20250312Notice_of_Application_Order_No_36499.pdf

Office of the Secretary
Service Date
March 12,2025
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-25-02
COMPANY'S APPLICATION TO MODIFY )
ITS ENERGY RISK MANAGEMENT ) NOTICE OF APPLICATION
STANDARDS )
NOTICE OF INTERVENTION
DEADLINE
ORDER NO. 36499
On January 31,2025, Idaho Power Company("Company") applied for authority to modify
its Energy Risk Management Standards ("ERMS"). The ERMS serve as the standard by which
prospective power supply transactions satisfying customer load are evaluated for potential future
rate treatment. The Company requested that this matter be processed by Modified Procedure.
The Commission now issues this Notice of Application and sets deadlines by which
interested persons may intervene.
NOTICE OF APPLICATION
YOU ARE HEREBY NOTIFIED that the ERMS implement the Company's Energy Risk
Management Policy("ERMP"), forming a systematic procedure to identify, evaluate, and manage
risks driven by market forces impacting the Company's operations.
YOU ARE FURTHER NOTIFIED that the ERMS and ERMP (collectively, "Program")
were initially developed more than two decades ago through settlement negotiations that resolved
an investigation into the Company's trading practices, including hedging, transmission and
wheeling charges, and Mid-C or Palo Verde pricing indexes.
YOU ARE FURTHER NOTIFIED that the Commission-approved Program included Risk
Guidelines defining when and how the Company would carry out hedging transactions.
YOU ARE FURTHER NOTIFIED that the Company represents that the Risk Guidelines
are divided into three sections called "Tiers." Tier One addresses financial exposure arising from
low-water and high-price scenarios. Tier Two addresses exposure associated with forecast deficit
or surplus positions. Tier Three focuses on leveraging low market price conditions.
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36499 1

YOU ARE FURTHER NOTIFIED that the Company represents that the composition of
its stack of generation resources has changed significantly since the inception of the ERMS,
transitioning from mostly coal-fired generation to natural gas-fired generation.
YOU ARE FURTHER NOTIFIED that the Company represents that this transition to
natural gas-fired generation units requires a larger volume of hedging transactions,which conflicts
with the fundamental goal of the ERMS, which is to limit the Company's exposure.
YOU ARE FURTHER NOTIFIED that the Company represents that the ERMS limits the
Company's access to the modern natural gas market, which has evolved since the inception of the
ERMS.
YOU ARE FURTHER NOTIFIED that the Company proposes modifying the ERMS in
response to the evolution of the natural gas market since the inception of the ERMS. Specifically,
the Company proposes modifying Tier One so that hedges will be required if a monthly forward
market price exceeds the calculated high price for that particular month. Tier Two would be
modified to permit the establishment of hedges to decrease the deficit or surplus position and
reduce market exposure. Tier Three would be modified to permit the Company to access more
low-volatility products.
YOU ARE FURTHER NOTIFIED that the Company represents that it is not proposing
changes to the ERMP.
YOU ARE FURTHER NOTIFIED that the Application has been filed with the
Commission and is available for public inspection during regular business hours at the
Commission's office. These documents are also available on the Commission's website at
www.puc.idaho.gov. Click on the "Electric" or icon, select "Open Cases," and then click on the
appropriate case number as shown on the front of this document.
YOU ARE FURTHER NOTIFIED that all proceedings in this case will be held pursuant
to the Commission's jurisdiction under Title 61 of the Idaho Code.
YOU ARE FURTHER NOTIFIED that all proceedings in this matter will be conducted
pursuant to the Commission's Rules of Procedure, IDAPA 31.01.01.000 et seq.
NOTICE OF INTERVENTION DEADLINE
YOU ARE FURTHER NOTIFIED that persons desiring to intervene in this matter to
obtain parties' rights of participation must file a Petition to Intervene with the Commission
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36499 2

pursuant to this Commission's Rules of Procedure 72 and 73, IDAPA 31.01.01.072 and -.073.
Persons who wish to intervene as a party must file a Petition to Intervene no later than 21
days after the date of service of this Order. Such persons shall also provide the Commission
Secretary with their email address to facilitate further communications. After the intervention
deadline runs, the Commission Secretary shall issue a Notice of Parties that identifies the parties
and assigns exhibit numbers to each party. Once the Notice of Parties has issued, Commission
Staff shall informally confer with the Company and any intervening parties about how to further
process this case and shall then report back to the Commission on a proposed case schedule.
YOU ARE FURTHER NOTIFIED that persons who would like to present their views
without parties' rights of participation and cross-examination do not have to intervene but may
present their views by submitting written comments to the Commission.
YOU ARE FURTHER NOTIFIED that the following people are designated as the
Company's representatives in this matter:
Lisa D. Nordstrom Matthew T. Larkin
Megan Goicoechea Allen Timothy E. Tatum
Idaho Power Company Jessi Brady
1221 West Idaho St. Idaho Power Company
P.O. Box 70 1221 West Idaho St.
Boise, Idaho 83707 P.O. Box
lnordstromgidahopower.com Boise, Idaho 83707
mgoicoecheaallengidahopower.com mlarkingidahopower.com
dockets(aiidahopower.com ttatum(a),idahopower.com
j braydgidahopower.com
ORDER
IT IS HEREBY ORDERED that persons desiring to intervene in this matter must file a
Petition to Intervene no later than 21 days from the service date of this Order. Once the deadline
has passed, the Commission Secretary shall prepare and issue a Notice of Parties.
IT IS FURTHER ORDERED that, after the Notice of Parties has issued,Commission Staff
shall confer with the parties regarding a procedural schedule for this matter including,if necessary,
a hearing in this matter.
IT IS FURTHER ORDERED that parties comply with Order No. 35375, issued April 21,
2022. Generally, all pleadings should be filed with the Commission electronically and will be
deemed timely filed when received by the Commission Secretary.See Rule 14.02. Service between
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36499 3

parties should continue to be accomplished electronically when possible. However, voluminous
discovery-related documents may be filed and served on CD-ROM or a USB flash drive.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 121h day of
March 2025. /
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EDWARD LODGE, PPWVSIDENT
J R. HAMMOND JR., COMMISSIONER
DAYN HARNE, COMMISSIONER
ATTEST:
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I:\Legal\ELECTRIC\IPC-E-25-02_Modify ERMS\orders\IPCE2502_NtcApp_ID_at.docx
NOTICE OF APPLICATION
NOTICE OF INTERVENTION DEADLINE
ORDER NO. 36499 4