HomeMy WebLinkAbout20230217DirectJEllsworth.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
JARED L. ELLSWORTH
RECEIVED
2023 February 17, 4:22PM
IDAHO PUBLIC
UTILITIES COMMISSION
ELLSWORTH, DI 1
Idaho Power Company
Q. Please state your name, business address, and 1
present position with Idaho Power Company (“Idaho Power” or 2
“Company”). 3
A. My name is Jared L. Ellsworth and my business 4
address is 1221 West Idaho Street, Boise, Idaho 83702. I 5
am employed by Idaho Power as the Transmission, 6
Distribution & Resource Planning Director for the Planning, 7
Engineering & Construction Department. 8
Q. Please describe your educational background. 9
A. I graduated in 2004 and 2010 from the 10
University of Idaho in Moscow, Idaho, receiving a Bachelor 11
of Science Degree and Master of Engineering Degree in 12
Electrical Engineering, respectively. I am a licensed 13
professional engineer in the State of Idaho. 14
Q. Please describe your work experience with 15
Idaho Power. 16
A. In 2004, I was hired as a Distribution 17
Planning engineer in the Company’s Delivery Planning 18
department. In 2007, I moved into the System Planning 19
department, where my principal responsibilities included 20
planning for bulk high-voltage transmission and substation 21
projects, generation interconnection projects, and North 22
American Electric Reliability Corporation’s (“NERC”) 23
reliability compliance standards. I transitioned into the 24
Transmission Policy & Development group with a similar 25
ELLSWORTH, DI 2
Idaho Power Company
role, and in 2013, I spent a year cross-training with the 1
Company’s Load Serving Operations group. In 2014, I was 2
promoted to Engineering Leader of the Transmission Policy & 3
Development department and assumed leadership of the System 4
Planning group in 2018. In early 2020, I was promoted into 5
my current role as the Transmission, Distribution and 6
Resource Planning Director. I am currently responsible for 7
the planning of the Company’s wires and resources to 8
continue to provide customers with cost-effective and 9
reliable electrical service. 10
Q. What is the purpose of your testimony in this 11
case? 12
A. The purpose of my testimony is to inform the 13
Idaho Public Utilities Commission (“Commission”) of the 14
Company’s need for new generation capacity by 2024 based 15
upon the load and resource balance utilized in the 2021 16
Integrated Resource Plan (“IRP”) and subsequently further 17
enhanced as part of the development of the 2023 IRP. I will 18
describe the modifications to the load and resource inputs 19
of the load and resource balance and the resulting 20
identification of Idaho Power’s 2024 capacity deficit. 21
Finally, I will provide support for the acquisition of new 22
resources to address identified near-term peak capacity 23
needs in 2024. 24
25
ELLSWORTH, DI 3
Idaho Power Company
I. BACKGROUND 1
Q. What is the goal of the IRP? 2
A. The goal of the IRP is to ensure: (1) Idaho 3
Power’s system has sufficient resources to reliably serve 4
customer demand and flexible capacity needs over a 20-year 5
planning period, (2) the selected resource portfolio 6
balances cost, risk, and environmental concerns, (3) 7
balanced treatment is given to both supply-side resources 8
and demand-side measures, and (4) the public is involved in 9
the planning process in a meaningful way. For reliability 10
purposes, in the 2021 IRP the Company planned its resource 11
portfolio to have a Loss of Load Expectation (“LOLE”) of 12
0.05 event-days per year or better (i.e. less than one 13
resource adequacy related outage event-day in 20 years). 14
Q. Please explain the Loss of Load Expectation. 15
A. The LOLE is a statistical measure of a 16
system’s resource adequacy, describing the expected number 17
of days per year that a system would be unable to meet 18
demand. In the 2021 IRP, Idaho Power planned to meet a 19
reliability threshold of 0.05 event-days per year, or 20
better, which represents one resource adequacy related 21
outage event-day, or less, in 20 years. The Company 22
utilizes test years, based on historical data, to calculate 23
the LOLE of any given year. Given Idaho Power’s dependence 24
on its hydro system, which fluctuates with annual water 25
ELLSWORTH, DI 4
Idaho Power Company
conditions, and the increased frequency of extreme events, 1
in the 2021 IRP the Company aligned its resource adequacy 2
methodology with the Northwest Power and Conservation 3
Council (“NWPCC”). The calculation of a system LOLE is 4
complex, and many forecasting modeling software do not take 5
a LOLE value as a direct input; therefore, the Company 6
developed an internal tool which utilizes the LOLE 7
methodology to produce outputs that can be converted and 8
applied to a tabulated load and resource balance for the 9
purposes of long-term planning. 10
Q. Please explain the “load and resource 11
balance.” 12
A. The load and resource balance is the Company’s 13
tabulated plan that identifies resource deficiencies during 14
the 20-year IRP planning horizon. It helps ensure Idaho 15
Power has sufficient resources to meet projected customer 16
demand including a margin to account for extreme 17
conditions, reserves, and resource outages, and is checked 18
against, and derived to adhere to, the LOLE threshold of 19
0.05 days per year. It is critical when comparing future 20
resource portfolios that each plan achieves at least a base 21
reliability threshold. 22
Q. How is the resulting resource sufficiency or 23
deficiency determined through the load and resource 24
balance? 25
ELLSWORTH, DI 5
Idaho Power Company
A. At a high level, the load and resource balance 1
incorporates the expected availability of Idaho Power’s 2
existing resources, comparing the total output to the 3
Company’s forecasted load, and illustrates the resulting 4
capacity length or deficit. This will identify the 5
Company’s first resource need date, or the point at which 6
Idaho Power’s reliability requirements may not be met. 7
Q. How is the expected availability of the 8
Company’s existing resources determined? 9
A. The availability of existing resources, 10
including Public Utility Regulatory Policies Act (“PURPA”) 11
projects, Power Purchase Agreements (“PPA”), hydro, coal, 12
gas, demand response, and market purchases, is determined 13
using a number of factors such as expected stream flows, 14
plant run times, forced outages, historical performance, 15
and transmission import capability, among other 16
considerations. 17
Q. How is the load forecast determined? 18
A. Each year, the Company prepares a forecast of 19
sales and demand of electricity based on a combination of 20
historical system data and trends in electricity usage 21
along with numerous external economic and demographic 22
factors. The anticipated average load and anticipated 23
peak-hour demand forecast represent Idaho Power’s most 24
probable outcome for load requirements during the planning 25
ELLSWORTH, DI 6
Idaho Power Company
period. The difference between the expected availability 1
of the Company’s existing resources and the forecasted load 2
is the resulting capacity length or deficit. 3
Q. What have previous load and resource balance 4
results indicated with respect to Idaho Power’s resource 5
sufficiency? 6
A. The Company has been generally resource-7
sufficient since the addition of the Langley Gulch natural-8
gas fired power plant almost a decade ago until recently. 9
The load and resource balance from the Second Amended 2019 10
IRP did not show a capacity deficiency occurring until the 11
summer of 2028. However, several converging factors, 12
including limited third-party transmission capacity, load 13
growth, and a decline in the peak serving effectiveness of 14
certain supply-side and demand-side resources have caused 15
Idaho Power to rapidly move to a near-term capacity 16
deficiency starting in 2023. These dynamic circumstances 17
led the Company to immediately file a request for a 18
Certificate of Public Convenience and Necessity (“CPCN”) to 19
acquire resources to be online in 20231, and Idaho Power 20
expects to acquire additional resources each year 21
thereafter through (at least) 2027, as discussed in the 22
Company’s request in this case. 23
24
1 Case No. IPC-E-22-13.
ELLSWORTH, DI 7
Idaho Power Company
II. 2021 IRP LOAD AND RESOURCE BALANCE 1
Q. When did Idaho Power identify that there was a 2
resource deficiency starting in 2023? 3
A. The Company first identified a resource 4
deficiency beginning in 2023 in the spring of 2021 while 5
refreshing the load and resource balance during the 6
development of a Valmy Unit 2 exit analysis, as directed by 7
the Commission in Order No. 34349, Idaho Power’s request to 8
update rates to reflect the accelerated depreciation 9
associated with an early exit from coal-fired operations at 10
Valmy, Case No. IPC-E-19-08. Following the filing of the 11
Second Amended 2019 IRP, in the first quarter of 2021, 12
Idaho Power began preparing the required Valmy Unit 2 exit 13
analysis, which included an evaluation of system 14
reliability. This analysis was performed simultaneously 15
with preparation of the 2021 IRP, and the refreshed load 16
and resource balance was further refined through the 17
remainder of the development of the 2021 IRP. 18
Q. What drove the rapid shift from resource 19
sufficiency to a resource deficiency at this time? 20
A. Several factors contributed to the change in 21
the load and resource balance at this time, including 22
significant current third-party transmission constraints 23
limiting wholesale market import purchases at peak, the 24
ability of demand response programs to meet load during the 25
ELLSWORTH, DI 8
Idaho Power Company
highest peak hours, planning reserve margin determinations 1
and methodology modernization, and load growth exceeding 2
previously forecasted expectations. The net change between 3
the Second Amended 2019 IRP and the updated load and 4
resource balance utilized for the Valmy Unit 2 exit 5
analysis was a reduction in over 500 MW in available 6
capacity each July during the 2022 through 2025 period. 7
Q. Were similar adjustments made to the load and 8
resource balance used in the 2021 IRP? 9
A. Yes. The load and resource balance used for 10
the 2021 IRP was updated to include the most up-to-date 11
resource and load inputs, as is standard when developing 12
the load and resource balance as part of the IRP process. 13
On the resource side, the Company applied the adjusted 14
transmission assumptions and made further enhancements to 15
the capacity contribution of variable energy resources 16
utilized to meet reliability requirements, using the LOLE 17
method. 18
Q. What were the adjusted transmission 19
assumptions used in preparation of the load and resource 20
balance prepared for the 2021 IRP? 21
A. As I mentioned earlier, the Company identified 22
market purchase assumptions that required changes, 23
primarily as a result of new and evolving market conditions 24
due to a constrained transmission market. The changes 25
ELLSWORTH, DI 9
Idaho Power Company
resulted in a net reduction to transmission capacity 1
availability. Because the transmission market continues to 2
be constrained, and is expected to remain constrained, the 3
load and resource balance used in the 2021 IRP included 4
adjusted transmission assumptions to reflect those new 5
market conditions. 6
Q. You indicated Idaho Power made enhancements to 7
the capacity contribution of variable energy resources 8
utilized to meet reliability requirements as part of the 9
load and resource balance update for the 2021 IRP. What 10
enhancements were made? 11
A. For reliability purposes, in the 2021 IRP the 12
Company planned its resource portfolio to have a LOLE of 13
0.05 event-days per year or better (i.e. less than one 14
resource adequacy related outage event-day in 20 years). 15
Aside from taking a more granular hourly approach, the LOLE 16
method can also be used to evaluate the capability of 17
existing resources to meet capacity need through the 18
determination of Effective Load Carrying Capability 19
(“ELCC”). 20
Q. Did the application of ELCC values result in 21
any significant changes to the contributing capacity of 22
Idaho Power’s existing resources? 23
A. Yes. When analyzing Idaho Power’s system on a 24
probabilistic hour-by-hour basis, the results indicated 25
ELLSWORTH, DI 10
Idaho Power Company
that the capacity contribution of the demand response 1
programs under the changing dynamics of Idaho Power’s 2
system was significantly lower than previously assumed. 3
This is primarily the result of increased solar resources 4
on the Company’s system pushing net peak load hours outside 5
the longstanding demand response program dispatch window of 6
1 PM to 9 PM. As a result, Idaho Power filed a request for 7
modifications to its demand response programs that are 8
designed to make the programs more effective at meeting 9
system needs. On March 4, 2022, the Commission issued Order 10
No. 35336, approving Idaho Power’s proposed modifications 11
to the demand response programs, effective for the 2022 12
demand response season. 13
Q. What resource potential did the Company assume 14
demand response provides as part of the load and resource 15
balance used in the 2021 IRP? 16
A. With an assumed reduction in participation 17
beginning in 2022 as a result of the demand response 18
program modifications, the 380 MW nameplate capacity was 19
adjusted to 300 MW beginning in 2022 for IRP modeling 20
purposes. The estimated 2021 IRP ELCC of the modified 21
demand response portfolio was 58.5 percent, or 22
approximately 176 MW. For comparison, in Case No. IPC-E-21-23
32, Idaho Power calculated the increase in capacity 24
contribution from the prior demand response portfolio 25
ELLSWORTH, DI 11
Idaho Power Company
parameters to the modified demand response portfolio 1
parameters to be 148 MW. 2
Q. What was the resulting capacity deficiency 3
identified in the load and resource balance prepared for 4
the 2021 IRP? 5
A. The resulting capacity deficiency was 6
approximately 101 MW in 2023, 186 MW in 2024, and 311 MW in 7
2025, which led to Idaho Power’s request for a CPCN in Case 8
No. IPC-E-22-13 for the 2023 resource procurement. 9
III. LOAD AND RESOURCE UPDATE 10
Q. Since the completion of the 2021 IRP, has the 11
Company continued to monitor other factors that could 12
influence the load and resource balance, and by extension, 13
Idaho Power’s resource need? 14
A. Yes. While the load and resource balance 15
prepared for an IRP is the primary source of information 16
used to inform resource procurement decisions, the Company 17
also recognizes that during the near-term resource 18
decision-making phase, the capacity deficit period can be 19
very fluid. As a result, Idaho Power continually evaluates 20
the load and resource balance to consider near-term known 21
changes, operational enhancements, limitations, or 22
constraints on the existing system, if any, to adequately 23
inform resource needs today. In the face of growing loads, 24
Idaho Power is also keenly focused on current supply chain 25
ELLSWORTH, DI 12
Idaho Power Company
challenges, which requires Idaho Power to constantly 1
monitor resource needs and respond with added urgency. 2
Q. As part of this near-term evaluation, what 3
near-term known changes did the Company identify as having 4
the potential to impact the need for new resources in 2024? 5
A. First, Idaho Power included the most up-to-6
date load and resource inputs. The Company’s service area 7
continues to experience very high load growth; in response, 8
the load forecast was updated and implemented as soon as it 9
became readily available. In Case No. IPC-E-21-43, 10
Commission Staff requested that Idaho Power change the LOLE 11
threshold to 0.1 event-days per year and increase the load 12
forecast for future analyses; the Company has since 13
utilized a 70th percentile peak load forecast, which for 14
2024 shows an increase of an expected 33 MW as compared to 15
the 50th percentile peak load forecast utilized in the 2021 16
IRP. The increase is partially due to recent economic 17
activity. 18
Q. What modifications were made to the resource 19
inputs included in the revised load and resource balance? 20
A. Changes to the resource inputs both increased 21
and decreased the resulting capacity deficiency of the 22
revised load and resource balance. There were four 23
resource additions anticipated in 2023 that reduce the 24
previously identified capacity deficit in 2024: (1) the 25
ELLSWORTH, DI 13
Idaho Power Company
addition of battery storage resources, (2) new distribution 1
substation battery storage systems, (3) upgrades at the 2
Company’s peaking gas plants, and (4) the impact of the 3
demand response program modifications to its effectiveness 4
at meeting the Company’s capacity need. 5
First, the Company added as new resources the Black 6
Mesa project, a 40 MW solar photovoltaic (“PV”) PPA in 7
combination with a 40 MW of four-hour duration battery 8
storage, and the Hemingway project, a Company-owned 80 MW 9
four-hour duration battery storage facility, both of which 10
are expected to be in service in 2023. In addition, the 11
Company is installing a total of 11 MW of four-hour 12
duration battery storage beginning in summer 2023 at 13
various distribution substations that will defer 14
transformer upgrades and coincidently effectively reduce 15
system demand during peak hours. Next, an approximate 20 MW 16
of capacity was added to Idaho Power’s existing resources 17
to reflect the cost-effective upgrades at two gas plants, 18
which is expected to occur prior to the beginning of the 19
summer of 2023. Finally, utilizing participation data from 20
the 2022 demand response season, Idaho Power increased the 21
nameplate of the demand response portfolio by 20 MW. 22
Q. What updates to the resource inputs increased 23
the 2024 capacity deficiency? 24
ELLSWORTH, DI 14
Idaho Power Company
A. There was one adjustment to the resource 1
inputs that increased the 2024 capacity deficiency: a 2
planned refurbishment of one hydro unit at the American 3
Falls facility will reduce the overall resource 4
availability by approximately 30 MW during the summer of 5
2024. 6
Q. Were any adjustments made to the transmission 7
or market purchase assumptions to reflect changes since 8
preparation of the load and resource balance for the 2021 9
IRP? 10
A. Yes. First, as explained in Case No. IPC-E-22-11
13, in late 2021, an opportunity arose for the Company to 12
purchase energy. On December 16, 2021, Idaho Power 13
executed an agreement for the delivery of 76 MW to Idaho 14
Power’s border, for the months June through September 2022 15
through 2024, seven days a week during heavy load hours, 16
reducing the projected capacity deficit identified in the 17
load and resource balance for 2023 and 2024. This short-18
term purchase only has the effect of deferring, not 19
eliminating, the growing resource need. In addition, the 20
Company reduced the resource availability associated with 21
the capacity benefit margin (“CBM”) of 330 MW to 200 MW. 22
Q. What is CBM? 23
A. The North American Electric Reliability 24
Corporation (“NERC”) defines CBM as: 25
ELLSWORTH, DI 15
Idaho Power Company
“The amount of firm transmission transfer 1
capability preserved by the transmission 2
provider for Load-Serving Entities (“LSEs”), 3
whose loads are located on that Transmission 4
Service Provider’s system, to enable access by 5
the LSEs to generation from interconnected 6
systems to meet generation reliability 7
requirements. Preservation of CBM for an LSE 8
allows that entity to reduce its installed 9
generating capacity below that which may 10
otherwise have been necessary without 11
interconnections to meet its generation 12
reliability requirements.” 13
Including CBM within the load and resource balance 14
recognizes this held transmission capacity allows Idaho 15
Power to reduce its installed generation capacity to meet 16
reliability requirements under emergency conditions. As an 17
example, if an energy emergency is declared following the 18
loss of multiple Idaho Power network resources, CBM 19
transmission capacity could be utilized to fill the 20
resource capacity need via market purchases. Effectively, 21
Idaho Power considers CBM a reserve resource and applies 22
credit in the load and resource balance. 23
Q. Why did the Company reduce CBM’s capacity 24
availability as part of the load and resource balance 25
computation? 26
A. There were two primary reasons for the 27
reduction in CBM: (1) the Company is preparing for its 28
future non-binding participation in the Western Resource 29
Adequacy Program (“WRAP”) and CBM will not have similar 30
value in that program, and (2) conducted evaluation of the 31
ELLSWORTH, DI 16
Idaho Power Company
ability to acquire transmission to the market during 1
emergency conditions. 2
Q. What is the WRAP? 3
A. The WRAP will deliver a region-wide approach 4
for assessing and addressing resource adequacy and is an 5
important step forward for reliability in the region. It 6
started at the request of many in the industry who were 7
concerned about the issue of resource adequacy in the west. 8
Q. How does the WRAP affect the Company’s 9
transmission assumption associated with CBM? 10
A. When evaluating resource adequacy planning 11
requirements under the WRAP, quantification of firm 12
resources will not allow for the inclusion of CBM to 13
demonstrate adequacy. For Idaho Power to meet the WRAP 14
forward showing requirements, have access to the program, 15
and avoid penalties, the Company must acquire firm 16
resources on firm transmission well in advance of each 17
season. CBM, by definition, is only available as firm 18
transmission when the Company is in an energy emergency, 19
and therefore cannot be utilized for WRAP forward showing 20
purposes. However, the Company believes participation in 21
the WRAP will benefit Idaho Power and its customers. With 22
coordination and visibility across participants, the WRAP 23
paints a more accurate, regional picture of resource needs 24
and supply. Participants in the WRAP benefit from 25
ELLSWORTH, DI 17
Idaho Power Company
reliability assurance through collaboration, taking 1
advantage of operating efficiencies, diversity, and the 2
sharing of pooled resources. 3
Q. If CBM cannot be used in the WRAP, why is 4
Idaho Power reducing CBM from 330 MW to 200 MW instead of 5
reducing CBM from 330 MW to 0 MW? 6
A. The Company is taking an incremental approach 7
to changing assumptions associated with the reliability 8
benefits provided by CBM. As discussed earlier, the WRAP is 9
only one of two major considerations. The WRAP program will 10
not be binding until approximately the summer of 2027, and 11
there remains uncertainty related to the load obligations 12
Idaho Power will be required to meet in the WRAP program, 13
and the credit the Company will receive for its resources 14
in the WRAP program. Idaho Power will continue to consider 15
the transmission assumptions associated with CBM in the 16
load and resource balance as the WRAP program matures. 17
The second major consideration to CBM is whether it 18
enhances the Company’s ability to recover from a major 19
unplanned disturbance. Following such a disturbance, the 20
Company can utilize its CBM capacity to bring in reserves 21
for one hour, and in that hour, Idaho Power must acquire 22
capacity from the market, and the transmission between the 23
capacity resource or market hub and the Company’s 24
transmission system, to continue to utilize CBM. 25
ELLSWORTH, DI 18
Idaho Power Company
Q. What are the results of Idaho Power’s 1
evaluation of transmission acquisition under emergency 2
conditions? 3
A. The Company believes that acquiring 330 MW in 4
an emergency situation may not be possible with current 5
transmission constraints, especially during regional 6
extreme weather events. As evidenced during recent energy 7
emergency events resulting from extreme weather in the 8
region, increased demand that cannot be met with local 9
generation results in strain on the interconnected 10
transmission system. Understanding the importance of 11
transmission availability during times of high electricity 12
demand, entities have reserved transmission capacity across 13
the west, including just outside the Company’s border, 14
significantly limiting Idaho Power’s access to market hubs. 15
The Company’s own transmission service queue was 16
flooded with multi-year requests with third-party marketing 17
firms looking to move energy from Mid-C across Idaho 18
Power’s transmission system to the south. These 19
transmission service requests at the Company’s borders have 20
added to an already constrained transmission market 21
limiting the Company’s access to Mid-C. Last minute 22
transmission acquisition under emergency conditions between 23
the market and Idaho Power’s border have not been 24
ELLSWORTH, DI 19
Idaho Power Company
consistently available providing further support that an 1
adjustment to CBM is appropriate. 2
Put another way, in the event of an energy 3
emergency, the Company will be able to utilize available 4
transmission within its borders; however, there may not be 5
available transmission between Idaho Power’s border and the 6
Mid-C market given the new transmission constraints. The 7
transmission constraint issue may be short term. Because 8
the Boardman to Hemingway project will create incremental 9
transmission capacity between Idaho Power and the Mid-C 10
market, Idaho Power will continue to evaluate CBM benefits 11
as part of resource planning in the future. 12
Given Idaho Power’s movement towards WRAP, the 13
certainty that the WRAP program will assign no resource 14
adequacy value to CBM, and the uncertainty of being able to 15
access emergency capacity resources when the Company is in 16
an energy emergency (the purpose of CBM), Idaho Power has 17
decided to reduce its reliance on CBM from 330 MW to 200 MW 18
for resource adequacy planning purposes. The Company will 19
continue to evaluate CBM’s reliability benefits and 20
effectiveness in future IRPs. 21
Q. Were there any additional updates made to the 22
load and resource inputs? 23
A. No. However, additional enhancements were made 24
to the Company’s reliability evaluation in preparation for 25
ELLSWORTH, DI 20
Idaho Power Company
the 2023 IRP, currently under development. First, Idaho 1
Power adjusted the Company’s resource capacities to account 2
for Equivalent Forced Outage Rates during Demand (“EFORd”) 3
using a 5-year rolling average from the NERC Generation 4
Availability Data System (“GADS”). The updated 5-year 5
rolling average EFORd values will better reflect industry 6
average generation resource performance data and resulting 7
outage rates. Second, the Company adjusted the LOLE 8
threshold from the 2021 IRP’s 0.05 event-days per year to 9
0.1 event-days per year, following Commission Staff’s 10
recommendation in their comments filed in Case No. IPC-E-11
21-43, which recommended a change in both the LOLE 12
threshold and load forecast percentile. These enhancements 13
are being made as part of the load and resource balance 14
being developed for the 2023 IRP. 15
Q. Based on your evaluation of the near-term 16
factors having the potential to impact the load and 17
resource balance for 2024, what is your estimate of the 18
resulting capacity length or deficit? 19
A. While procurement of 120 MW of dispatchable 20
energy storage addressed the 2023 capacity deficits, and 21
reduced the 2024 deficit, a 2024 capacity deficit still 22
exists. Following updates to the load and resource inputs, 23
including the new 2023 resources, and enhancements to the 24
calculation of reliability thresholds since completion of 25
ELLSWORTH, DI 21
Idaho Power Company
the load and resource balance used for the 2021 IRP, the 1
2024 capacity deficiency has decreased from 186 MW to 2
approximately 103 MW. 3
IV. MEETING THE CAPACITY DEFICIENCY 4
Q. Has Idaho Power taken any actions to acquire 5
resources to meet the 2024 capacity deficit? 6
A. Yes. Under Idaho law, Idaho Power has an 7
obligation to provide adequate, efficient, just, and 8
reasonable service on a nondiscriminatory basis to all 9
those that request it within its certificated service area.2 10
In order to meet its obligations to reliably serve customer 11
load, and given the extremely short turn-around to 12
construct a resource to meet the first deficit in the 13
summer of 2023, particularly in the midst of supply chain 14
disruption, ongoing COVID-19 impacts, and constraints in 15
the industry and in ancillary industries, on June 30, 2021 16
the Company conducted a competitive solicitation through a 17
Request for Proposals (“RFP”) seeking to acquire up to 80 18
MW of peak capacity resources to meet the 2023 capacity 19
deficit - seeking projects to be online by June of 2023 20
(“2021 RFP”). As presented in Case No. IPC-E-22-13 for 21
which the Commission granted a CPCN with Order No. 35643, 22
the RFP process resulted in the procurement of 120 MW of 23
dispatchable four-hour duration energy storage as well as 24
2 Idaho Code §§ 61-302, 61-315, 61-507.
ELLSWORTH, DI 22
Idaho Power Company
execution of a 20-year PPA for 40 MW of solar, all of which 1
were necessary to adequately address 2023 capacity 2
deficits. However, the acquisition will not completely 3
satisfy the previously identified capacity deficiencies in 4
2024. 5
Q. What actions did Idaho Power take to satisfy 6
the 2024 capacity deficiency? 7
A. As indicated by in Order No. 35643, Idaho 8
Power is responsible for planning and managing its load and 9
resource portfolio and the Commission expects “the Company 10
to closely monitor its projected capacity needs going 11
forward and to act proactively to ensure a robust RFP 12
process can be completed.”3 Therefore, similar to the RFP 13
issued to address the 2023 deficiency, given the short 14
turn-around to construct a resource to meet the deficit in 15
the summer of 2024, on December 30, 2021, the Company 16
conducted a competitive solicitation through an RFP seeking 17
to acquire energy and capacity to help meet Idaho Power’s 18
previously identified capacity needs of 85 MW in 2024 and 19
an incremental 115 MW in 2025 (“2022 RFP”). As detailed in 20
Company witness Mr. Hackett’s testimony, the RFP process 21
resulted in the selection of a 100 MW solar PV plus 60 MW 22
four-hour duration energy storage project, consisting of a 23
25-year PPA associated with a 100 MW solar PV facility that 24
3 Case No. IPC-E-22-13, Order No. 35643, p. 13.
ELLSWORTH, DI 23
Idaho Power Company
supplies energy to the Company’s system combined with an 1
Idaho Power-owned 60 MW four-hour duration battery storage 2
facility. 3
Q. Will the combined 100 MW solar PV plus 60 MW 4
four-hour duration energy storage project address the near-5
term capacity deficit in 2024? 6
A. No. Evaluation of the reliability given 2024 7
forecasted load and generation, including the 100 MW solar 8
PV plus 60 MW four-hour duration energy storage project, 9
results in a remaining capacity deficit of 7 MW. To ensure 10
the Company is able to continue to provide safe, reliable 11
service to its customers in 2024, and as evidenced by the 12
fluidity of the load and resource balance recently, an 13
additional Idaho Power-owned 12 MW four-hour duration 14
energy storage project was least-cost/least-risk and 15
selected as part of the RFP process. 16
Q. Do you believe there is sufficient support for 17
the procurement of the PPA and the 72 MW of four-hour 18
duration battery storage resources to be online in 2024? 19
A. Yes, I do. The two acquisitions were pursued 20
and procured as a least cost/least risk method of meeting 21
the 2024 capacity deficits identified in the Company’s 2021 22
IRP and subsequently with the results of the revised load 23
and resource balance. The fluidity of the load and resource 24
ELLSWORTH, DI 24
Idaho Power Company
balance and continued high load growth further supports 1
this resource procurement. 2
V. CONCLUSION 3
Q. Please summarize your testimony. 4
A. Idaho Power’s most recently updated load and 5
resource balance has identified a 2024 capacity need of 103 6
MW. In response to this resource need, the Company has 7
executed a 100 MW solar PV PPA and agreements to procure 72 8
MW of four-hour duration battery storage resources to 9
satisfy the identified capacity need in 2024. 10
Q. Does this complete your testimony? 11
A. Yes, it does. 12
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25
ELLSWORTH, DI 25
Idaho Power Company
DECLARATION OF JARED L. ELLSWORTH 1
I, Jared L. Ellsworth, declare under penalty of 2
perjury under the laws of the state of Idaho: 3
1. My name is Jared L. Ellsworth. I am 4
employed by Idaho Power Company as the Transmission, 5
Distribution & Resource Planning Director for the Planning, 6
Engineering & Construction Department. 7
2. On behalf of Idaho Power, I present this 8
pre-filed direct testimony in this matter. 9
3. To the best of my knowledge, my pre-filed 10
direct testimony is 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