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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. ) ) ) ) ) ) ) ) ) ) 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 // 13 // 14 // 15 // 16 // 17 // 18 // 19 // 20 // 21 // 22 // 23 // 24 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