 14
Idaho Power Company
evaluation process for qualitative and quantitative 1
evaluation and ranking. 2
Initial Screen 3
Q. Please provide an overview of the qualitative 4
and quantitative evaluation and ranking process. 5
A. Confidential Exhibit No. 4 presents the 6
evaluation process of the project submittals that remained 7
following the threshold screen. Each project is identified 8
as Project No. 1 through 17 in Table 1 of the exhibit. Once 9
the threshold screen was completed, the qualitative and 10
quantitative evaluations, which I will explain in more 11
detail, were performed iteratively. The qualitative 12
evaluation ranked the proposals based on project 13
feasibility, project capability, counterparty profile, and 14
community stewardship, with each category weighted to 15
ensure the evaluation process is conducted without bias and 16
yields results that are aligned to Idaho Power’s resource 17
needs. The quantitative evaluation ranked the proposals by 18
cost. 19
Q. When did evaluation of the proposals begin? 20
A. Idaho Power began qualitative evaluation of 21
the 17 proposals that made up the initial short list in 22
March 2022 using the objective scoring methodology to 23
reasonably evaluate the attributes of each bid. The 24
qualitative evaluation used the 57 unique factors mentioned 25
HACKETT, DI 15
Idaho Power Company
earlier in my testimony for scoring, for which the rating 1
criteria of each factor was determined before proposals 2
were received and not changed thereafter. The Idaho Power 3
subject matter expert performing the qualitative evaluation 4
of all shortlist proposals performed their respective 5
evaluation independent of price inputs. 6
Q. What is meant by reasonably evaluate? 7
A. With respect to qualitative evaluation, 8
reasonably evaluate refers to the method of allowing 9
qualitative evaluators to independently utilize their 10
subject matter expertise while being constrained to follow 11
the rating criteria guidance and be subject to calibration. 12
The result is a reasonable balance between individual 13
expertise and group consensus yielding reasonable 14
evaluation results. 15
Q. Why would the subject matter experts perform 16
the qualitative evaluation independent of the quantitative 17
evaluation? 18
A. The independent qualitative evaluation of all 19
initial shortlist proposals by subject matter experts 20
ensures avoidance of a situation in which the qualitative 21
evaluator becomes biased for or against a particular 22
proposal due to its evaluated cost. Instead, the 23
quantitative production cost model analysis was performed 24
after the qualitative evaluation. 25
HACKETT, DI 16
Idaho Power Company
Q. Once the qualitative evaluations were 1
completed by the subject matter experts, was this scoring 2
used to exclusively select the winning proposals? 3
A. No. Upon completion of the qualitative 4
evaluation of the initial short list, the scores were 5
reviewed to ensure consistent application of scores and 6
rating criteria. At this point in the evaluation, 7
considering inflationary pressures on material and labor 8
costs as well as continued supply chain issues, developers 9
were provided the opportunity to submit revised pricing and 10
any additional information they desired to clarify or 11
support their proposal. This information was used to re-12
score and calibrate the proposal rankings. A review of the 13
relative pricing of the various proposals was also 14
performed at this time resulting in the final short list of 15
proposals. The Company believes this internal evaluation 16
with prescribed criteria serves the objective of 17
identifying proposals that fit the needs specified in the 18
RFP. Idaho Power notified those projects that did not 19
progress to the final short list in June/July 2022. 20
Final Short List 21
Q. What were the results of the final short list? 22
A. Five project proposals made the final short 23
list, Project Nos. 2, 7, 8, 9 and 10 listed in Table 3 of 24
Confidential Exhibit No. 4. 25
HACKETT, DI 17
Idaho Power Company
Q. Please describe the elimination of the 12 1
projects from the initial short list. 2
A. The qualitative evaluation allows for the 3
relative ranking of the initial short list projects to 4
better identify those projects that best meet the Company’s 5
resource needs. To further refine those projects that would 6
move to the final short list, the RFP evaluation team 7
performed a quantitative evaluation comparing the relative 8
price components through indicative AURORA scenarios, which 9
allowed for the use of a consistent common evaluation tool 10
with consistent common assumptions in that tool, for 11
reasonable evaluation results. Using the most recent load 12
forecast at the time, the RFP evaluation team used AURORA’s 13
long-term capacity expansion (“LTCE”) modeling capability 14
to develop the least-cost, least-risk portfolio for meeting 15
the 2024 capacity deficiency. Under the LTCE modeling 16
approach, the levelized cost of capacity (“LCOC”) of all 17 17
projects are input into AURORA as potential resource 18
additions, along with their project specific operating 19
characteristics. The LTCE model optimizes these potential 20
resource selections based on the performance of each 21
resource within Idaho Power’s zone, optimizing for the cost 22
function while meeting the Company’s identified capacity 23
deficiency. 24
Q. How is the LCOC determined? 25
HACKETT, DI 18
Idaho Power Company
A. The LCOC is the conversion of all fixed costs 1
associated with the separate technologies of each project, 2
including capital costs, depreciation expense, tax expense, 3
financing costs including both the return on Company-owned 4
assets or the imputed debt cost associated with a PPA, 5
operations and maintenance expenses, and property taxes and 6
insurance, to an equivalent, comparable value. Because the 7
resources have varying economic lives, the annual 8
depreciation of capital costs is based on apportioning the 9
capital costs over the entire economic life. The costs are 10
expressed in terms of kW of nameplate capacity. 11
Q. Please explain imputed debt costs associated 12
with a PPA. 13
A. Idaho Power competes with other companies in 14
the capital markets, to obtain debt and equity financing 15
necessary to operate its business and fund capital 16
projects. In seeking to access capital, one of the major 17
factors banks, investors, investment analysts, and lenders 18
consider is the Company’s overall financial profile, 19
including the strength of its balance sheet. Credit rating 20
agencies assess the financial strength of Idaho Power and 21
provide ratings that act as a barometer to balance sheet 22
strength among other things. While agencies may look at 23
imputed debt differently, they evaluate future contractual 24
obligations related to long-term PPAs as they consider 25
HACKETT, DI 19
Idaho Power Company
future debt obligations of issuers during their ongoing 1
monitoring of credit quality. 2
That imputation is understandable as the third-party 3
supplier is ultimately leveraging Idaho Power’s balance 4
sheet to develop its project, by using the PPA and 5
underlying long-term debt-like obligation and payment 6
stream from the Company as collateral, while at the same 7
time diminishing Idaho Power’s credit profile and financial 8
strength. Credit rating agencies account for this 9
transferred risk as a fixed debt obligation of the utility 10
and impute this risk to the utility's balance sheet, costs 11
that are ultimately borne by customers through higher costs 12
of capital. When determining the LCOC of PPAs, Idaho Power 13
adds the imputed debt as a financing cost associated with 14
the project. 15
Q. What were the results of the quantitative 16
evaluation of the final short list projects performed 17
through indicative AURORA scenarios? 18
A. The indicative AURORA modeling scenarios 19
consistently selected Project Nos. 7 and 8 as the resource 20
additions resulting in a least-cost, least-risk portfolio 21
for meeting the identified 2024 capacity deficiency. To 22
ensure a more robust final short list for negotiating best 23
and final offers and to begin contract negotiations, Idaho 24
Power selected the three next most cost-effective projects 25
HACKETT, DI 20
Idaho Power Company
to move forward to the final short list as well, Project 1
Nos. 2, 9 and 10. 2
Q. Was the comparison of the relative price 3
components the only screen performed on the initial short 4
list projects? 5
A. No. In addition to price, it was determined 6
that Project Nos. 4, 5, 6, and 11 had no available 7
transmission capacity which also prevented the projects 8
from moving to the final short list. Similarly, further 9
investigation into Project No. 1 revealed deliverability 10
concerns for meeting the June 2024 commercial operation 11
date and therefore did not move to the final short list. 12
Finally, though still feasible projects, it is worth noting 13
that based on the technologies proposed, Project Nos. 12, 14
13, 14, and 15, were not cost-effective options because of 15
the limited capacity benefit of the energy storage or 16
surplus only availability of the energy storage. 17
Q. What was the next step of the evaluation 18
process once the final short list was established? 19
A. Following establishment of the final short 20
list, the RFP evaluation team provided another opportunity 21
for developers to update and clarify their pricing 22
information, particularly considering the Inflation 23
Reduction Act of 2022 (“2022 IRA”), signed into law on 24
August 16, 2022, which had the potential to lower proposal 25
HACKETT, DI 21
Idaho Power Company
pricing and the resulting LCOC. 1
Q. Why did the Company believe the 2022 IRA would 2
impact the pricing of the proposals? 3
A. The 2022 IRA provides for, among other things, 4
numerous renewable energy tax credits, for example 5
extension of the current investment tax credits (“ITC”) and 6
production tax credits (“PTC”), a new ITC for standalone 7
energy storage, application of the PTC to solar, transition 8
to a technology-neutral ITC and PTC after 2024, and creates 9
a transferability option that allows credits to be sold to 10
an unrelated taxpayer. The 2022 IRA modifies the 11
calculation of most of the energy tax credits by 12
introducing the concept of a “base credit” (e.g., 6 percent 13
ITC) and a “bonus credit” (e.g., an additional 24 percent 14
ITC) if certain wage and apprenticeship requirements are 15
met in the construction and ongoing maintenance of the 16
renewable energy facilities. 17
Q. Did all five shortlist projects listed in 18
Table 3 of Confidential Exhibit No. 4 provide updated 19
pricing with the impacts of the 2022 IRA impact? 20
A. Yes, with the exception of one project, 21
Project No. 7. Prior to providing updated pricing, the 22
developer of Project No. 7 notified the RFP evaluation team 23
that they were withdrawing the project from evaluation as a 24
2024 resource due to site control concerns. It is also 25
HACKETT, DI 22
Idaho Power Company
worth noting that while the net change in the LCOC of the 1
final shortlist projects was a reduction in costs, 2
developers indicated that continued supply chain issues and 3
inflationary pressures on material and labor costs offset a 4
portion of the benefits associated with the 2022 IRA. 5
Q. Did the RFP evaluation team refresh the 6
quantitative evaluation with the revised LCOC for the four 7
remaining final short list projects? 8
A. Yes. Using the updated LCOC inputs in AURORA, 9
the LTCE analysis was performed again for Project Nos. 2, 10
8, 9, and 10. Similar to the initial LTCE analysis, Project 11
No. 8 was consistently selected as the most cost-effective 12
resource for meeting the 2024 capacity deficiency. 13
Q. Did the addition of the cost of imputed debt 14
in the LCOC calculation impact the ranking of the relative 15
price components of the projects? 16
A. No. The inclusion of imputed debt did not 17
change the selection of Project No. 8 as the most cost-18
effective resource. 19
IV. PROJECT NECESSARY TO FILL 2024 CAPACITY DEFIENCY 20
Q. Please describe Project No. 8. 21
A. Project No. 8 envisioned a 25-year PPA 22
associated with a 100 MW solar PV facility that supplies 23
energy to an Idaho Power-owned energy storage facility, 20 24
MW of battery storage. 25
HACKETT, DI 23
Idaho Power Company
Q. Will the 100 MW solar PV plus 20 MW energy 1
storage project be sufficient to meet Idaho Power’s 2
capacity need in 2024? 3
A. No. While the standalone 100 MW solar PV plus 4
20 MW energy storage project was consistently selected as 5
the most cost-effective resource for meeting the 2024 6
capacity deficiency as part of the initial LTCE analysis 7
and again for the LTCE analysis performed with the final 8
short list projects, between the time when the refreshed 9
LTCE analysis was performed and when contract negotiations 10
were to begin, the 2024 capacity need had increased. As 11
detailed in the direct testimony of Mr. Ellsworth, the 12
Company’s load and resource balance remains very fluid 13
during the near-term resource decision-making phase, driven 14
in part by continued high load growth. To account for the 15
increased 2024 capacity deficiency, when Idaho Power 16
commenced contract negotiations for Project No. 8, the 17
Company inquired about the feasibility of an increase to 18
the proposed 20 MW energy storage system. The developer 19
confirmed the battery storage pricing per kW could be 20
maintained, and an increased system installed, for up to 60 21
MW of storage. Project No. 8 became a 100 MW solar PV plus 22
60 MW energy storage project. 23
Q. Did the increase in the battery storage 24
capacity change the economics of the project? 25
HACKETT, DI 24
Idaho Power Company
A. No. Because the pricing of the battery storage 1
on a per kW basis remained nearly the same, the increased 2
capacity would not materially change the LCOC or the 3
resulting LTCE analysis. 4
Q. Why is it that the other final short list 5
projects have a lower energy storage cost but are not 6
selected as a more cost-effective resource addition? 7
A. Although the costs associated with the battery 8
storage component of Project No. 8 are higher than other 9
projects on the final short list, the PPA costs are 10
significantly lower. As a potential resource addition, the 11
solar PV is paired with the battery storage in AURORA. The 12
continued selection by AURORA of the combined solar PV and 13
battery storage in the LTCE analysis indicates the low 14
solar PPA price of Project No. 8 is contributing to the 15
value the project provides as compared to the other final 16
short list projects. In addition to being a lower cost 17
resource, when compared to standalone battery storage 18
systems, the combined solar PV plus energy storage of 19
Project No. 8 better meets the Company’s capacity needs, 20
resulting in a higher ELCC than would exist as a standalone 21
energy storage system. 22
Power Purchase Agreement 23
Q. You indicated Project No. 8 consists of a 25-24
year PPA associated with a 100 MW solar PV facility 25
HACKETT, DI 25
Idaho Power Company
combined with a 60 MW energy storage facility. Has the 1
Company executed the PPA? 2
A. Yes. On January 20, 2023, Idaho Power and 3
Franklin Solar LLC (“Franklin Solar”) executed a 25-year 4
PPA. Under the terms of the PPA, Franklin Solar will 5
construct, own, operate and maintain a 100 MW solar PV 6
facility located in Twin Falls County, Idaho, supplying the 7
output to Idaho Power’s system. An executed copy of the PPA 8
is included as Confidential Exhibit No. 5 to my testimony. 9
Q. Confidential Exhibit No. 4 identifies Project 10
No. 8 as Duke Energy Renewables, LLC, an indirect wholly-11
owned subsidiary of Duke Energy Corporation (“Duke Energy 12
Renewables”). What is the relationship between Duke Energy 13
Renewables and Franklin Solar? 14
A. Duke Energy Renewables is the indirect parent 15
entity of Franklin Solar. The direct parent entity of 16
Franklin Solar is Duke Energy Renewables Solar, LLC (“Duke 17
Energy Solar”). 18
Q. Please provide an overview of the PPA between 19
Idaho Power and Franklin Solar. 20
A. The PPA contains non-levelized, fixed pricing 21
that escalates at 2.0 percent annually during the term. 22
Exhibit 5 to the PPA sets forth the Contract Price for 23
Contract Years 1 through 25 on a dollars per megawatt-hour 24
("MWh") basis. The PPA is similar in many ways to the 25
HACKETT, DI 26
Idaho Power Company
numerous energy sales agreements approved by the Commission 1
pursuant to the Company's obligations under PURPA, but also 2
contains additional other terms and conditions consistent 3
with industry standard, non-PURPA power purchase agreements 4
including pricing, security, and other terms of service. 5
Q. Does the PPA provide for any assurances or 6
guarantees related to the commercial operation date of June 7
1, 2024, and ongoing operation of the solar facility? 8
A. Yes. Under Section 1.59, the PPA provides for 9
a Guaranteed Commercial Operation Date, which is 180 days 10
after the Scheduled Commercial Operation Date of June 1, 11
2024. Section 9 of the PPA contains provisions requiring 12
the Seller to post and maintain security, both Project 13
Development Security and Default Security. A Project 14
Development Security in the amount of $90 per kW of 15
Nameplate Capacity Rating must be in place within 30 days 16
of a final order of the Commission approving the PPA and 17
will remain in place to ensure the project meets its 18
Commercial Operation Date. For the first 10 contract years, 19
a Default Security in the amount of $45 per kW of Nameplate 20
Capacity Rating must be in place at the Commercial 21
Operation Date, after which the required Default Security 22
reduces to $35 per kW of Nameplate Capacity Rating and will 23
be maintained through the entire term of the PPA. Default 24
Security may be used for any Deficit Damages if the project 25
HACKETT, DI 27
Idaho Power Company
is brought online at less than the Expected Nameplate 1
Capacity or for any other damages Idaho Power suffers if 2
the PPA is terminated because of the Seller's default. 3
Q. Does the PPA contain any performance 4
guarantees? 5
A. Yes. Section 7.12 of the PPA contains a 6
performance requirement in the form of an Output Guarantee. 7
Under the Output Guarantee, the Seller is obligated to 8
deliver 90 percent of the Estimated Monthly Output of the 9
Facility on a monthly basis. The PPA allows the Seller an 10
adjustment of Estimated Monthly Net Output Amounts by the 11
25th day of the preceding month. If the project delivers 12
less than the Output Guarantee during any month, the Seller 13
must pay the Output Shortfall for that month multiplied by 14
Idaho Power's Cost to Cover as liquidated damages. If the 15
delivered Net Output is equal to or greater than the Output 16
Guarantee, then the Seller is deemed to have satisfied the 17
Output Guarantee. 18
In addition, Section 7 of the Agreement contains 19
standard provisions for operation and control of the 20
project. These include such things as planned outages, 21
forced outages, and maintenance outages, as well as 22
scheduling, forecasting, generator output limit control 23
(“GOLC”), and metering. For forecasting, the PPA provides 24
the same allocated portion of the total cost of Idaho 25
HACKETT, DI 28
Idaho Power Company
Power's Solar Energy Production Forecast model that is used 1
for all solar projects that are under contract to provide 2
energy to Idaho Power. 3
Q. Will Idaho Power take ownership of any Green 4
Tags or Environmental Attributes associated with the 5
Facility? 6
A. Yes. Under the PPA, Idaho Power will own 100 7
percent of the Green Tags and Environmental Attributes 8
associated with the facility. 9
Q. When will the PPA become effective? 10
A. Section 3.1.1 provides that the PPA will not 11
become effective unless the Commission has approved all of 12
the PPA's terms and provisions and declared that all 13
payments the Company makes to Seller for purchases of 14
energy will be allowed as prudently incurred expenses for 15
ratemaking purposes. The obligation of Idaho Power to 16
purchase energy under the PPA will not become effective 17
should it be disapproved by either the Commission or the 18
Public Utility Commission of Oregon. This section also 19
provides that subsequent to execution of the PPA, Idaho 20
Power will seek a final order regarding approval or 21
rejection of the Agreement from the Commission by February 22
17, 2023, and that if Commission approval is not obtained 23
by August 17, 2023, the Scheduled Commercial Operation Date 24
of June 1, 2024, and Guaranteed Commercial Operation Date, 25
HACKETT, DI 29
Idaho Power Company
which 180 days after, may be extended on a day-for-day 1
basis until approval is obtained. Should Commission 2
approval not be obtained by February 17, 2024, then the 3
Seller has the right to terminate the Agreement. 4
Energy Storage 5
Q. Has Idaho Power executed an agreement for the 6
60 MW energy storage component of the project? 7
A. Yes. Concurrent with execution of the PPA, on 8
January 20, 2023, the Company executed a Build Transfer 9
Agreement with Duke Energy Solar, for the purchase of a 10
Battery Energy Storage System (“BESS”), co-located with the 11
Franklin Solar 100 MW solar PV facility in Twin Falls 12
County, Idaho, providing for a minimum capacity of 60 MW. 13
As described below, the Build Transfer Agreement (“BTA”) is 14
structured as a sale by Duke Energy Solar to the Company at 15
mechanical completion of the equity interests in Franklin 16
Battery Storage, LLC (“Franklin Storage”). Franklin 17
Storage is developing and will construct the BESS. The BTA 18
is included as Confidential Exhibit No. 6. 19
Q. Please explain the Build Transfer Agreement 20
(“BTA”). 21
A. The BTA provides for the transfer to Idaho 22
Power from Duke Energy Solar of 100 percent of the equity 23
interests in Franklin Storage once mechanical completion is 24
reached. It requires that the project must achieve 25
HACKETT, DI 30
Idaho Power Company
mechanical completion, that is, the project has been 1
installed in accordance with the contract documents, is 2
mechanically, structurally and electrically sound, and is 3
ready for initial start-up, adjustment and testing, by the 4
Guaranteed Mechanical Completion Date of April 7, 2024 5
(subject to extension under certain circumstances). The 6
Guaranteed Substantial Completion date is June 1, 2024 7
(subject to extension under certain circumstances), and 8
requires the project to be commercially operational. 9
Failure to meet the Guaranteed Mechanical Completion Date 10
entitles Idaho Power to liquidated damages which are 11
subject to reimbursement if the Guaranteed Substantial 12
Completion Date is met. 13
Q. Are there any additional fundamental 14
provisions to note? 15
A. Yes. In addition to the purchase and sale and 16
specific BESS provisions, the BTA provides for, among 17
others, required credit support, Commission approval 18
provisions, limitation of liability, base purchase price 19
terms, and ITC terms to ensure the project is constructed 20
to maximize tax credit benefits. 21
Q. Will there be any additional contracts 22
required for the 60 MW energy storage project? 23
A. Yes. In addition to the BTA, Idaho Power will 24
enter into a Shared Facilities Agreement and a Long-Term 25
HACKETT, DI 31
Idaho Power Company
Services Agreement for O&M services performed for the 1
energy storage project following commercial operation of 2
the project. Pursuant to the Build Transfer Agreement, 3
execution of the remaining agreements is anticipated to be 4
complete by the closing date. 5
Q. Are there additional benefits associated with 6
the 100 MW solar PV facility combined with a 60 MW energy 7
storage facility that you have not yet discussed? 8
A. Yes. In addition to the project being the most 9
cost-effective resource selected through the LTCE analyses, 10
and being able to meet the critical in-service date, having 11
contracted with Duke Energy for PPA’s in the past provided 12
for increased contract negotiation efficiencies. 13
Furthermore, the Franklin Solar site was already under 14
development, reducing the risk associated with maximizing 15
the 2022 IRA benefits, which for maximum ITCs required 16
construction to begin prior to January 30, 2023. Finally, 17
the project provides diversification in battery storage 18
suppliers, reducing the risk associated with relying on 19
only one manufacturer for both the 2023 and 2024 battery 20
storage resources. 21
Q. Idaho Power’s request in this case is for a 22
CPCN for 72 MW of battery storage resources. Please 23
reconcile the difference between the 60 MW of battery 24
storage resulting from the BTA with Duke Solar and the 72 25
HACKETT, DI 32
Idaho Power Company
MW of battery storage for which the Company is requesting a 1
CPCN. 2
A. As I mentioned earlier, and as discussed in 3
detail in the Direct Testimony of Mr. Ellsworth, the 4
Company’s load and resource balance remains very fluid 5
during the near-term resource decision making phase, driven 6
in part by continued high load growth. During contract 7
negotiations for the 100 MW solar PV facility combined with 8
a 60 MW energy storage facility, the load and resource 9
balance was refreshed again as part of preparation of the 10
2023 IRP, and it was determined that, even with the 11
combined 100 MW solar PV facility and 60 MW energy storage 12
facility, a 7 MW capacity shortfall still existed in 2024. 13
Because Duke Energy had already moved forward with 14
procurement of 60 MW of energy storage as part of the 15
agreement, the RFP evaluation team contacted the next most 16
cost-effective project identified to meet the 2024 capacity 17
deficit, Project No 10, one of the Idaho Power battery 18
storage benchmark resources. Through discussions with the 19
project submittal contact in Company’s Power Supply 20
department, it was determined Idaho Power could 21
economically and efficiently add 12 MW of battery storage 22
at the Hemingway substation, the site for which 80 MW of 23
battery storage is being installed to meet the 2023 24
capacity deficiency. The 12 MW addition would not require 25
HACKETT, DI 33
Idaho Power Company
infrastructure upgrades and would also ensure maximum ITC 1
benefits as installation could begin timely. The resulting 2
LCOC is lower than any remaining final short list projects. 3
Q. Has the Company entered into a contract for 4
the 12 MW of battery storage to be located at the Hemingway 5
site? 6
A. No. Idaho Power’s intent is to add the 12 MW 7
BESS to the contract executed with Powin Energy Corporation 8
(“Powin”) on February 28, 2022, the contract in place for 9
the 2023 energy storage resources, through a change order. 10
Or, in the alternative, use a different supplier the 11
Company has available. 12
Q. Idaho Power indicated in the Application the 13
Company is not requesting binding ratemaking treatment for 14
investments in the 72 MW battery storage facilities in this 15
case. Does the Company have an estimate of the costs 16
associated with the energy storage projects? 17
A. Yes. The BTA purchase price encompasses all 18
costs associated with the construction and installation of 19
the 60 MW BESS for equal to the Purchase Price set forth in 20
the BTA included as Confidential Exhibit No. 6. Although a 21
change order has not been executed for the 12 MW Hemingway 22
BESS, the Company estimates project costs of $, 23
for a total project cost associated with the 72 MW battery 24
storage of an estimated $. 25
HACKETT, DI 34
Idaho Power Company
Q. Does Idaho Power believe the procurement 1
process has determined the least-cost, least-risk resources 2
to meet the 2024 capacity deficiency? 3
A. Yes. Through the fair and competitive 2022 4
RFP process, Idaho Power received 17 eligible project 5
submittals, comprising 23 different proposals, from 11 6
developers as potential for meeting the 2024 capacity 7
deficiency. The RFP did not restrict ownership structure or 8
resources. Through qualitative and quantitative 9
evaluations, the RFP evaluation team narrowed the project 10
submittals to a final short list, and ultimately the 11
identification of a combination of two projects that 12
resulted in the acquisition of least-cost, least-risk 13
resources. These projects are necessary and required to 14
timely meet the Company’s resource needs and continue to 15
provide reliable and adequate service to Idaho Power’s 16
customers starting in the summer of 2024 and into the 17
future. 18
V. CONCLUSION 19
Q. Please summarize your testimony. 20
A. Idaho Power initiated a competitive RFP 21
process to provide a capacity resource to help meet the 22
Company’s peak electric energy needs in 2024, including an 23
objective scoring methodology used to reasonably evaluate 24
various competing resources. The capacity resources 25
HACKETT, DI 35
Idaho Power Company
selected through the fair and competitive procurement 1
process resulted in a 100 MW solar PV plus 60 MW energy 2
storage project, consisting of a 25-year PPA for a 100 MW 3
solar PV facility that supplies energy to the Company’s 4
system combined with an Idaho Power-owned 60 MW battery 5
storage facility. In addition, the fluid load and resource 6
balance required a second capacity resource: an Idaho 7
Power-owned 12 MW battery storage facility, which was also 8
procured through the Company’s robust competitive bidding 9
process. The combined projects provide for the least-cost 10
and least-risk resources necessary for meeting the 11
Company’s 2024 capacity deficiency. 12
Q. Does this conclude your testimony? 13
A. Yes. 14
// 15
// 16
// 17
// 18
// 19
// 20
// 21
// 22
// 23
// 24
// 25
HACKETT, DI 36
Idaho Power Company
DECLARATION OF ERIC HACKETT 1
I, Eric Hackett, declare under penalty of perjury 2
under the laws of the state of Idaho: 3
1. My name is Eric Hackett. I am employed by 4
Idaho Power Company as the Projects and Design Senior 5
Manager. 6
2. On behalf of Idaho Power, I present this 7
pre-filed direct testimony and Exhibit Nos. 1 through 3 and 8
Confidential Exhibit Nos. 4 through 6 in this matter. 9
3. To the best of my knowledge, my pre-filed 10
direct testimony and exhibits are true and accurate. 11
I hereby declare that the above statement is true to 12
the best of my knowledge and belief, and that I understand 13
it is made for use as evidence before the Idaho Public 14
Utilities Commission and is subject to penalty for perjury. 15
SIGNED this 17th day of February 2023, at Boise, 16
Idaho. 17
18
Signed: 19
20
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
HACKETT, DI
TESTIMONY
EXHIBIT NO. 1
2022
All Source Request for Proposals (RFP)
FOR PEAK CAPACITY AND ENERGY RESOURCES
Idaho Power Company
P.O. Box 70
Boise, ID USA 83707
Zycus Sourcing Event #1312683354
RFP Issued: December 30, 2021
REP Response: March 10, 2022 | 4:00 p.m. Mountain Time
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 1 of 44
Page i
Table of Contents
1. Disclaimer _____________________________________________________________________ 1
2. Purpose _______________________________________________________________________ 3
2.1. BACKGROUND _____________________________________________________________________ 3
2.2. THE SOLICITATION _________________________________________________________________ 3
2.3. REGULATORY CONTEXT _____________________________________________________________ 4
2.4. CONFIDENTIALITY __________________________________________________________________ 4
2.5. SOLICITATION PORTAL AND RESTRICTION ON COMMUNICATIONS ___________________________ 4
2.6. SCHEDULE ________________________________________________________________________ 5
2.7. PRE-BID PRESENTATION AND RECORDING ______________________________________________ 6
3. Product Specifications ____________________________________________________________ 7
3.1. ELIGIBLE PRODUCTS ________________________________________________________________ 7
3.2. DELIVERY AND RESOURCE STATUS____________________________________________________ 10
3.3. OWNERSHIP AND AGREEMENT TYPES _________________________________________________ 10
3.4. ADDITIONAL PRODUCT SPECIFICATIONS _______________________________________________ 10
4. Electric Interconnection _________________________________________________________ 11
4.1. COST ESTIMATING ________________________________________________________________ 11
4.2. INTERCONNECTION STUDIES ________________________________________________________ 12
5. Additional Requirements ________________________________________________________ 14
5.1. DATA AND CYBER SECURITY _________________________________________________________ 14
5.2. PURCHASING RESTRICTIONS/PROHIBITED TECHNOLOGY _________________________________ 14
5.3. SMALL BUSINESS AND SMALL DISADVANTAGED BUSINESS PROGRAM _______________________ 14
6. Proposal Format and Submittal ___________________________________________________ 15
6.1. SUBMISSION OF PROPOSALS ________________________________________________________ 15
6.2. BID FEES _________________________________________________________________________ 15
6.3. PROPOSAL NAMING _______________________________________________________________ 16
6.4. PROPOSAL WRITTEN DOCUMENTS ___________________________________________________ 16
6.5. PROPOSAL SUBMISSION REQUIREMENTS ______________________________________________ 16
6.6. FIRM PROPOSAL __________________________________________________________________ 17
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 2 of 44
Page ii
6.7. TAXES ___________________________________________________________________________ 17
6.8. INSURANCE ______________________________________________________________________ 17
6.9. FINANCIAL AND CREDIT INFORMATION _______________________________________________ 21
6.10. STANDARD TERMS AND CONDITIONS AND POWER PURCHASE AGREEMENT ________________ 21
6.11. EXCEPTIONS TO THE TECHNICAL SPECIFICATIONS ______________________________________ 21
6.12. EXCEPTIONS TO THE DRAFT FORM LETTER OF CREDIT __________________________________ 22
6.13. CLARIFICATION OF PROPOSALS ____________________________________________________ 22
6.14. ADDENDA TO RFP _______________________________________________________________ 22
7. Proposal Evaluation, Negotiation and Approval ______________________________________ 23
7.1. EVALUATION PROCESS _____________________________________________________________ 23
7.2. ADDITIONAL RIGHTS _______________________________________________________________ 24
7.3. ACCEPTANCE AND REJECTION OF PROPOSALS __________________________________________ 24
7.4. AGREEMENT NEGOTIATIONS ________________________________________________________ 24
7.5. EXCLUSIVITY _____________________________________________________________________ 24
7.6. PUBLICITY _______________________________________________________________________ 25
7.7. COMMISSION APPROVAL ___________________________________________________________ 25
7.8. ENTIRE RFP ______________________________________________________________________ 25
EXHIBIT A – Information for Qualitative Evaluation ______________________________________ 26
EXHIBIT B – Information for Quantitative Evaluation _____________________________________ 27
EXHIBIT C – Information on Preferred Locations _________________________________________ 28
EXHIBIT D – Information on Most Valuable Hours ________________________________________ 29
EXHIBIT E – Standard Terms and Conditions _____________________________________________ 30
Exhibit F – Power Purchase Agreement ________________________________________________ 31
EXHIBIT G – BESS Technical Specifications ______________________________________________ 32
EXHIBIT H – Solar Technical Specifications ______________________________________________ 33
EXHIBIT I – Wind Technical Specifications _______________________________________________ 34
EXHIBIT J – Gas-Fired Convertible to Hydrogen Specifications ______________________________ 35
EXHIBIT K – Mutual Non-Disclosure Agreement __________________________________________ 36
EXHIBIT L - Counterparty Financial Questionnaire ________________________________________ 37
EXHIBIT M – Draft Form Letter of Credit ________________________________________________ 38
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 3 of 44
Page iii
EXHIBIT N – Effective Load Carrying Capability Factors ____________________________________ 39
EXHIBIT O – Bid Fee Submittal ________________________________________________________ 40
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 4 of 44
Page 1
1. Disclaimer
The information contained in this Request for Proposals (RFP) is presented to assist interested parties in deciding
whether or not to submit a proposal. Idaho Power Company (IPC), an operating company subsidiary of IDACORP,
Inc., is issuing this RFP to solicit formal proposals from qualified companies (each a Respondent) and does not
represent this information to be comprehensive or to contain all of the information that a Respondent may need
to consider in order to submit a proposal. None of IPC, its affiliates, or their respective employees, directors,
officers, customers, agents and consultants makes, or will be deemed to have made, any current or future
representation, promise or warranty, express or implied, as to the accuracy, reliability or completeness of the
information contained herein, or in any document or information made available to a Respondent, whether or
not the aforementioned parties knew or should have known of any errors or omissions, or were responsible for
their inclusion in, or omission from, this RFP.
No part of this RFP and no part of any subsequent correspondence by IPC, its affiliates, or their respective
employees, directors, officers, customers, agents or consultants shall be taken as providing legal, financial or
other advice or as establishing a contract or contractual obligation. IPC reserves the right to request from
Respondent information that is not explicitly detailed in this document, obtain clarification from Respondents
concerning proposals, conduct contract development and other discussions with selected Respondents, and
conduct discussions with members of the evaluation team and other support resources as described in this RFP.
The requirements specified in this RFP reflect those presently known. IPC reserves the right to vary, in detail, the
requirements and/or to issue addenda to the RFP. In the event it becomes necessary to revise any part of the
RFP, addenda will be provided to Respondents included in the current and applicable stage of the RFP.
IPC will, in its sole discretion and without limitation, evaluate proposals and proceed in the manner IPC deems
appropriate. IPC reserves the right to reject any and all, or portions of, any proposal submitted by Respondents
for failure to meet any criteria set forth in this RFP or otherwise, to make an independent assessment of viability
of submissions, and to accept proposals other than the lowest cost proposal.
This RFP has been prepared solely to solicit proposals and is not a contract offer or a contract. This RFP is not
binding on IPC. The only document that will be binding on IPC is an agreement duly executed by IPC and the
successful Respondent (if any) after the completion of the evaluation process and the award and negotiation of
an agreement. IPC reserves the right to reject any and all proposals submitted by Respondents. The issuance of
this RFP does not obligate IPC to purchase any product or services offered by Respondent or any other entity.
Furthermore, IPC may choose, at its sole discretion, to abandon the RFP process in its entirety. Respondents
agree that they submit proposals without recourse against IPC, IDACORP Inc., any of IDACORP Inc.’s affiliates, or
any of their respective employees, agents, officers, or directors for failure to accept an offer for any reason. IPC
also may decline to enter into any agreement with any Respondent, terminate negotiations with any
Respondent or abandon the RFP process in its entirety at any time, for any reason and without notice thereof.
Respondents that submit proposals agree to do so without legal recourse against IPC, its affiliates, or their
respective employees, directors, officers, customers, agents or consultants for rejection of their proposals or for
failure to execute an agreement for any reason. IPC and its affiliates shall not be liable to any Respondent or
other party in law or equity for any reason whatsoever for any acts or omissions arising out of or in connection
with this RFP. Respondent shall conform in all material respects to all applicable laws, ordinances, rules, and
regulations and nothing in this RFP shall be construed to require IPC or Respondent to act in a manner contrary
to law. Except as otherwise provided in the rules and orders of the state of Idaho and Oregon Public Utilities
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 5 of 44
Page 2
Commissions (the Commission or Commission’s), by submitting its proposal, a Respondent waives any right to
challenge any valuation by IPC of its proposal. Respondent whose proposal may be selected in response to this
RFP acknowledges that it assumes full legal responsibility for the accuracy, validity, and legality of the work
provided in conformance with this RFP. By submitting its proposal, a Respondent waives any right to challenge
any determination of IPC to select or reject its proposal. IPC reserves the right to accept the proposal in whole or
in part, and to award to more than one Respondent. Furthermore, Respondent understands that any “award” by
IPC does not obligate IPC in any way. IPC will not be obligated to any part unless and until IPC executes a
definitive agreement between the parties.
Respondent will absorb all costs incurred in responding to this RFP, including without limitation, costs related to
the preparation and presentation of its response, supplemental responses, and negotiation and documentation
of agreements. All materials submitted by the Respondent immediately become the property of IPC. Any
exception will require written agreement by both parties prior to the time of submission.
In responding to this RFP, Respondent shall adhere to best business and ethical practices. Respondent shall
adhere to IPC’s Supplier Code of Conduct, available at idahopower.com.
Respondent is specifically notified that failure to comply with any part of this RFP may result in disqualification
of the proposal, at IPC’s sole discretion.
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 6 of 44
Page 3
2. Purpose
2.1. BACKGROUND
IDACORP, Inc. is a holding company formed in 1998. Comprised of regulated and non-regulated businesses, its
origins lie with Idaho Power, a regulated electric utility that began operations in 1916. Today, IPC is the largest
regulated electric utility in the state of Idaho and IDACORP’s chief subsidiary. IPC serves over 600,000
residential, business, agricultural, and industrial customers. The company’s service area covers approximately
24,000 square miles, including portions of eastern Oregon. Learn more about Idaho Power at idahopower.com.
IPC currently serves its customers by supplying low-cost, reliable, and clean energy. Affordable, clean
hydropower is the largest source of energy for customers. Power generation comes from a diverse set of
resources that continues to meet a growing demand. For a more detailed description of current generation
resources, please visit: idahopower.com/energy-environment/energy/energy-sources/.
IPC's service territory continues to experience customer growth and increasing demand (load) for
electricity. IPC anticipates sustained load growth that will require the procurement of new resources to
meet peak summer demand to maintain system reliability. Additionally, Idaho Power is interested in the
procurement of potential economic energy resources, as detailed in the company’s 2021 Integrated
Resource Plan (IRP) results, to supplement the company’s existing portfolio of resources. The addition of
new resources is critical to ensure IPC can continue to reliably meet the growing pressures on its electrical
system and serve its customers. The 2021 IRP is the basis for the resource requests in this solicitation.
2.2. THE SOLICITATION
IPC is issuing this RFP to solicit formal proposals from Respondents for electric energy and capacity delivered
from electric resources that employ certain qualifying technologies under certain ownership arrangements
(Products) to help meet IPC’s identified capacity needs of 85 megawatts (MW) in 2024 and an incremental 115
MW in 2025. The eligible types of Products are described further in Section 3 of this RFP. Details on the proposal
submission process and the proposal evaluation process are also described further in this RFP.
Evaluation of proposals will be performed by a special team of IPC staff and retained consultants with relevant
subject matter expertise (Evaluation Team). Proposals may be submitted by a separate team of IPC staff and
retained consultants (Internal Team). The Evaluation Team will treat the Internal Team as a Respondent. Any
proposal from the Internal Team will be subject by the Evaluation Team to the same requirements, evaluation
methodology, and other standards specified in this RFP for a proposal from any Respondent. Furthermore, the
Evaluation Team and the Internal Team must comply with IPC’s Separation of Functions Protocol to ensure the
Evaluation Team functions independently from the Internal team, does not provide access to any non-public
information or undue preference to the Internal Team, and provides the Internal Team and Respondents equal
access to non-public information related to the competitive bidding process for new generation resource
procurement.
The process of issuing and responding to this RFP, evaluation and selection of proposals, and the negotiation and
approval of the agreement(s) is known as the solicitation (Solicitation). Respondents who are interested in
participating in the Solicitation and submitting a proposal must first register via the third-party solicitation
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 7 of 44
Page 4
portal, Zycus, further described in Section 2.5 of this RFP. This RFP sets forth the terms and conditions by which
IPC will perform the Solicitation. Respondent agrees to be bound by all the terms, conditions, and other
provisions of this RFP and any addenda to it that may be issued by IPC. This RFP governs the Solicitation and
supersedes any other written or oral form of communication between Respondents and IPC concerning the
Solicitation.
2.3. REGULATORY CONTEXT
The terms and conditions and effectiveness of any agreement will ultimately be subject to the Commissions’
approval. This could also include, but is not limited to, Commission approval of a certificate of public
convenience and necessity (CPCN) application from IPC. IPC reserves the right to: 1) inform the Commission that
IPC could not reach agreement with the Respondent of a selected resource; 2) request Commission approval of
any agreements it enters into with successful Respondents (e.g., CPCN applications); and 3) to terminate any
agreement if IPC fails to receive Commission approval of submitted agreements or applications. Respondent
shall provide any and all information and documentation reasonably requested by IPC to support such
applications and requests.
2.4. CONFIDENTIALITY
Respondent acknowledges and agrees that all information obtained or produced in relation to this RFP is the
sole property of IPC and shall not be released or disclosed by Respondent to any person or entity for any
purpose other than providing a proposal to IPC, without the express written consent of IPC. Respondent agrees
not to make any public comments or disclosures, including statements made for advertising purposes, regarding
this RFP to the media or any other party without prior written consent of IPC. If Respondent receives any
inquiries regarding this RFP from the media or any other party, said inquiries shall be forwarded to IPC.
Respondents shall specifically designate and clearly label any and all material(s) or portions thereof, contained in
their proposals, that they deem to contain proprietary information as “CONFIDENTIAL”. Nonetheless, IPC
reserves the right to release all proposals to its affiliates and such affiliates’ agents, advisors, and consultants, for
purposes of proposal evaluation. IPC will advise each agent, advisor, or consultant that receives such claimed
confidential information of its obligations to protect such information. In addition, all information, regardless of
its confidential or proprietary nature, will be subject to review by the Commission and other governmental
authorities and courts with jurisdiction, and may be subject to legal discovery. It is not IPC’s intent to enter into
any separate confidentiality, non-disclosure, or similar agreements as a condition to receiving a Respondent’s
proposal. However, if and when a proposal is advanced to the Initial Shortlist phase of this RFP, the Respondent
must execute a Mutual Nondisclosure & Confidentiality Agreement (Confidentiality Agreement) with IPC in
advance of further discussions with, and evaluation of, any such Respondent proposal by IPC. Respondents are
directed to EXHIBIT K – Mutual Non-Disclosure Agreement for more detailed information.
2.5. SOLICITATION PORTAL AND RESTRICTION ON COMMUNICATIONS
IPC has opened a web-based portal hosted on the Zycus sourcing platform (the Portal). All information
exchanged between the Respondent and IPC concerning the Solicitation must be via the Portal only from the
time the Portal is open until it is closed by IPC. The Portal allows a Respondent to see only its own information
and not the information of other Respondents.
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 8 of 44
Page 5
IPC has the ability to communicate with Respondents through the Portal. Other than written communication
through the Portal, Respondents are prohibited from communicating with IPC employees, representatives, staff,
or Board Members regarding the Solicitation during the period in which the Portal is open. Restricted
communication includes, but is not limited to, “thank you” letters, phone calls, emails, and any contact that
results in the direct or indirect discussion of the Solicitation and/or submitted proposals. Violation of this
provision by Respondents or their agents may lead to disqualification.
The web link to the Portal hosted by Zycus is: zycus.com
Respondent is responsible for ensuring it has registered for, and posts documents to, the correct Portal hosted
by Zycus. The Respondent registering for access to the Portal must be a representative of the Respondent and
counterparty with which IPC will engage in any future negotiations, and not consultants or attorneys for the
Respondent.
Respondents who have completed the registration process and submitted the public Notice of Intent Form
found at idahopower.com/about-us/doing-business-with-us/request-for-resources shall receive an email
invitation from Zycus containing a link to the event.
Respondent must not disclose its participation in this Solicitation (other than by attendance at any meeting held
by IPC with respect to the Solicitation) or collaborate on, or discuss with any other Respondent or potential
Respondent bidding strategies or the substance of any proposal(s), including without limitation the price or any
other terms or conditions of any proposal(s).
Questions regarding the Portal should be directed to:
Idaho Power Company
Request for Resource Team
resourceNOI@idahopower.com
2.6. SCHEDULE
The key milestones for the Solicitation and their currently scheduled dates are provided in Table 1 below.
Table 1 – Key Milestones for the Solicitation
Milestone Date
Portal opened for interested party registration and communication December 30, 2021
RFP and other Solicitation documents posted to the Portal December 30, 2021
Pre-Bid Presentation Recording posted to the Portal January 20, 2022
Deadline for Submittal of Questions, after which IPC may not respond February 10, 2022 by 4 p.m.
Mountain Time
Deadline for Proposal Submittal – Portal closed to further posting by
Respondents, evaluation begins
March 10, 2022 by 4 p.m.
Mountain Time
Threshold and Eligibility Screening Completed March 31, 2022
Initial Shortlist Completed April 21, 2022
IRP Modeling and Contract Negotiations with Initial Shortlist April 22, 2022 – June 1, 2022
Final Shortlist Selected June 3, 2022
Complete Final Contract Negotiations June 30, 2022
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Page 6
Execute Agreements (Pending Commission Approval) July 15, 2022
This schedule and documents associated with the Solicitation are subject to change at IPC’s sole discretion at
any time and for any reason. IPC will endeavor to notify Respondents of any changes to the Solicitation but shall
not be liable for any costs or liability incurred by Respondents or any other party due to a change or for failing to
provide notice or acceptable notice of any change. Respondents should factor this schedule and any changes
thereto into their project development timelines and proposals.
Respondents should carefully review this RFP for questions, clarifications, defects, and questionable or
objectionable materials. Comments and questions concerning clarifications, defects, and questionable or
objectionable material must be submitted through the Portal and must be submitted on or before the date and
time specified in the above schedule. IPC may not respond to questions submitted after this date. All questions
and their applicable responses will be provided to Respondents via the Portal.
2.7. PRE-BID PRESENTATION AND RECORDING
IPC will not host an in-person live pre-bid meeting or webcast regarding the Solicitation due to concerns over
potential technical difficulties in live hosting such a large event and fairness to Respondents from distant time
zones. Instead, IPC will prepare a video or audio recording concerning the RFP and the overall Solicitation
process. The recording will include video of a presentation deck and audio of the speakers presenting the deck.
The recording will be posted to the Portal on or before the date identified in the Schedule provided in Section
2.6 of this RFP. Viewing of the recording is not mandatory for Respondents.
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 10 of 44
Page 7
3. Product Specifications
A proposal must demonstrate that the specifications stated in this section are satisfied.
3.1. ELIGIBLE PRODUCTS
The Products eligible to be proposed in response to the RFP are presented in the below Key Product Specification Tables.
Key Product Specification Tables:
Table 2 – Renewable Energy Products
Product 1 2 3 4 5 6 7 8 9
Resource Type Solar PV Wind Geothermal
Product Type Power Purchase Agreement
(PPA)
Asset
Purchase PPA Asset
Purchase PPA Asset Purchase
Ownership Structure Respondent IPC Respondent IPC Respondent IPC
Term
20-34, 35 years,
IPC Asset
Purchase
35 years n/a
20-34, 35
years, IPC
Asset
Purchase
35
years n/a
20-34, 35
years, IPC
Asset
Purchase
35
years n/a
First Delivery On or before 6/1/2024 (for 85 MW 2024 deficit), or 6/1/2025 (for 115 MW 2025 deficit)
Resource Status Existing or proposed new in late-stage development with pending or executed Large Generation Interconnection
Application (LGIA)/ Small Generation Interconnection Application (SGIA)
Design Life 35 years minimum
Capacity Minimum 100 MW ac nameplate or minimum 40 MW ac capacity after application of effective load carrying capability
(ELCC) factor1
Interconnection IPC Transmission System or transmission system of adjacent host utility
Delivery Point Within the boundary of the IPC Balancing Authority (BA) Area, or outside with all necessary transmission rights to the BA
Storage Duration n/a
Storage Cycles n/a
Other A Proposal for a 20-34 year PPA must include pricing for each of the alternatives shown under Term section of this Table 2.
A resource of less than the specified capacity minimums that offers unique benefits may be proposed
1 Refer to Exhibit N for ELCC factors
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Table 3 – Storage Products
Product 10 11 12 13 14 15 16 17 18 19
Resource Type
Battery
Energy
Storage
(BESS)
Solar + BESS Wind + BESS Long Duration Storage
Product Type Asset
Purchase
Asset
Purchase
Solar PPA
20-34 Years
+ BESS
Asset
Purchase
Solar PPA
35 Years +
BESS Asset
Purchase
Asset
Purchase
Wind PPA
20-34 years
+ BESS
Asset
Purchase
Wind PPA
35 years +
BESS Asset
Purchase
PPA Asset
Purchase
Ownership
Structure IPC IPC
Solar:
Respondent
BESS: IPC
Solar:
Respondent
BESS: IPC
IPC
Wind:
Respondent
Storage: IPC
Wind:
Respondent
Storage: IPC
Respondent IPC
Term n/a n/a
20-34 years,
35 years,
IPC Asset
Purchase
35 years n/a
20-34 years,
35 years,
IPC Asset
Purchase
35 years
20-34
years, 35
years,
IPC Asset
Purchase
35
years n/a
First Delivery On or before 6/1/2024 (for 85 MW 2024 deficit), or 6/1/2025 (for 115 MW 2025 deficit)
Resource Status Existing or proposed new in late-stage development with pending or executed LGIA/SGIA
Design Life 35 years
Capacity Minimum 40 MW ac capacity after application of ELCC factor1
Interconnection IPC Transmission System or transmission system of adjacent host utility
Delivery Point Within the boundary of the IPC Balancing Authority (BA) Area, or outside with all necessary transmission rights to the BA
Storage
Duration 4+ hours 6+ hours
Storage Cycles 1+ cycles per day
Other
A proposal for a 20-34 year PPA must include pricing for each of the alternatives show under the Term section of
this Table 3. Storage combined with a renewable must be chargeable from the grid by IPC after expiration of the
tax benefit recapture period, if applicable. A solar or wind resource of less than the specified capacity minimums
that offers unique benefits may be proposed.
1 Refer to Exhibit N for ELCC factors
Exhibit No. 1
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Table 4 – Other Products
Product 20 21 22 23
Resource Type Gas-fired Convertible to Hydrogen Demand Response
Product Type PPA Asset Purchase Program
Ownership Structure Respondent IPC Respondent
Term
20-34 years, 35
years, IPC Asset
Purchase
35 years n/a 5 year maximum
First Delivery On or before 6/1/2024 (for 85 MW 2024 deficit), or 6/1/2025 (for 115 MW 2025 deficit)
Resource Status Existing or proposed new in late-stage development with
pending or executed LGIA/SGIA n/a
Design Life 50 years n/a
Capacity Minimum 40 MW ac capacity after application of ELCC factor Minimum 5 MW ac delivered after applications of
ELCC factor
Interconnection IPC Transmission System or Transmission System of adjacent
host utility n/a
Delivery Point Within the boundary of the IPC Balancing Authority (BA) Area,
or outside with all necessary transmission rights to the BA n/a
Storage Duration n/a
Storage Cycles n/a
Other
A Proposal for a 20-34 year PPA must include pricing for each
of the alternatives shown under Term section of this Table 4.
Conversion must be achievable within 10 years and costs
must be accounted for in submittal.
Must meet cost effectiveness test based on utility
cost test (UCT). Capacity must be dispatchable based
on day ahead notification minimum with preference
for shorter notice dispatch (e.g. 10 minute to 1 hour
ahead)
New programs must be differentiated from
existing programs and exclude existing IPC demand
response participants (not overlap) or provide details
of how the new program would complement existing
IPC programs.
New programs must demonstrate how marketing
and customer participation will not be detrimental or
cause undue confusion to IPC customers.
Respondents must have a demonstrated record of
program success.
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Page 10
3.2. DELIVERY AND RESOURCE STATUS
Preference will be given to proposals with proof of generator interconnection status and the ability to
deliver such proof as a pending or executed Generation Interconnection Agreement (LGIA or SGIA),
progress or status of the interconnection study, and/or understanding of contingent queue projects
that may hinder deliverability.
3.3. OWNERSHIP AND AGREEMENT TYPES
As a vertically integrated utility with an obligation to provide safe, reliable electric service, IPC will
carefully consider any additional quantitative and qualitative benefits associated with resources
proposed under an IPC ownership mechanism, under which ownership of the resource is transferred
to IPC upon achieving commercial operation, or occurring later, at some subsequent date.
3.4. ADDITIONAL PRODUCT SPECIFICATIONS
IPC may also accept other Products that meet the ownership and electrical functionality criteria
outlined in the Key Product Specification Tables identified in Section 3.1 of this RFP. Respondents
who propose a Product not specifically identified in the Key Product Specification Tables must provide
applicable information, specifications, terms, etc. for evaluation purposes. Products that are not
eligible include, but are not limited to; non-electrical energy or capacity (e.g., thermal energy storage
without conversion to electric energy), renewable energy credits without the associated energy
(Unbundled Renewable Energy Credits [RECs]), and financial instruments used to mitigate variable
cost exposure without associated energy or capacity (Financial Firming).
Respondents whose proposals include Solar Photovoltaic (PV) and/or Wind technologies are
encouraged to configure the Solar PV and/or Wind resources to maximize energy delivery during hours
most valuable to IPC.
Information concerning the hours most valuable to IPC is provided in EXHIBIT D – Information on Most
Valuable Hours attached hereto. Respondents are also advised to review the (ELCC) factors that IPC
has forecasted consistent with the 2021 IRP for various resource types, Exhibit N – Effective Load
Carrying Capability Factors to this RFP. These ELCCs are provided for information purposes only. IPC
will use project-specific data to determine project-specific ELCCs to discount the capacity proposed by
the Respondent during the quantitative evaluation process described in this RFP. The ELCC factors will
not impact the actual prices that would be paid to a Respondent if and when IPC enters an agreement
with the Respondent to purchase the proposed Product.
Respondents are directed to EXHIBIT E – Standard Terms and Conditions and Exhibit F – Power
Purchase Agreement for more detailed information concerning the key terms and conditions to be
incorporated into Respondent’s agreement structure. IPC encourages the submission of proposals
that use applicable tax credits in the most efficient manner to reduce the project’s overall cost. Any
structure needed to effectively utilizes tax credits and subsidies should be included in the Proposal.
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Page 11
Respondents are also directed to EXHIBIT M – Draft Form Letter of Credit for reference. In such case
that the Respondent is successful, Respondent shall be responsible for furnishing a letter of credit in a
format substantially similar to these forms included in this RFP. These forms shall be subject to review
and acceptance by IPC in its reasonable discretion. Respondent shall deliver the required letter of
credit no later than 30 days following any such notice of award of the Project.
4. Electric Interconnection
4.1. COST ESTIMATING
Respondent is responsible for understanding the electric transmission interconnection processes of
IPC or other transmission providers, considering the durations and costs of those processes in its
proposals, and successfully executing those processes to achieve coordination with IPC and delivery of
the proposed Products to IPC on or before the dates identified in its proposed schedule for the
resource. A proposal must demonstrate that all incremental costs to deliver energy from the resource
to IPC’s load have been contemplated as described below. The Respondent must include all costs
pursuant to an existing or future Generator Interconnection Agreement (GIA) that will allow the
resource to be designated as a Network Resource.
Electric interconnection facilities consist of multiple components as defined below.
a) Interconnection Customer’s Interconnection Facilities (ICIF) are all facilities and equipment
(including the gen tie line) located between the resource and the Point of Change of
Ownership. Respondent must submit resource-specific cost estimates of ICIF as part of its
proposal and consider the cost of ICIF in its pricing.
b) Transmission Provider Interconnection Facilities (TPIF) connect the Interconnection
Customer’s Interconnection Facilities and facilitate the metering, relay and communications,
etc. TPIF are all facilities owned, controlled or operated by the transmission Provider from the
Point of Change of Ownership to the Point of Interconnection. These are facilities that IPC will
own, and the Respondent will fund. Respondent must submit resource-specific cost estimates
of TPIF as part of its proposal and consider the cost of TPIF in its pricing. To aid in
consideration of the cost, an estimated cost for TPIF based on interconnection voltage level is
provided below. If an interconnection study has been performed by the Transmission Provider
that includes an estimate of TPIF, then the costs from that study should be used in lieu of
these estimates.
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 15 of 44
Page 12
Voltage TPIF Estimated Cost (2021 $ 000s)
69 kilovolts (kV) $1,500
138 kV $2,000
Voltage TPIF Estimated Cost (2021 $ 000s)
230 kV $2,500
345 kV $3,000
Station Network Upgrades (SNU) in a GIA are either new switchyards or additions to existing
switchyards or substations that are built to interconnect the generator to IPC’s transmission system.
SNUs become a component of the integrated IPC transmission system and are incorporated into IPC
tariffs according to the Open Access Transmission Tariff (OATT). Respondents are required to provide
cost estimates of SNUs. Respondents must submit resource-specific cost estimates of SNU’s as a part
of their proposal and consider the cost of SNU in the pricing. If costs are not available from an
interconnection study then Respondent should estimate costs and provide rationale to substantiate
the cost estimate.
c) Delivery Network Upgrades (DNU) in a GIA are upgrades to IPC’s transmission network that
will be required for individual resources and groups of resources. These upgrades will be
incorporated into IPC’s transmission tariffs according to the OATT. Respondents must submit
resource-specific cost estimates of DNUs as part of their proposal and consider the cost of
DNU in the pricing. If costs are not available from an interconnection study then Respondent
should estimate costs and provide rationale to substantiate the cost estimate.
If a Respondent has an active interconnection request, the Respondent must provide the
interconnection request identifier(s) (the "queue position") associated with its resource in its proposal.
If the resource identified in the proposal was in the queue but has since withdrawn, the Respondent
should provide that queue position even though it is no longer active.
Respondent must provide proposal-specific SNUs and DNUs and associated costs or estimate the SNUs
and DNUs if unavailable from the Transmission Provider. Proposals involving existing generation
resources from which IPC currently purchases capacity and energy will not be burdened during
proposal evaluation with any incremental electric interconnection or network delivery costs provided
that IPC currently has sufficient transmission and distribution capacity to deliver the proposed energy
to its load. Existing generation resources that IPC determines to have inadequate transmission
capacity to deliver will be burdened with the estimated cost of purchasing additional transmission
rights and/or SNUs and DNUs.
4.2. INTERCONNECTION STUDIES
The Transmission Provider function within IPC, separate and apart from the RFP evaluation team,
performs studies for (LGIA) requests (over 20 MW) and (SGIA) requests (under 20 MW). The studies
are performed to determine the feasibility, cost, time to construct, and injection capability for the
interconnection of an electric generating resource. Information concerning generator interconnection
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
Page 16 of 44
Page 13
can be found at IPC’s website 1 including information on PURPA Qualifying Facility (QF)
Interconnections, Non-PURPA QF Interconnections, and Facility Connection Requirements. IPC posts
the results of these studies on its OASIS website.2
Transmission systems are interrelated and generation injection at one point on the systems may
change the injection capability at other points. The generation injection capability assumed by the
Respondent for purposes of a proposal may change when the Transmission Provider performs specific
resource and resource portfolio interconnection studies. For purposes of aiding Respondents in
determining points of interconnection and delivery, IPC has identified areas on the IPC system that
may have relatively high injection capability and relatively low cost and time to construct if studied by
the Transmission Provider. These areas are identified in EXHIBIT C – Information on Preferred
Locations of this RFP.
For Respondents that submit a generation interconnection request or transmission service request
pursuant to IPC’s OATT intending to receive interconnection or transmission service cost estimates for
purposes of responding to this RFP, Respondents are advised that there may not be sufficient time to
have studies performed and completed prior to proposal evaluation.
If and when a proposal is selected for the Initial Shortlist and it is for a new resource that will be
interconnected to the IPC BA, it may be studied by IPC per IPC’s generation interconnection process.
Respondents will be notified if their proposed resource will be studied, and the Respondents must
provide the site control, monetary deposits and other information required under the IPC generator
interconnection process. When the study process reaches the Facilities Study phase, the Respondent
will be responsible for continued compliance to bring the resource through the balance of the IPC
interconnection process and execute an interconnection agreement.
Upon completion of the Facilities Study, the estimated costs of the ICIF, TPIF, SNU, and DNU resulting
from the study (if any) will be used by IPC in further evaluation of the proposal and determination if
the Respondent will be selected for the Final Shortlist and invited to negotiate an agreement with IPC.
For Final Shortlist resources IPC requires that it will be declared a Network Resources of IPC. The cost
of any network transmission service on IPC’s system for a resource that is ultimately contracted and
achieves commercial operation will be funded according to the OATT.
Regardless of resource ownership, Respondents must provide satisfactory proof that all ICIF, TPIF,
SNU, and DNU facilities can be complete and delivery of the proposed Products to IPC on or before the
dates identified in its proposed schedule for the resource.
1 www.idahopower.com/about-us/doing-business-with-us/generator-
interconnection/ 2 www.oasis.oati.com/ipco/.
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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5. Additional Requirements
5.1. DATA AND CYBER SECURITY
A proposal must comply with the expectations of the Office of Electricity with regard to Presidential
Executive Order 14017 (E.O. 14017) issued February 24, 2021, titled America’s Supply Chains and
Notice of Request for Information (RFI) on Ensuring the Continued Security of the United States Critical
Electric Infrastructure Frequently Asked Questions, which (among other things) expect utilities to act
in a way that minimizes the risk of installing electric equipment and programmable components that
are subject to foreign adversaries’ ownership, control, or influence.
All design and implementation details must follow electrical industry best practices for cyber security
as well as all applicable regulatory requirements pertaining to the security of electric system assets. In
response to EXHIBIT A – Information for Qualitative Evaluation of this RFP, Respondents must
generally describe their cyber security requirements, practices, and policies. Any additional IPC
specific requirements will be addressed during the RFP review and contracting process, pursuant to
EXHIBIT K – Mutual Non-Disclosure Agreement. Respondent must state that any and all equipment
utilized in the proposed resource will not be procured through an Office of Foreign Assets Control
(OFAC) designed entity or otherwise be comprised of equipment prohibited for use by electric utilities
in the United States.
5.2. PURCHASING RESTRICTIONS/PROHIBITED TECHNOLOGY
Pursuant to Section 889(a)(1)(B) of the John S. McCain National Defense Authorization Act for Fiscal
Year 2019, a Respondent must be able to represent in its agreement with IPC that the Respondent
does not and/or will not use any telecommunications equipment, system, or service (or as a
substantial or essential component of any system or as or critical technology of any system) made by
any of the following companies, or any subsidiary or affiliate thereof (including companies with the
same principal word in the name, e.g., Huawei or Hytera: Huawei Technologies Company; ZTE
Corporation; Hytera Communications Corporation; Hangzhou Hikvision Digital Technology Company;
or, Dahua Technology Company (collectively, Prohibited Technology).
Prohibited Technology may include, but is not limited to, video/monitoring surveillance
equipment/services, public switching and transmission equipment, private switches, cables, local area
networks, modems, mobile phones, wireless devices, landline telephones, laptops, desktop
computers, answering machines, teleprinters, fax machines, and routers. Prohibited Technology does
not include telecommunications equipment that cannot route or redirect user data traffic or permit
visibility into any user data or packets that the equipment transmits or handles.
5.3. SMALL BUSINESS AND SMALL DISADVANTAGED BUSINESS
PROGRAM
IPC is committed to the implementation of a Small and Disadvantaged Business Program. It is the
intent of IPC that small business concerns and small businesses owned and controlled by socially and
economically disadvantaged individuals have the opportunity to participate in the performance of
contracts awarded by IPC. Consequently, we request that you indicate your eligibility as a small
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Page 15
business based upon the regulations in Title 13, Code of Federal Regulations, Part 121. If in doubt,
consult the Small Business Administration Office in your area.
6. Proposal Format and Submittal
6.1. SUBMISSION OF PROPOSALS
A proposal is considered the aggregate of the information uploaded by a Respondent, and
subsequently entered directly into the cells of the spreadsheet titled “Proposal Entry Form” located in
the Portal (Information).
Respondent is responsible for uploading the Proposal Entry Form back to the Portal, with all and other
written documents required by the Proposal Entry Form and this RFP. The Portal is designed to accept
the majority of the Information as data entered in the Proposal Entry Form, with data entry restricted
to only certain eligible types and values. The purpose is to ensure Information is entered consistently
across all Respondents and proposals such that IPC can consistently, fairly, and quickly organize the
Information and evaluate the proposals and minimize the amount of written (e.g., PDF, DOC)
documents that IPC must review and interpret.
Respondents are strongly advised to carefully review Exhibit E – Standard Terms and Conditions and
Exhibit F – Power Purchase Agreement and the Technical Specifications (Exhibit G – BESS Technical
Specification, Exhibit H – Solar Technical Specification, and Exhibit I – Wind Technical Specification,
Exhibit J – Gas-Fired Convertible to Hydrogen Technical Specification) relevant to their proposed
products prior to uploading information to the Portal. If and when a Respondent is selected for
negotiation of an agreement, IPC will utilize the Information submitted to populate the relevant
portions of the agreements for that Respondent. Respondents should upload information with the
understanding that it will ultimately result in binding contract terms.
6.2. BID FEES
A Respondent is required to submit to IPC a non-refundable fee of $10,000 with each proposal
submitted (Evaluation Fee). The purpose of the Evaluation Fee is to encourage submission of well-
developed and viable proposals and to offset the cost to IPC for evaluation of proposals. For the
purpose of assessing an Evaluation Fee, a proposal is generally defined as follows:
• A single capacity construction phase of a resource at one site = one proposal
• Different capacity, or initial delivery year from the same site = different proposal
• Different technology from the same site = different proposal
• Different Product from same site = different proposal
• Different site = different proposal
IPC may deem a proposal that does not satisfy the requirements for a single proposal as multiple
proposals, each of which would require a separate Evaluation Fee. If IPC deems a Respondent’s
proposal to be multiple proposals, IPC will notify the Respondent and allow it to elect to pay the
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Page 16
incremental Evaluation Fee or to revise its proposal to comply with IPC’s requirements for a single
proposal.
A Respondent that has its proposal selected for the Final Shortlist and is invited to begin negotiation of
an agreement may be required to submit an additional fee in an amount equal to $1/kW of proposed
resource capacity (a Supplemental Fee) to IPC prior to commencement of negotiations. For example, a
proposal for a resource with a proposed capacity of 80 MW would pay a Supplemental Fee of $80,000
(e.g., 80 MW Project
* $1/kW = $80,000). The purpose of the Supplemental Fee is to ensure good faith submissions and
negotiations by the Respondent and to offset the costs that IPC will incur while reviewing proposals
and negotiating an agreement.
The Evaluation Fee and Supplemental Fee may be refunded by IPC at its sole discretion.
6.3. PROPOSAL NAMING
A Respondent must generate a unique name for each of its proposals (Proposal Code) by selecting
and entering in the Proposal Entry Form where indicated the Product Type, Proposal Name, and
whether the facility is new or existing. The resulting Proposal Code must thereafter be used by the
Respondent when referring to the proposal and must be inserted into the file name of each
document for the proposal uploaded by the Respondent. The purpose of the Proposal Code is to
allow IPC to more easily identify and differentiate among proposals and documents particularly if the
volume of proposals received is relatively large.
6.4. PROPOSAL WRITTEN DOCUMENTS
Written documents must be text-searchable PDF (portable document format) and must contain
documents reproduced directly from the native document (i.e., Word, Excel, MicroStation,
AutoCAD). Scanned images and documents will be considered irregular and may be rejected.
6.5. PROPOSAL SUBMISSION REQUIREMENTS
Exhibits to this RFP summarize the Information that must be uploaded by Respondents to the Portal.
These include EXHIBIT A – Information for Qualitative Evaluation and EXHIBIT B – Information for
Quantitative Evaluation attached hereto.
Respondents are directed to the Proposal Entry Form within the Portal to ensure Respondent responds
to, and completes all the requested information applicable for Respondents proposed technology.
Respondents will ensure the specific type and level of detail requested in the Proposal Entry Form is
provided, complete, and accurate.
Respondent must fill out all applicable fields on all four sheets of the Proposal Entry Form in the order
of:
1. Respondent Information;
2. Commercial;
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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3. Technical; and
4. Pricing.
Respondents are directed to the Proposal Entry Form within the Portal for further instructions.
Incomplete Proposal Entry Forms will be considered non-conforming and may be rejected.
6.6. FIRM PROPOSAL
Each proposal shall be firm, not subject to price escalation, and binding for one hundred eighty (180)
days from the date the proposals are due under this RFP. Proposed pricing shall include Operating and
Maintenance (O&M), Long-Term Services Agreement (LTSA), and warranty costs for the proposed
terms. Respondent shall ensure all pricing information is complete and accurately entered in to the “4.
Pricing” tab of the Proposal Entry Form located in the Portal. Incomplete pricing information will be
considered irregular and may be rejected.
6.7. TAXES
Respondents are responsible for the payment of all sales, conveyance, transfer, excise, real estate
transfer, business and occupation, and similar taxes assessed in connection with a proposed
agreement.
6.8. INSURANCE
The insurance requirements that must be met by Respondent are summarized below. This summary is
provided for information only and is subject to revision. If a conflict arises between this summary and
any executed agreement between Respondent and IPC, the executed agreement shall govern.
At its sole cost and expense, Respondent shall maintain (and cause each of its agents, independent
contractors, and Subcontractors at any tier performing any services on the project to maintain) at least
the following insurance:
• Workers’ Compensation Insurance with limits of not less than those required by
applicable statutes.
• Employer’s Liability Insurance. When permitted by law, the insurance policies required
shall contain waivers of the insurer’s subrogation rights against IPC. Respondent shall
reimburse IPC for any costs (including self-insured tax audit assessments) incurred in
the event Respondent maintains an uninsured status within the State of Idaho.
• Business Automobile Liability Insurance.
• Commercial General Liability Insurance applicable to all premises and operations,
including without limitation: (i) bodily injury, (ii) property damage, (iii) contractual
liability coverage covering its obligations of indemnity and defense, (iv) products and
completed operations, (v) independent contractors, and (vi) personal and advertising
injury. Such insurance shall provide for occurrence-based coverage and shall have
such other terms, conditions, and endorsements of coverage as are deemed prudent
by IPC from time to time.
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Page 18
• Professional Liability Insurance or Errors and Omissions Insurance, including without
limitation, coverage for claims of financial loss due to error, act, or omission of
Respondent or Respondents employees, officers, equity owners, subcontractors at any
tier, or agents. Professional Liability Insurance shall be maintained for a minimum of
two-years beyond the date of expiration of the executed agreement or the agreement
is otherwise terminated.
• IP (Intellectual Property/Patent) Insurance covering infringement of copyrights,
trademarks, and patents, and misappropriation of trade secrets.
• Fidelity Insurance naming IPC as Loss Payee, for losses arising out of, or in connection
with, any fraudulent or dishonest acts, including without limitation computer fraud,
committed by Respondent or Respondent’s employees, officers, equity owners,
Subcontractors at any tier, or agents, acting alone or with others, including losses of
property and funds in their care, custody, or control.
• Contractor’s Pollution Liability Insurance. Respondent, and Respondent
subcontractors or their respective agents or employees are performing services under
an executed agreement with environmental hazards maintains a “Claims Made” policy
under this such insurance or its replacement insurance shall have a retroactive date of
no later than the effective date of the agreement. Such insurance policy or its
replacement policy shall provide either a minimum of two-years extended reporting
period coverage after completion of all services, or a period equal to the maximum
time under the State of Idaho statute of limitations existing on the effective date for
potential claims under such insurance, whichever is longer. The policy must also
provide the following:
o Coverage for defense, reimbursement, and indemnity obligations assumed by
Respondent under the executed agreement related to claims, damages,
liabilities, losses, demands, expenses, suits, judgments, penalties, fines and
costs, including without limitation, investigative costs, settlement costs, court
costs at all levels, and attorneys’ and expert witness fees and expenses;
o Coverage for any demands for environmental cleanup costs related to
Respondents services under the executed agreement;
o Coverage for the presence, discharge, dispersal, release or escape of smoke,
vapors, soot, fumes, acids, alkalis, toxic chemicals, liquids or gases, waste
materials or other irritants, contaminants or pollutants, silt or sediment into or
upon land, the atmosphere or any watercourse or body of water (Pollution
Conditions) emanating from or affecting any location, whether or not owned,
leased, occupied or otherwise controlled by IPC, to the extent such Pollution
Conditions are caused by Respondent, its employees, and agents;
o Coverage for bodily injury, sickness, disease, mental anguish or shock sustained
by any person, including death, and medical monitoring;
o Coverage for physical injury to, or destruction of tangible property of, parties
other than the insured including the resulting loss of use and diminution in
value thereof; loss of use, but not diminution in value, of tangible property of
Exhibit No. 1
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parties other than that belonging to the insured that has not been physically
injured or destroyed;
o Coverage for transportation and non-owned disposal site (with no sunset
clause/restricted coverage term) (if applicable);
o Property damage to include natural resources damage; and
o No exclusions for asbestos, lead paint, silica or mold/fungus.
Coverage shall apply to sudden and non-sudden Pollution Conditions, provided such conditions are not
naturally present in the environment in the concentration or amounts discovered, unless such natural
condition(s) are released or dispersed as a result of the performance of covered operations. Respondent
additionally agrees to name IPC as an additional insured and to provide waiver of subrogation against
IPC an to furnish insurance certificates, showing Respondents compliance.
• Cyber Liability, Network Security, Data Breach Protection and/or Similar Privacy
Liability Insurance. In the event that Respondent will have access to any restricted
information of IPC, its clients, customers, employees, prospective employees, or other
third parties, whether protected or not by any local, statutory, federal or other
governing legislation(s) or regulation(s), Respondent shall maintain cyber liability,
network liability, data breach or similar privacy liability insurance covering actual
and/or alleged acts, errors or omissions committed by Respondent, its employees,
contractors or agents. For purposes of this RFP, “Restricted Information” means any
confidential or personal information that is protected by law or policy and that
requires the highest level of access control and security protection, whether in storage
or in transit, including without limitation, personal identity information (PII), protected
health information (PHI), electronic protected health information (ePHI) protected by
Federal Health Insurance Portability and Accountability Act (HIPAA) legislation, credit
card data regulated by the Payment Card Industry (PCI), passport numbers, passwords
providing access to restricted data or resources, information relating to an ongoing
criminal investigation, court-ordered settlement agreements requiring non-disclosure,
information specifically identified by contract as restricted, and other information for
which the degree of adverse effect that may result from unauthorized access or
disclosure is high. Such insurance shall expressly provide coverage for the following
perils up to the full limit of coverage with no sublimit:
o Unauthorized use/access of a computer system or database;
o Defense of any regulatory or governmental action involving a breach of privacy
or similar rights;
o Failure to protect from disclosure Restricted Information;
o Notification and remedial action costs (such as credit monitoring) in the event of
an actual or perceived computer security or privacy breach; and
o Denial of electronic access, electronic infection, and electronic information
damage, whether or not required by law.
Such insurance shall extend to cover damages arising out of any actual or alleged act(s), error(s) or
omission(s) of any individual when acting under Respondent’s supervision, direction, or control. Such
Exhibit No. 1
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Page 20
insurance shall provide coverage on a worldwide basis. Respondent and its insurer(s) shall waive rights
of recovery against IPC for any benefits under Respondents cyber-risk, data breach protection or similar
privacy liability insurance.
• Cargo and Property Insurance. If Respondent, Subcontractor at any tier, or their
respective agents or employees are transporting and/or storing IPC materials or
equipment, Contractor shall provide Cargo Insurance and/or Property Insurance (as
applicable) covering physical loss or damage, naming IPC as Loss Payee, arising out of,
or in connection with, any loss associated with transportation or storage of IPC
equipment or material while in the care, custody, or control of Contractor (or its
Subcontractors at all tiers). The declared value of the Cargo and/or Property Insurance
shall be based on the replacement value of the property in question.
Insurance required shall be primary and non-contributory and:
• Be issued on a U.S. policy by one or more carriers acceptable to IPC and licensed to do
business in the state where services are rendered;
• Except as to Workers’ Compensation Insurance, Employer Liability Insurance, and
Professional Liability Insurance, name IPC as an additional insured or loss payees, as its
interests may appear;
• Not be able to be canceled or materially changed unless IPC is given written notice of
such cancellation or change at least thirty (30) days in advance;
• Provide for severability of interests;
• Waive all right of subrogation against additional insureds and IPC, its members,
officers, employees, agents, and the successors in interest of the foregoing; and
• Shall not be limited to “ongoing” operations. Respondent shall pay for all deductibles.
If approved in advance by IPC in writing, Respondent may use a combination of Umbrella/Excess and
Primary limits of insurance to provide coverage up to the required amount. Upon execution of an
agreement, Contractor shall provide IPC with a certificate of insurance indicating all coverages
required hereunder, and copies of all policies if requested by IPC.
Respondent agrees to carry and keep insurance in full force during the term of any agreements
sufficient to fully protect IPC from all damages, claims, suits and/or judgments including, but not
limited to, errors, omissions, violations, fees and penalties caused or claimed to have been caused by,
or in connection with the performance or failure to perform under the agreements by Respondent,
Respondent’s agents or employees, a Respondent’s Subcontractor(s), or its agents or employees.
Should the Minimum Insurance Requirements of IPC change, the Respondent shall be notified in
writing and Respondent shall have sixty (60) days to meet the new requirements. Should the new
requirements add materially to Respondent’s cost, Respondent may notify IPC and request adjustment
in Respondent’s compensation commensurate with the increase or decrease in Respondent’s cost to
achieve the new requirements.
Exhibit No. 1
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6.9. FINANCIAL AND CREDIT INFORMATION
Respondent must provide a written response and associated documents in response to the
Counterparty Financial Questionnaire. Details are further described in EXHIBIT L - Counterparty
Financial Questionnaire of this RFP.
6.10. STANDARD TERMS AND CONDITIONS AND POWER PURCHASE
AGREEMENT
Respondents must provide IPC with their definitive agreement, complete with applicable terms and
conditions, exhibits, schedules, attachments, and any other supplemental documents proposed as part
of Respondents submittal into this RFP, and for IPC’s review.
Accordingly, IPC is providing Respondents a list of standard terms and conditions and power purchase
agreement that IPC is requesting to be incorporated as part of Respondents proposal (Exhibit E –
Standard Terms and Conditions and Exhibit F – Power Purchase Agreement). Respondents must
provide proposals and pricing consistent and compliant with EXHIBIT E – Standard Terms and
Conditions and Exhibit F – Power Purchase Agreement for the proposed Product and resource type. To
the extent that the validity of a Respondent’s proposal and/or the Respondent’s ability to execute an
agreement is contingent upon material changes to the language in EXHIBIT E – Standard Terms and
Conditions or Exhibit F – Power Purchase Agreement, the Respondent should specifically identify the
terms they propose to change in the form of a redline markup to Exhibit E and Exhibit F, and submit
the redline with its proposal. To the extent that a Respondent wishes to propose changes to Exhibit E
or Exhibit F that, if accepted by IPC, would reduce the Respondent’s proposed pricing the proposal
should specifically identify in the redline such changes and the associated price reduction.
Respondents proposing to sell existing generation facilities must propose in the redline changes to
Exhibit E and Exhibit F (as applicable) of this RFP for the proposed resource type reflecting the terms
and conditions on which their proposal is based. The proposed changes must be specific and include a
detailed explanation and supporting rationale for each. General comments, drafting notes and
footnotes such as “parties to discuss” will be disregarded and not negotiated. Exceptions to the
EXHIBIT E – Standard Terms and Conditions and Exhibit F – Power Purchase Agreement requested by a
Respondent will be reviewed as part of IPC’s qualitative (and quantitative as applicable) evaluation of
the proposal. Proposals which do not include redlines to Exhibit E and Exhibit F, shall be deemed by
IPC as accepting IPC’s Exhibit E- Standard Terms and Conditions and Exhibit F – Power Purchase
Agreement in their current form as included in this RFP.
6.11. EXCEPTIONS TO THE TECHNICAL SPECIFICATIONS
Respondents that propose a resource for IPC ownership must provide proposals and pricing consistent
and compliant with the applicable technical specifications provided as Exhibits to this RFP (“Technical
Specifications”). To the extent the validity of a Respondent’s proposal and/or the Respondent’s ability
to execute an agreement is contingent upon material changes to the language in the Technical
Specifications, the Respondent must specifically identify the specifications it proposes to change in the
form of a redline markup to the Technical Specification and submit the redline with its proposal. To
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Page 22
the extent a Respondent wishes to propose changes to the Technical Specification that, if accepted by
IPC, would reduce the Respondent’s proposed pricing the Respondent should specifically identify in
the redline such changes and the associated price reduction. To the extent practicable, Respondents
should develop exhibits, schedules, attachments and other supplemental documents required by the
Technical Specification in the redline.
The proposed changes must be specific and include a detailed explanation and supporting rationale for
each. General comments, drafting notes and footnotes such as “parties to discuss” will be disregarded
and not negotiated. Exceptions to the Technical Specifications requested by a Respondent will be
reviewed as part of IPC’s qualitative evaluation of the proposal.
6.12. EXCEPTIONS TO THE DRAFT FORM LETTER OF CREDIT
Respondents that propose a resource for IPC ownership must provide proposals and pricing consistent
and compliant with the EXHIBIT M - Draft Form Letter of Credit. To the extent the validity of a
Respondent’s proposal and/or the Respondent’s ability to execute an agreement is contingent upon
material changes to the language in the Draft Form Letter of Credit, the Respondent should specifically
identify the terms they propose to change in the form of a redline markup to EXHIBIT M - Draft Form
Letter of Credit and submit the redline with its proposal. To the extent a Respondent wishes to
propose changes to the Draft Form Letter of Credit that, if accepted by IPC, would reduce the
Respondent’s proposed pricing the proposal should specifically identify in the redline such changes
and the associated price reduction.
The proposed changes must be specific and include a detailed explanation and supporting rationale
for each. General comments, drafting notes and footnotes such as “parties to discuss” will be
disregarded and not negotiated. Exceptions requested by a Respondent will be reviewed as part of
IPC’s qualitative evaluation of the proposal.
6.13. CLARIFICATION OF PROPOSALS
While evaluating a proposal, IPC may request clarification or additional information from the
Respondent about any item in its proposal. Such requests will be sent via the Portal by IPC and the
Respondent must provide a response back to IPC via the Portal within five (5) business days, or IPC
may deem the Respondent to be non-responsive and either suspend or terminate further evaluation
of its proposal. Respondents are encouraged to provide an alternate point of contact to ensure a
timely response to clarification requests.
6.14. ADDENDA TO RFP
Any additional responses required from Respondents as a result of an Addendum to this RFP shall
become part of each proposal. Respondents must acknowledge receipt of and list all Addenda, where
indicated in the Proposal Entry Form.
Exhibit No. 1
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7. Proposal Evaluation, Negotiation and Approval
7.1. EVALUATION PROCESS
The overall proposal evaluation process will consist of initial screens and subsequent qualitative and
quantitative evaluation and ranking processes.
The evaluation process begins with an initial screening to identify and remove from further evaluation
proposals that are incomplete or do not comply with the basic requirements of the Solicitation
(Threshold Screen). Examples of situations where a proposal may fail the Threshold Screen include,
but are not limited to, 1) the proposed Product is not compliant with the Product definitions, 2) a
substantial number of data fields in the Proposal Entry Form are incomplete, 3) key Information
necessary to complete a comprehensive evaluation has not been uploaded.
Proposals that pass the Threshold Screen will be further screened to remove those that would
result in high costs to IPC relative to proposals for the same or similar Product (Initial Cost
Screen). The purpose is to reduce the number of proposals to a number that can be
subsequently evaluated within the staff and time constraints of the Evaluation Team. The
screening will be based on the forecast levelized cost of energy (LCOE) and levelized cost of
capacity (LCOC) calculated from the price, energy, capacity, efficiency, degradation, length of
term and other information quoted in the Proposal and certain other common assumptions
made by IPC.
Proposals that pass the Initial Cost Screen will then enter detailed qualitative and quantitative
evaluation processes that are performed in parallel.
For the quantitative evaluation, information entered in the proposal entry form for each of the
quantitative factors identified in the form will be entered into a production cost simulation
software tool and other costing tools to forecast the capital and operating cost impacts of the
proposal to IPC over a future term. The capacity benefit of a proposal will be based on resource-
specific (ELCC) values, taking into account the resource location, generation shape, characteristics
of the resource and availability. Results from the simulation will be summarized on a net present
value basis, then the proposals will be ranked from highest to lowest net benefits.
For the qualitative evaluation, information entered in the proposal entry form for each of the
qualitative factors identified in the form will be evaluated by one or more subject matter experts
from the Evaluation Team. There are numerous qualitative factors which fall under the general
categories of Project Feasibility, Project Capability, Counterparty Profile and Community
Stewardship. The evaluator will give a qualitative rating to each response, which will then be
scaled to a numeric value, which will then be weighted to result in an overall numeric score for
the factor. The score for each factor will them be summed resulting in an overall numeric
qualitative score for the proposal. The proposals will then be ranked from highest to lowest
qualitative score.
Results of the quantitative and qualitative evaluation processes will then be brought together.
The quantitative rankings will be the primary determinant of which proposals are best. However,
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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Page 24
the qualitative rankings will be examined and may be used to change the quantitative ranking.
For example, if Proposal A has a slightly higher quantitative score than Proposal B, but a
significantly lower qualitative score than Proposal B, then proposal B may be re-ranked above
proposal A in the quantitative ranking. The highest ranked proposals will then be advanced to
shortlisting. During the shortlisting phase, IPC may request shortlist interviews to obtain
additional information about each shortlisted proposal, and may perform additional production
cost simulation of the shortlisted proposals alone or in combination, to select one or more (or no)
proposals for negotiation of an agreement.
7.2. ADDITIONAL RIGHTS
IPC may, in its sole discretion, at any time during the Solicitation:
1. Appoint evaluation committees to review proposals, seek the assistance of outside
technical experts and consultants in proposal evaluation, and seek or obtain data from any
source that has the potential to improve the understanding and evaluation of the
responses to this RFP.
2. Revise and modify, at any time before the Deadline for Proposal Submittal, the factors it
will consider in evaluating proposals and to otherwise revise or expand its evaluation
methodology.
3. Hold interviews and meetings to conduct discussions and exchange correspondence with
either all Respondents or only those with proposals that IPC elects to select for detailed
discussions (Initial Shortlisted Proposals) to seek an improved understanding and
evaluation of an individual Respondent’s proposal.
4. Issue a new RFP.
5. Cancel or withdraw the entire RFP or any part thereof.
7.3. ACCEPTANCE AND REJECTION OF PROPOSALS
IPC is under no obligation to award an agreement after analysis and evaluation of the proposals. IPC
reserves the right to reject any and all proposals, to waive minor formalities and irregularities, and to
evaluate the proposals to determine which, in IPC’s sole judgment, represents the best value for the
Products requested.
7.4. AGREEMENT NEGOTIATIONS
In anticipation of an award, there will be a period of negotiations to finalize the agreement(s) between
the parties. An agreement, including all terms, conditions, exhibits, and attachments must be executed
by both IPC and the successful Respondent in order to create a binding enforceable agreement
between IPC and the successful Respondent.
7.5. EXCLUSIVITY
If and when a proposal is selected for the Final Shortlist, from that date through the date of execution
by both Parties of an agreement, the Respondent and/or its affiliates shall not execute an agreement
Exhibit No. 1
Case No. IPC-E-23-05 E. Hackett, IPC
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with any other party for the sale of the proposed Product(s) such that the Respondent would no
longer be able to timely provide the Products proposed in the proposal.
7.6. PUBLICITY
IPC intends that it and the successful Respondent issue joint public announcements containing
mutually-agreed upon content in the form of press releases, case studies, and/or other materials, ,
upon execution of the agreements. Neither party shall use the name, logo, or any other indicia of the
other party in any public statement, press release, other public relations or marketing materials, the
identity of the other party, or any underlying information with respect to the agreement(s) at any time
without the prior written consent of the other party, which it may withhold in such other party’s sole
discretion. Prior to making any such permitted use, each party shall provide for the other party’s
review and approval any publicity materials. Any and all goodwill from use of IPC’s name, logo, or
indicia will inure to IPC’s sole and exclusive benefit.
7.7. COMMISSION APPROVAL
As stated previously in Section 2.3, effectiveness of an agreement will ultimately be subject to
Commission approval.
7.8. ENTIRE RFP
This RFP and all Exhibits, Attachments, Questionnaires, Forms, and Addenda within the Portal event
are incorporated herein by this reference and represent the final expression of this RFP. Only
information supplied by IPC in writing through the Portal, listed herein, or incorporated by this
reference made in submittal of this RFP shall be used as the basis for the preparation of responses.
Exhibit No. 1
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EXHIBIT A – Information for Qualitative Evaluation
Respondents are directed to the Proposal Entry Form located in the Portal for the detailed
information that must be uploaded to the Portal by Respondents for purposes of the qualitative
evaluation. The required information differs among the product types. Respondents are directed to
the Portal to review all of the specific information related to specific product type(s) and reference
the level of detail that must be provided for each product type.
Exhibit No. 1
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EXHIBIT B – Information for Quantitative Evaluation
Respondents are directed to the Proposal Entry Form located in the Portal for the detailed information
that must be uploaded to the Portal by Respondents for purposes of the quantitative evaluation. The
required information differs among the product types. Respondents are directed to the Portal to
review all of the specific information related to specific product type(s) and reference the level of
detail that must be provided for each product type.
Exhibit No. 1
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EXHIBIT C – Information on Preferred Locations
The following diagram summarizes the preferred locations and points of delivery for Products proposed in response to this RFP. This is provided
for information only. Respondents are directed to the Portal for the most recent version of this information. In the case of conflict between this
information and the information provided in the Portal, the form provided in the Portal shall govern.
Exhibit No. 1
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EXHIBIT D – Information on Most Valuable Hours
The following table illustrates the hours during which capacity and energy are most valuable to IPC for a typical day in each month for the years
2024 and 2025. Proposals that can help meet IPC’s capacity needs during critical hours while reducing surpluses off-peak will benefit in IPC’s
analysis. This is provided for information only. Respondents are directed to the Portal for the most recent version of this information. In the case
of conflict between this information and the information provided in the Portal, the form provided in the Portal shall govern.
Most Valuable Hours
0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
January
February
March
April
May
June
July
August
September
October
November
December
= Critical Hours: These are the critical need hours for Idaho Power's capacity deficit
= Valuable Hours: These are in addition to the critical hours; IPC’s analysis will favor resources that can meet both the critical hours
and the valuable hours
Exhibit No. 1
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EXHIBIT E – Standard Terms and Conditions
Respondents are directed to the Portal for the Standard Terms and Conditions that must be redlined and
uploaded to the Portal.
Exhibit No. 1
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Exhibit F – Power Purchase Agreement
Respondents are directed to the Portal for Power Purchase Agreement that must be redlined and uploaded to
the Portal.
Respondents are directed to the Portal for the Standard Terms and Conditions that must be redlined and
uploaded to the Portal.
Exhibit No. 1
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EXHIBIT G – BESS Technical Specifications
Respondents are directed to the Portal for the BESS Technical Specifications that must be met for a BESS project
offered for IPC ownership.
Exhibit No. 1
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EXHIBIT H – Solar Technical Specifications
Respondents are directed to the Portal for the Solar + Storage Technical Specifications that must be met for a
Solar + Storage project offered for IPC ownership.
Exhibit No. 1
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EXHIBIT I – Wind Technical Specifications
Respondents are directed to the Portal for the Wind Technical Specifications that must be met for a Wind +
Storage project offered for IPC ownership.
Exhibit No. 1
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EXHIBIT J – Gas-Fired Convertible to Hydrogen Specifications
Respondents are directed to the Portal for the Gas-fired Convertible to Hydrogen Technical Specifications that
must be met for a Gas-fired Convertible to Hydrogen resource offered for IPC ownership.
Exhibit No. 1
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EXHIBIT K – Mutual Non-Disclosure Agreement
Respondents are directed to the Portal for the draft form Mutual Non-Disclosure Agreement that must be
executed prior to discussion of IPC specific cyber security requirements.
Exhibit No. 1
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EXHIBIT L - Counterparty Financial Questionnaire
Respondents are directed to the Portal for the Counterparty Financial Questionnaire document for which a
response must be included in any proposal.
Exhibit No. 1
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EXHIBIT M – Draft Form Letter of Credit
Respondents are directed to the Portal for the Draft Form Letter of Credit that must be redlined and submitted
as part of a proposal
Exhibit No. 1
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EXHIBIT N – Effective Load Carrying Capability Factors
The following table summarizes effective load carrying capability (ELCC) factors that IPC has forecasted
consistent with the 2021 IRP1 for various resource types2. These are provided as indicative information only, and
IPC will utilize project-specific data to determine project specific ELCCs as part of the evaluation processes
described in this RFP. The ELCC factors will not impact the actual prices that would be paid to a Respondent if
and when IPC enters an agreement with the Respondent to purchase a proposed Product. This is provided for
information only. Respondents are directed to the Portal for the most recent version of this information. In the
case of conflict between this information and the information provided in the Portal, the form provided in the
Portal shall govern.
Name ELCC
Solar PV 10.20%
Wind 11.15%
Demand Response
TBD -
Program
Specific
Storage - 4-Hour Li Battery 87.50%
Geothermal 95.00%
Storage - 8-Hour Li Battery 97.00%
Solar PV + 4-Hour Li Battery (1:1) 97.00%
Natural Gas - Reciprocating Gas Engine 95.00%
Natural Gas - Combined Cycle Combustion Turbine (CCCT) 95.00%
Small Modular Nuclear Reactor 100.00%
Storage - Pumped Hydro (assumed 12-hr+ duration) 100.00%
Natural Gas - Simple Cycle Combustion Turbine (SCCT) 95.00%
Natural Gas - Aeroderivative 95.00%
1 Idaho Power continues to analyze near-term resource specific ELCC’s for use in the RFP evaluation and may vary from the
table which are provided as reference only.
2 Wind+Storage ELCC - Due to the variability of wind projects based on location, hub height, turbine diameter, etc.,
Wind+Storage projects will be modeled based on project proposal specifics to determine the applicable ELCC.
Exhibit No. 1
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EXHIBIT O – Bid Fee Submittal
Respondents are directed to the Portal for instructions specific to the submittal of the Evaluation Fee to
submitted as part of a proposal
End of Document
Exhibit No. 1
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IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
HACKETT, DI
TESTIMONY
EXHIBIT NO. 2
SEE ATTACHED SPREADSHEET
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
HACKETT, DI
TESTIMONY
EXHIBIT NO. 3
2022 REQUEST FOR PROPOSALS ‐ KEY PRODUCT SPECIFICATIONS
Addendum Product Table: April 12, 2022
Table 2 – Renewable Energy Products
Product 1 2 3 4 5 6 7 8 9
Resource Type Solar PV Wind Geothermal
Product Type Power Purchase Agreement
(PPA)
Asset
Purchase PPA Asset
Purchase PPA Asset Purchase
Ownership Structure Respondent IPC Respondent IPC Respondent IPC
Term
20‐34, 35 years,
IPC Asset
Purchase
35 years n/a
20‐34, 35
years, IPC
Asset
Purchase
35
years n/a
20‐34, 35
years, IPC
Asset
Purchase
35
years n/a
First Delivery On or before 6/1/2024 (for 85 MW 2024 deficit), or 6/1/2025 (for 115 MW 2025 deficit)
Resource Status Existing or proposed new in late‐stage development with pending or executed Large Generation Interconnection
Application (LGIA)/ Small Generation Interconnection Application (SGIA)
Design Life 35 years minimum
Capacity Minimum 100 MW ac nameplate or minimum 40 MW ac capacity after application of effective load carrying capability
(ELCC) factor1
Interconnection IPC Transmission System or transmission system of adjacent host utility
Delivery Point Within the boundary of the IPC Balancing Authority (BA) Area, or outside with all necessary transmission rights to the BA
Storage Duration n/a
Storage Cycles n/a
Other A Proposal for a 20‐34 year PPA must include pricing for each of the alternatives shown under Term section of this Table 2.
A resource of less than the specified capacity minimums that offers unique benefits may be proposed
1 Refer to Exhibit N for ELCC factors
Exhibit No. 3
Case No. IPC-E-23-05 E. Hackett, IPC
Page 1 of 3
Table 3 – Storage Products
Product 10 10.a 11 12 13 14 15 16 17 18 19
Resource Type Battery Energy Storage
(BESS) Solar + BESS Wind + BESS Long Duration Storage
Product Type Asset
Purchase
Battery
Storage
Agreement
Asset
Purchase
Solar PPA
20‐34 Years
+ BESS
Asset
Purchase
Solar PPA
35 Years +
BESS Asset
Purchase
Asset
Purchase
Wind PPA
20‐34 years
+ BESS
Asset
Purchase
Wind PPA
35 years +
BESS Asset
Purchase
PPA Asset
Purchase
Ownership
Structure IPC Respondent IPC
Solar:
Respondent
BESS: IPC
Solar:
Respondent
BESS: IPC
IPC
Wind:
Respondent
Storage:
IPC
Wind:
Respondent
Storage: IPC
Respondent IPC
Term n/a 20 years n/a
20‐34
years, 35
years, IPC
Asset
Purchase
35 years n/a
20‐34
years, 35
years, IPC
Asset
Purchase
35 years
20‐34
years, 35
years,
IPC Asset
Purchase
35
years n/a
First Delivery On or before 6/1/2024
for Product 10.a
On or before 6/1/2024 (for 85 MW 2024 deficit), or 6/1/2025 (for 115 MW 2025 deficit)
Resource
Status
Existing or proposed new in late‐stage development with pending or executed LGIA/SGIA
Design Life 20 years 20 years 35 years
Capacity Minimum 40 MW ac capacity after application of ELCC factor1
Interconnection IPC Transmission System or transmission system of adjacent host utility
Delivery Point Within the boundary of the IPC Balancing Authority (BA) Area, or outside with all necessary transmission rights to the BA
Storage
Duration
4+ hours 6+ hours
Storage Cycles 1+ cycles per day up to 365 cycles per year
Other
A proposal for an Asset
Purchase may also
include pricing for the
alternative Battery
Storage Agreement.
A proposal for a 20‐34 year PPA must include pricing for each of the alternatives show under the Term section of
this Table 3. Storage combined with a renewable must be chargeable from the grid by IPC after expiration of the
tax benefit recapture period, if applicable. A solar or wind resource of less than the specified capacity minimums
that offers unique benefits may be proposed.
1 Refer to Exhibit N for ELCC factors
Exhibit No. 3
Case No. IPC-E-23-05 E. Hackett, IPC
Page 2 of 3
Table 4 – Other Products
Product 20 21 22 23
Resource Type Gas‐fired Convertible to Hydrogen Demand Response
Product Type PPA Asset Purchase Program
Ownership Structure Respondent IPC Respondent
Term
20‐34 years, 35
years, IPC Asset
Purchase
35 years n/a 5 year maximum
First Delivery On or before 6/1/2024 (for 85 MW 2024 deficit), or 6/1/2025 (for 115 MW 2025 deficit)
Resource Status Existing or proposed new in late‐stage development with
pending or executed LGIA/SGIA n/a
Design Life 50 years n/a
Capacity Minimum 40 MW ac capacity after application of ELCC factor Minimum 5 MW ac delivered after applications of ELCC factor
Interconnection IPC Transmission System or Transmission System of adjacent
host utility n/a
Delivery Point Within the boundary of the IPC Balancing Authority (BA) Area,
or outside with all necessary transmission rights to the BA n/a
Storage Duration n/a
Storage Cycles n/a
Other
A Proposal for a 20‐34 year PPA must include pricing for each
of the alternatives shown under Term section of this Table 4.
Conversion must be achievable within 10 years and costs
must be accounted for in submittal.
Must meet cost effectiveness test based on utility cost test (UCT).
Capacity must be dispatchable based on day ahead notification
minimum with preference for shorter notice dispatch (e.g. 10 minute
to 1 hour ahead)
New programs must be differentiated from existing programs and
exclude existing IPC demand response participants (not overlap) or
provide details of how the new program would complement existing
IPC programs.
New programs must demonstrate how marketing and customer
participation will not be detrimental or cause undue confusion to IPC
customers.
Respondents must have a demonstrated record of program
success.
Exhibit No. 3
Case No. IPC-E-23-05 E. Hackett, IPC
Page 3 of 3
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
CONFIDENTIAL
HACKETT, DI
TESTIMONY
EXHIBIT NO. 4
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
CONFIDENTIAL
HACKETT, DI
TESTIMONY
EXHIBIT NO. 5
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-05
IDAHO POWER COMPANY
CONFIDENTIAL
HACKETT, DI
TESTIMONY
EXHIBIT NO. 6