20230526Direct Ellsworth.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 IN BOTH
2024 AND 2025 AND FOR APPROVAL OF
AN ENERGY STORAGE AGREEMENT WITH
KUNA BESS LLC.
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CASE NO. IPC-E-23-20

IDAHO POWER COMPANY

DIRECT TESTIMONY

OF

JARED L. ELLSWORTH
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 based upon the 15
load and resource balance utilized in the 2021 Integrated 16
Resource Plan (“IRP”) and subsequently further enhanced 17
through a system resource adequacy reliability evaluation. 18
I will describe the most recent assessment of system 19
reliability and its impact to the capacity deficit 20
identified in the load and resource balance. Finally, I 21
will provide support for the acquisition of new resources 22
to address the identified near-term peak capacity needs. 23
I. BACKGROUND 24
Q. What is the goal of the IRP? 25
ELLSWORTH, DI 3
Idaho Power Company
A. The goal of the IRP is to ensure: (1) Idaho 1
Power’s system has sufficient resources to reliably serve 2
customer demand and flexible capacity needs over a 20-year 3
planning period, (2) the selected resource portfolio 4
balances cost, risk, and environmental concerns, (3) 5
balanced treatment is given to both supply-side resources 6
and demand-side measures, and (4) the public is involved in 7
the planning process in a meaningful way. To verify the 8
portfolios produced through the planning process meet the 9
Company’s reliability requirements, Idaho Power utilizes a 10
Loss of Load Expectation (“LOLE”) methodology. 11
Q. Please explain the Loss of Load Expectation. 12
A. The LOLE is a statistical measure of a 13
system’s resource adequacy, describing the expected number 14
of event-days per year that a system would be unable to 15
meet demand. As utilities continue to add more renewable 16
energy to the electric grid, analyzing the effect variable 17
energy resources have on system reliability has become more 18
critical. To assess system reliability, the Company uses an 19
internally developed reliability and capacity assessment 20
tool, which ensures that portfolios include a recognition 21
that the output of variable energy resources, such as wind 22
and solar, change with time (with their hourly output being 23
dependent on a multitude of factors like weather and 24
environmental conditions); it is essential to capture and 25
ELLSWORTH, DI 4
Idaho Power Company
value that variability. The results of the LOLE analysis 1
are used to determine various modeling outputs, such as the 2
Company’s capacity position in a given year, the capacity 3
contribution of variable and energy limited resources and 4
an overall quantification of Idaho Power’s system 5
reliability. 6
Q. Please explain the “load and resource 7
balance.” 8
A. The load and resource balance is the Company’s 9
tabulated plan that identifies resource deficiencies during 10
the 20-year IRP planning horizon. It helps visually ensure 11
Idaho Power has sufficient resources to meet projected 12
customer demand including a margin to account for extreme 13
conditions, reserves, and resource outages. It is critical 14
when comparing future resource portfolios that each plan 15
achieves at least a base reliability threshold, which is 16
why Idaho Power considers the LOLE methodology when 17
creating a load and resource balance. 18
Q. How is the resulting resource sufficiency or 19
deficiency determined through the load and resource 20
balance? 21
A. At a high level, the load and resource balance 22
incorporates the expected availability of Idaho Power’s 23
existing resources, comparing the total output to the 24
Company’s forecasted load, and illustrates the resulting 25
ELLSWORTH, DI 5
Idaho Power Company
capacity length or deficit. This will identify the timing 1
of the Company’s first resource need, or the point at which 2
Idaho Power’s reliability requirements may not be met. 3
Q. How is the expected availability of the 4
Company’s existing resources determined? 5
A. The availability of existing resources, 6
including Public Utility Regulatory Policies Act (“PURPA”) 7
projects, Power Purchase Agreements (“PPA”), hydro, coal, 8
gas, demand response, and market purchases, is determined 9
using a number of factors such as expected stream flows, 10
plant run times, forced outages, historical performance, 11
and transmission import capability, among other 12
considerations. 13
Q. How is the load forecast determined? 14
A. Throughout the year, the Company prepares a 15
forecast of sales and demand of electricity based on a 16
combination of historical system data and trends in 17
electricity usage along with numerous external economic and 18
demographic factors. The anticipated load and anticipated 19
peak-hour demand forecast represent Idaho Power’s most 20
probable outcome for load requirements during the planning 21
period. 22
Q. What have previous load and resource balance 23
results indicated with respect to Idaho Power’s resource 24
sufficiency? 25
ELLSWORTH, DI 6
Idaho Power Company
A. The Company has been generally resource-1
sufficient since the addition of the Langley Gulch natural-2
gas fired power plant almost a decade ago until recently. 3
The load and resource balance from the Second Amended 2019 4
IRP did not show a capacity deficiency occurring until the 5
summer of 2028. However, several converging factors, 6
including limited third-party transmission capacity, load 7
growth, and a decline in the peak serving effectiveness of 8
certain supply-side and demand-side resources caused Idaho 9
Power to rapidly move to a near-term capacity deficiency 10
starting in 2023. These dynamic circumstances led the 11
Company to immediately file a request for a Certificate of 12
Public Convenience and Necessity (“CPCN”) to acquire 13
resources to be online in 20231 as well as a CPCN to acquire 14
resources to be online in 20242, and Idaho Power expects to 15
acquire additional resources each year thereafter through 16
(at least) through 2027, as discussed in the Company’s 17
request in this case. 18
II. 2021 IRP LOAD AND RESOURCE BALANCE 19
Q. When did Idaho Power identify that there was a 20
resource deficiency starting in 2023? 21
A. The Company first identified a resource 22
deficiency beginning in 2023 in the spring of 2021 while 23

1 Case No. IPC-E-22-13
2 Case No. IPC-E-23-05
ELLSWORTH, DI 7
Idaho Power Company
refreshing the load and resource balance during the 1
development of a Valmy Unit 2 exit analysis, as directed by 2
the Commission in Order No. 34349, Idaho Power’s request to 3
update rates to reflect the accelerated depreciation 4
associated with an early exit from coal-fired operations at 5
Valmy, Case No. IPC-E-19-08. Following the filing of the 6
Second Amended 2019 IRP, in the first quarter of 2021, 7
Idaho Power began preparing the required Valmy Unit 2 exit 8
analysis, which included an evaluation of system 9
reliability. This analysis was performed simultaneously 10
with preparation of the 2021 IRP, and the refreshed load 11
and resource balance was further refined through the 12
remainder of the development of the 2021 IRP. 13
Q. What drove the rapid shift from resource 14
sufficiency to a resource deficiency at this time? 15
A. Several factors contributed to the change in 16
the load and resource balance at this time, including 17
significant third-party transmission constraints limiting 18
wholesale market import purchases at peak, the ability of 19
demand response programs to meet load during the highest 20
risk hours, planning reserve margin determinations and 21
methodology modernization, and load growth exceeding 22
previously forecasted expectations. The net change between 23
the Second Amended 2019 IRP and the updated load and 24
resource balance utilized for the Valmy Unit 2 exit 25
ELLSWORTH, DI 8
Idaho Power Company
analysis was a reduction in over 500 megawatts (“MW”) in 1
available capacity each July during the 2022 through 2025 2
period. 3
Q. What enhancements were made to the capacity 4
contribution of variable energy resources utilized to meet 5
reliability requirements for the 2021 IRP? 6
A. For reliability purposes, in the 2021 IRP the 7
Company planned its resource portfolio to have a LOLE of 8
0.05 event-days per year or better (i.e. less than one 9
resource adequacy related outage event-day in 20 years). 10
Aside from taking a more granular hourly approach, the LOLE 11
methodology can also be used to evaluate the capability of 12
existing resources to meet capacity need through the 13
determination of Effective Load Carrying Capability 14
(“ELCC”). 15
Q. Did the application of ELCC values result in 16
any significant changes to the contributing capacity of 17
Idaho Power’s existing resources? 18
A. Yes. When analyzing Idaho Power’s system on a 19
probabilistic hour-by-hour basis, existing variable 20
resource capacity contributions fluctuated. As an example, 21
the results showed that the ELCC of the demand response 22
programs under the changing dynamics of Idaho Power’s 23
system was significantly lower than previously assumed. 24
This is primarily the result of increased solar resources 25
ELLSWORTH, DI 9
Idaho Power Company
on the Company’s system pushing high-risk (i.e. net peak 1
load) hours outside the longstanding demand response 2
program dispatch window of 1 PM to 9 PM. As a result, Idaho 3
Power filed a request for modifications to its demand 4
response programs that are designed to make the programs 5
more effective at meeting system needs. On March 4, 2022, 6
the Commission issued Order No. 35336, approving Idaho 7
Power’s proposed modifications to the demand response 8
programs, effective for the 2022 demand response season. 9
Q. What was the resulting capacity deficiency 10
identified in the load and resource balance prepared for 11
the 2021 IRP? 12
A. The resulting capacity deficiency was 13
approximately 101 MW in 2023, 186 MW in 2024, and 311 MW in 14
2025, which led to Idaho Power’s request for a CPCN in Case 15
No. IPC-E-22-13 for the 2023 resource procurement. 16
III. LOAD AND RESOURCE UPDATE 17
Q. Since the completion of the 2021 IRP, has the 18
Company continued to monitor other factors that could 19
influence the load and resource balance, and by extension, 20
Idaho Power’s resource need? 21
A. Yes. While the load and resource balance 22
prepared for an IRP is the primary source of information 23
used to inform resource procurement decisions, the Company 24
also recognizes that during the near-term resource 25
ELLSWORTH, DI 10
Idaho Power Company
decision-making phase, the capacity deficit period can be 1
very fluid. As a result, Idaho Power continually assesses 2
system reliability, monitoring near-term known changes, 3
operational enhancements, limitations, or constraints on 4
the existing system, if any, that would impact the resource 5
needs. In the face of growing loads, Idaho Power is also 6
keenly focused on current supply chain challenges, which 7
requires the Company to constantly monitor resource needs 8
and respond with added urgency. This is evidenced by Idaho 9
Power’s consecutive requests for CPCNs to acquire resources 10
to be online in both 2023 and 2024.3 11
Q. Has the capacity deficiency changed since 12
Idaho Power’s request in Case No. IPC-E-23-05 was filed? 13
A. Yes. As preparation of the 2023 IRP began, 14
Idaho Power incorporated modeling input updates and made 15
additional enhancements to the Company’s reliability 16
evaluation which impact the need for new resources. 17
Q. What input updates and enhancements have been 18
made to the Company’s reliability evaluation? 19
A. First, in Case No. IPC-E-21-43, Commission 20
Staff requested that Idaho Power address the 21
appropriateness of the LOLE threshold utilized in the 2021 22
IRP; the Company has since changed the reliability target 23
from 0.05 event-days per year to 0.1 event-days per year as 24

3 Case Nos. IPC-E-22-13 and IPC-E-23-05.
ELLSWORTH, DI 11
Idaho Power Company
well as utilizing a 70th percentile peak load forecast as 1
opposed to the 50th percentile peak load forecast utilized 2
in the 2021 IRP. In addition, the Company adjusted Idaho 3
Power’s resource capacities to account for Equivalent 4
Forced Outage Rates during Demand (“EFORd”) using a 5-year 5
rolling average from the North American Electric 6
Reliability Corporation (“NERC”) Generation Availability 7
Data System (“GADS”). The updated 5-year rolling average 8
EFORd values will better reflect industry average 9
generation resource performance data and resulting outage 10
rates. Finally, the Company reduced the resource 11
availability associated with the capacity benefit margin 12
(“CBM”) from 330 MW to 200 MW from March through October 13
and to 0 MW from November to February for resource adequacy 14
purposes. 15
Q. What is CBM? 16
A. The NERC defines CBM as: 17
“The amount of firm transmission transfer 18
capability preserved by the transmission 19
provider for Load-Serving Entities (“LSEs”), 20
whose loads are located on that Transmission 21
Service Provider’s system, to enable access by 22
the LSEs to generation from interconnected 23
systems to meet generation reliability 24
requirements. Preservation of CBM for an LSE 25
allows that entity to reduce its installed 26
generating capacity below that which may 27
otherwise have been necessary without 28
interconnections to meet its generation 29
reliability requirements.” 30
ELLSWORTH, DI 12
Idaho Power Company
Including CBM within the load and resource balance 1
recognizes this held transmission capacity allows Idaho 2
Power to reduce its installed generation capacity to meet 3
reliability requirements under emergency conditions. As an 4
example, if an energy emergency is declared following the 5
loss of multiple Idaho Power network resources, CBM 6
transmission capacity could be utilized to fill the 7
resource capacity need via market purchases. Effectively, 8
Idaho Power considers CBM a reserve resource and applies 9
credit in the load and resource balance. 10
Q. When applying input updates and enhancements 11
to the Company’s reliability evaluation, what changes were 12
made to the CBM modeling assumptions? 13
A. As explained in Idaho Power’s request in Case 14
No. IPC-E-22-05, following an evaluation of the ability to 15
acquire transmission to the market during emergency 16
conditions, the Company determined that it may not be 17
possible with current transmission constraints, especially 18
during regional extreme weather events, which was evidenced 19
during recent energy emergency events due to extreme 20
weather in the region. Increased demand could not be met 21
with local generation, resulting in strain on the 22
interconnected transmission system. Last minute 23
transmission acquisition under these emergency conditions 24
ELLSWORTH, DI 13
Idaho Power Company
between the market and Idaho Power’s border have not been 1
consistently available. 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 constraints, however, may be short term 8
because the Boardman to Hemingway project will create 9
incremental transmission capacity between Idaho Power and 10
the Mid-C market. The results of the evaluation of the 11
ability to acquire transmission to the market during 12
emergency conditions indicate that an adjustment to CBM is 13
appropriate. 14
Q. Were there any other factors that impacted the 15
Company decision to reduce the capacity availability of CBM 16
as part of the enhancements to Idaho Power’s reliability 17
evaluation? 18
A. Yes. In addition to the evaluation of the 19
acquisition of transmission during emergency conditions, as 20
the Company began preparing for its future non-binding 21
participation in the Western Resource Adequacy Program 22
(“WRAP”), it was determined that CBM will not have similar 23
value in that program. 24
Q. What is the WRAP? 25
ELLSWORTH, DI 14
Idaho Power Company
A. The WRAP will deliver a region-wide approach 1
for assessing and addressing resource adequacy and is an 2
important step forward for reliability in the region. It 3
started at the request of many in the industry who were 4
concerned about the issue of resource adequacy in the west. 5
Q. How does the WRAP affect the Company’s 6
transmission assumption associated with CBM? 7
A. When evaluating resource adequacy planning 8
requirements under the WRAP, quantification of firm 9
resources will not allow for the inclusion of CBM to 10
demonstrate adequacy. For Idaho Power to meet the WRAP 11
forward showing requirements, have access to the program, 12
and avoid penalties, the Company must acquire firm 13
resources on firm transmission well in advance of each 14
season. CBM, by definition, is only available as firm 15
transmission when the Company is in an energy emergency, 16
and therefore cannot be utilized for WRAP forward showing 17
purposes. However, the Company believes participation in 18
the WRAP will benefit Idaho Power and its customers, as 19
outlined in the Company’s request for Commission 20
acknowledgement of participation in WRAP in Case No. IPC-E-21
23-08. 22
Q. If CBM cannot be used in the WRAP, why is 23
Idaho Power reducing CBM from 330 MW to 200 MW for a 24
ELLSWORTH, DI 15
Idaho Power Company
portion of the year instead of reducing CBM from 330 MW to 1
0 MW for the entire year? 2
A. The Company is taking an incremental approach 3
to changing assumptions associated with the reliability 4
benefits provided by CBM. As discussed earlier, the WRAP is 5
only one of two major considerations. The WRAP program will 6
not be binding until approximately the summer of 2027, and 7
there remains uncertainty related to the load obligations 8
Idaho Power will be required to meet in the WRAP, and the 9
credit the Company will receive for its resources in the 10
WRAP program. Idaho Power will continue to consider the 11
transmission assumptions associated with CBM in the 12
assessment of system reliability as the WRAP matures. 13
The second major consideration to CBM is whether it 14
enhances the Company’s ability to recover from a major 15
unplanned disturbance. Following such a disturbance, the 16
Company can utilize its CBM capacity to bring in reserves 17
for one hour, and in that hour, Idaho Power must acquire 18
capacity from the market, and the transmission between the 19
capacity resource or market hub and the Company’s 20
transmission system, to continue to utilize CBM. 21
Given Idaho Power’s movement towards WRAP, the 22
certainty that the WRAP program will assign no resource 23
adequacy value to CBM, and the uncertainty of being able to 24
access emergency capacity resources when the Company is in 25
ELLSWORTH, DI 16
Idaho Power Company
an energy emergency (the purpose of CBM), especially at 1
times when other utilities in the Pacific Northwest region 2
experience peak loads, Idaho Power has decided to reduce 3
the inclusion of CBM from 330 MW to 200 MW during the March 4
through October time frame for resource adequacy planning 5
purposes. The Company will continue to evaluate CBM’s 6
reliability benefits and effectiveness in future system 7
reliability evaluations and IRPs. 8
Q. Were there any other updates made to the 9
system reliability evaluation that impacted the capacity 10
deficiency and Idaho Power’s need for new resources? 11
A. Yes. Any time the system reliability 12
evaluation is performed, Idaho Power includes the most up-13
to-date load and resource inputs. The Company’s service 14
area continues to experience very high load growth; in 15
response, the load forecast was updated and implemented as 16
soon as it became readily available. Current transmission 17
reservations were included. Resource inputs were updated to 18
include new resource additions anticipated since 19
development of the 2021 IRP, including: (1) the Black Mesa 20
project, a 40 MW solar photovoltaic (“PV”) PPA in 21
combination with a 40 MW four-hour duration battery storage 22
facility, (2) the Hemingway 80 MW four-hour duration 23
battery storage facility project in 2023 and an additional 24
12 MW of four-hour duration battery storage in 2024, (3) 25
ELLSWORTH, DI 17
Idaho Power Company
the 11 MW four-hour duration battery storage at various 1
distribution substations, (4) the Franklin project, a 100 2
MW solar PV PPA in combination with a 60 MW four-hour 3
duration battery storage facility, and the (5) 200 MW 4
Pleasant Valley solar project in 2025. 5
Q. Are there any changes to the resource inputs, 6
aside from the cycle-to-cycle data updates, that have 7
increased the capacity deficiency since preparation of the 8
load and resource balance for the 2021 IRP? 9
A. Yes. There are two adjustments to the resource 10
inputs that increased the capacity deficiency beginning in 11
2023: (1) a planned refurbishment of one hydro unit per 12
year, for three years, at the American Falls facility will 13
reduce the overall resource availability by approximately 14
30 MW through 2025, and (2) the Langley Gulch facility has 15
recently been derated by 20 MW through the fall of 2025 due 16
to parts failure and supply chain issues of those higher 17
capacity parts. In addition, due to uncertainty associated 18
with the two solar PURPA projects located in eastern 19
Oregon, totaling 72 MW of nameplate capacity, that were 20
expected to be online by the summer of 2025, the Company 21
has removed these projects from the system reliability 22
analysis, resulting in an increase to the capacity 23
deficiency beginning in 2025. 24
ELLSWORTH, DI 18
Idaho Power Company
Q. Based on your most recent evaluation of system 1
reliability, how has the capacity deficiency changed since 2
Idaho Power’s request in Case No. IPC-E-23-05 was filed? 3
A. While continued procurement of additional 4
resources have contributed to a reduction in the capacity 5
deficiencies, following enhancements to the system 6
reliability calculations and continued load growth since 7
completion of the load and resource balance used for the 8
2021 IRP, Idaho Power estimates a capacity deficiency of 8 9
MW still exists in 2024 while the capacity deficiency in 10
2025 is 178 MW, with both of these deficiencies assuming 11
the Company can compress the American Falls outages into 12
nine-months, and maintain full American Falls capacity 13
through the summer-months. 14
Q. Are you indicating the resource procurements 15
identified in Case No. IPC-E-23-05 will not be sufficient 16
to satisfy the 2024 resource needs? 17
A. Yes. Following updates to the system 18
reliability evaluation, including (1) the reduced winter 19
resource availability associated with CBM, (2) 20
identification of an over-allocation of capacity of a 21
resource in the LOLE calculation, and (3) the unexpected 20 22
MW derate at Langley Gulch, the Company has determined that 23
the combined 100 MW solar PV PPA and 72 MW of four-hour 24
battery storage resources for which Idaho Power is 25
ELLSWORTH, DI 19
Idaho Power Company
requesting approval and a CPCN in Case No. IPC-E-23-05, 1
will not be sufficient to meet the identified 2024 resource 2
needs. As I discussed previously, during the near-term 3
resource decision-making phase, Idaho Power continually 4
assesses system reliability. However, when the Company is 5
repeatedly matching near-term resource procurements with 6
the capacity need identified at a point in time, it is not 7
possible to specifically align procurement of resources 8
with the fluctuating need. The newly identified additional 9
capacity need in 2024 is the result of trying to target a 10
near-term resource need during a very fluid capacity 11
deficit period. 12
IV. MEETING THE CAPACITY DEFICIENCY 13
Q. Did Idaho Power evaluate any alternative 14
solutions for meeting the capacity deficiencies to avoid 15
building a new resource? 16
A. Yes. Prior to filing the request for a CPCN in 17
Case No. IPC-E-22-13, Idaho Power evaluated alternative 18
solutions for meeting the 2023 capacity deficiency to avoid 19
building a new resource, including modifications to 20
existing demand response programs, expansion of the 21
existing pricing programs, and the potential for other 22
short-term market solutions. 23
Modifications to Existing Demand Response Programs 24
ELLSWORTH, DI 20
Idaho Power Company
As mentioned earlier, Idaho Power modified its 1
demand response programs, which were approved with 2
Commission Order No. 35336, effective for the 2022 demand 3
response season. Although the demand response program 4
modifications resulted in a higher ELCC than previous 5
programs, it alone did not prove to be viable for meeting 6
the 2023 resource deficiency nor have any circumstances 7
changed within the past 12 months that would have indicated 8
demand response could provide a solution for meeting the 9
2024 and 2025 resource needs. 10
Evaluation of Existing and Potential Pricing Programs 11
Idaho Power evaluated the Company’s current Time-of-12
Use (“TOU”) offering and the potential for other pricing 13
programs as possible options for meeting the capacity 14
deficiency. The Company has existing TOU offerings in both 15
its Idaho and Oregon jurisdictions, with 1,000 customers 16
enrolled in the Idaho offering and five customers enrolled 17
in the Oregon pilot program. With the level of customer 18
participation data, the sample used to develop a 19
comprehensive and reliable assessment of residential peak 20
shifting would be outside an acceptable margin of error 21
tolerance limit at approximately +/- 60 percent. As such, 22
circumstantial behavioral changes could misrepresent peak 23
shifting impacts when expanded to the full residential 24
ELLSWORTH, DI 21
Idaho Power Company
customer class. Idaho Power continues to assess the 1
programs and how to encourage customer participation. 2
Short-Term Market Solutions 3
To test the transmission deliverability and resource 4
market availability of a replacement resource for Valmy 5
Unit 2, the Company issued a request for proposals (“RFP”) 6
on April 26, 2021, for the delivery of firm capacity and 7
energy during the summer months beginning 2023. Idaho 8
Power received no bids, indicative of the evolving market 9
conditions leading to revised transmission import 10
assumptions in the system reliability evaluation. Idaho 11
Power continually monitors the availability of 12
energy/capacity deliveries to the Company’s border as well 13
as transmission availability that would allow for the 14
delivery of energy from a market hub to Idaho Power’s 15
system. 16
Q. Has Idaho Power taken any actions to acquire 17
resources to meet the capacity deficits? 18
A. Yes. Under Idaho law, Idaho Power has an 19
obligation to provide adequate, efficient, just, and 20
reasonable service on a nondiscriminatory basis to all 21
those that request it within its certificated service area.4 22
In order to meet its obligations to reliably serve customer 23
load, and given the extremely short turn-around to 24

4 Idaho Code §§ 61-302, 61-315, 61-507.
ELLSWORTH, DI 22
Idaho Power Company
construct a resource to meet the first deficit in the 1
summer of 2023, particularly in the midst of supply chain 2
disruption, ongoing COVID-19 impacts, and constraints in 3
the industry and in ancillary industries, on June 30, 2021 4
the Company conducted a competitive solicitation through an 5
RFP seeking to acquire up to 80 MW of peak capacity 6
resources to meet the 2023 capacity deficit - seeking 7
projects to be online by June of 2023 (“2021 RFP”). As 8
presented in Case No. IPC-E-22-13 for which the Commission 9
granted a CPCN with Order No. 35643, the RFP process 10
resulted in the procurement of 120 MW of dispatchable four-11
hour duration energy storage as well as execution of a 20-12
year PPA for 40 MW of solar, all of which were necessary to 13
adequately address 2023 capacity deficits. 14
As indicated by Order No. 35643, Idaho Power is 15
responsible for planning and managing its load and resource 16
portfolio and the Commission expects “the Company to 17
closely monitor its projected capacity needs going forward 18
and to act proactively to ensure a robust RFP process can 19
be completed.”5 Therefore, similar to the RFP issued to 20
address the 2023 deficiency, given the short turn-around to 21
construct a resource to meet the deficit in the summer of 22
2024, on December 30, 2021, the Company conducted a 23
competitive solicitation through an RFP seeking to acquire 24

5 Page 13.
ELLSWORTH, DI 23
Idaho Power Company
energy and capacity to help meet Idaho Power’s previously 1
identified capacity needs of 85 MW in 2024 and an 2
incremental 115 MW in 2025 (“2022 RFP”). 3
Q. What actions has Idaho Power taken to satisfy 4
the capacity deficiencies? 5
A. As detailed in Company witness Mr. Hackett’s 6
testimony, through the Company’s robust competitive bidding 7
process, the RFP resulted in the selection of a 150 MW 8
energy storage project, consisting of a 20-year Energy 9
Storage Agreement (“ESA”) for a 150 MW battery storage 10
facility and 77 MW of Idaho Power-owned battery storage at 11
Happy Valley station to meet the 2025 capacity deficiency. 12
In addition, for the newly identified capacity need in 13
2024, an additional 24 MW of Idaho Power-owned battery 14
storage at Hemingway was procured to ensure the Company is 15
able to continue to provide safe, reliable service to its 16
customers in 2024 and beyond. 17
Q. You mentioned previously in your testimony 18
that Idaho Power estimates a capacity deficiency of 8 MW in 19
2024 and 178 MW in 2025. Why is the Company requesting a 20
CPCN for a cumulative 251 MW of battery storage additions 21
in 2024 and 2025? 22
A. The 186 MW represents the estimated capacity 23
deficiency, while the 251 MW represents the nameplate 24
capacity of the resource additions. The nameplate capacity 25
ELLSWORTH, DI 24
Idaho Power Company
must be adjusted to reflect the ELCC of these resource 1
additions. 2
Q. What is the Company’s resulting capacity 3
balance position for 2024 and 2025 following the 4
procurement of the ESA and the combined 101 MW of four-hour 5
duration battery storage? 6
A. Assuming the Company and its contractors are 7
successful restoring the American Falls power plant to full 8
capacity prior to the summer of each year, the Company 9
anticipates a 13 MW capacity length in 2024, and a 6 MW 10
capacity length in 2025. If Idaho Power is unable to 11
restore American Falls to full capacity for the summer, the 12
Company estimates 0 MW of capacity length in 2024 and an 8 13
MW capacity deficit in 2025. 14
Q. Do you believe there is sufficient support for 15
the procurement of the ESA and the combined 101 MW of four-16
hour duration battery storage resources to be online in 17
2024 and 2025? 18
A. Yes, I do. The acquisitions were pursued and 19
procured as a least cost/least risk method of meeting the 20
capacity deficits first identified in the Company’s 2021 21
IRP and subsequently with the results of system reliability 22
evaluation. The fluidity of the capacity deficit period and 23
continued high load growth further supports these resource 24
procurements. 25
ELLSWORTH, DI 25
Idaho Power Company
V. CONCLUSION 1
Q. Please summarize your testimony. 2
A. Idaho Power’s most recent system reliability 3
evaluation has identified a capacity deficiency of 8 MW 4
still exists in 2024 and the capacity deficiency in 2025 is 5
178 MW. In response to this resource need, the Company has 6
executed an ESA for a 150 MW battery storage facility and 7
procured a combined 101 MW of four-hour duration battery 8
storage resources to satisfy the identified capacity needs 9
in 2024 and 2025. 10
Q. Does this complete your testimony? 11
A. Yes, it does. 12
ELLSWORTH, DI 26
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 26th day of May 2023, at Boise, Idaho. 16
17 Signed: ________________________ 18
Jared L. Ellsworth 19