20250508APPLICATION.pdf

ow-10AW POWER.
RECEIVED
DONOVAN WALKER May 8, 2025
Lead Counsel IDAHO PUBLIC
dwalker(cD_idahopower.com UTILITIES COMMISSION
May 8, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-25-22
Idaho Power Company's Application for Authority to Update its Operation
and Maintenance Charges Applicable to Schedule 72, Generator
Interconnections to PURPA Qualifying Facility Sellers
Dear Commission Secretary:
Attached please find Idaho Power Company's Application and Direct Testimony of
Riley Maloney to be filed in the above-entitled matter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Donovan E. Walker
DEW:cd
Attachments
1221 W. Idaho St(83702)
P.O.Box 70
Boise, ID 83707

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-22
AUTHORITY TO UPDATE ITS OPERATION )
AND MAINTENANCE CHARGES ) APPLICATION
APPLICABLE TO SCHEDULE 72, )
GENERATOR INTERCONNECTIONS TO )
PURPA QUALIFYING FACILITY SELLERS. )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho
Public Utilities Commission ("Commission") Rule of Procedure' 52 and the applicable
provisions of the Public Utility Regulatory Policies Act of 1978 ("PURPA"), hereby
respectfully applies to the Commission for an order modifying Schedule 72, Generator
Interconnections to PURPA Qualifying Facility ("QF") Sellers, in compliance with the
settlement stipulation approved by Order No. 36042 issued in the Company's 2023
General Rate Case, IPC-E-23-11 ("2023 GRC").
The Company respectfully requests that the Commission issue an Order
approving: (1) the proposed changes to Schedule 72, effective January 1 , 2026, and (2)
Hereinafter cited as RP.
APPLICATION - 1

finding that the Company has satisfied its compliance obligation from the 2023 GRC to
update monthly operations and maintenance ("O&M") charges contained in Schedule 72,
Generator Interconnections to PURPA Qualifying Facility Sellers, to reflect current
operating metrics and assumptions. Filed with this Application is the Direct Testimony of
Riley Maloney. Additionally, in support of this Application, Idaho Power represents as
follows:
L BACKGROUND
1. The Commission first adopted Schedule 72, governing the interconnection
of PURPA QF generators to Idaho Power's system in Idaho Power's Idaho service area,
in Case No. IPC-E-90-20. When Schedule 72 was established, a schedule of monthly
O&M charges ("O&M Charges") assessed to interconnecting QFs were set out in a 35-
year table. When a PURPA QF interconnects to the Company's facilities, the QF pays
the capital costs of the facilities necessary to connect the project to the Company's
system. Once completed, ownership of these facilities prior to the QF's interconnection
point transfers to the Company, which then assumes responsibility for all ongoing
operation and maintenance expenses. The O&M Charge appearing within Schedule 72
is designed to reimburse the Company for the costs, using system averages, associated
with operating and maintaining such interconnection facilities. These charges are
necessary to ensure the Company's general body of customers do not shoulder the
ongoing O&M of the infrastructure caused by the addition of the QF project.
2. On December 23, 2023, the Commission issued Order No. 36042 in Idaho
Power's 2023 GRC, which approved the settlement stipulation entered into by Idaho
Power, Staff, Clean Energy Opportunities for Idaho, Idaho Irrigation Pumpers Association,
APPLICATION - 2

Inc., Industrial Customers of Idaho Power, Idaho Hydroelectric Power Producers Trust
d/b/a IdaHydro, Micron Technology, Idaho Conservation League, the City of Boise, The
United States Department of Energy on behalf of the Federal Executive Agencies, NW
Energy Coalition, and Walmart, Inc. (collectively "the Parties"). In the settlement
stipulation, Parties agreed:
11. Generation Interconnection Charges. The monthly operations
and maintenance ("O&M") charge in Schedule 72, Generator
Interconnections to PURPA Qualifying Facility Sellers, will be updated in the
future to reflect current operating metrics and assumptions, in conjunction
with the informal proceeding described in paragraph 13(b) below. . .
13. Separate Informal Proceedings. To facilitate further investigation
and participation, the Parties agree that: ...
(b) IdaHydro will initiate and meet with Idaho Power to discuss
Qualified Facility O&M charges. Execution of, and agreement to this
Stipulation and Settlement is without prejudice to any Parties' ability to bring
a separate action before the Commission related to O&M charges in
Schedule 72.
3. Since the conclusion of the 2023 GRC, Idaho Power and IdaHydro have
held informal discussions regarding the basis for the methodology used to establish the
current O&M Charges in 1990 ("Original Methodology"). Coincident with these
discussions, Idaho Power provided Excel workbooks that performed the calculations to
allow IdaHydro to develop a more complete understanding of the methodology. Those
workbooks also recalculated the equivalent levelized O&M charge rates using historical
financial information from several other select years (2015-2017, 2022, 2023).
4. Idaho Power believes that the methodology and updated calculation
proposed in this Application complies with the terms of the settlement stipulation
approved in the 2023 GRC. A summary of the proposed Schedule 72 O&M Charge
update is as follows.
APPLICATION - 3

II. PROPOSED SCHEDULE 72 O&M CHARGE UPDATE
5. Generally using the Original Methodology, Idaho Power calculated new
O&M Charges based on 13-month average plant balances and such plant's associated
O&M expenses, as stated within the Company's 2024 FERC Form 1. These levelized
rates equate to a proposed monthly 0.96 percent rate applied to the original cost of
distribution interconnection equipment and a 0.28 percent rate applied to the original cost
of transmission interconnection equipment. Exhibit No. 1 to the Direct Testimony of Riley
Maloney provides the calculation of these proposed rates. In comparison to the existing
O&M Charge, the updated levelized distribution rate increases from 0.70 percent per
month to 0.96 percent per month, while the levelized transmission rate decreases from
0.40 percent per month to 0.28 percent per month.
6. Idaho Power proposes to implement the updated O&M Charges utilizing the
levelized, average rates to collect O&M going forward, and to abandon the de-levelized
schedule containing different O&M charges on a yearly basis over 35 years as currently
exists. The rates that are currently in effect were subjected to a "de-levelization" process,
where the rate is lower early in the life of the interconnection equipment and escalated
for 35 years using an inflation factor. As more fully set forth in the Direct Testimony of
Riley Maloney, the Company proposes to remove the de-levelization concept from the
rate and instead charge the same calculated average rate each year.
7. Additionally, Idaho Power proposes to update Schedule 72's O&M Charge,
along with the associated revenue credit, on a more frequent basis in conjunction with
each general rate case proceeding, similar to how it updates Rule M, Facilities Charges.
APPLICATION - 4

8. The proposed Schedule 72 tariff sheets (both clean and legislative format)
are attached hereto as Attachment 1.
III. MODIFIED PROCEDURE
9. Idaho Power believes that a technical hearing is not necessary to consider
the issues presented herein and respectfully requests that this Application be processed
under Modified Procedure, i.e., by written submissions rather than by hearing. RP 201,
et seq. The Company has, however, contemporaneously filed the Maloney Testimony
and stands ready to present its testimony and support the Application if the Commission
determines that a technical hearing is required.
IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
10. Communications and service of pleadings, exhibits, orders, and other
documents relating to this proceeding should be sent to the following:
Donovan E. Walker Tim Tatum
IPC Dockets Riley Maloney
Idaho Power Company Idaho Power Company
1221 West Idaho Street (83702) 1221 West Idaho Street (83702)
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
dwalker _idahopower.com ttatum _idahopower.com
dockets idaho power.com rmaloney(@jdahopower.com
V. REQUEST FOR RELIEF
11. Idaho Power respectfully requests that the Commission issue an order: (1)
authorizing that this matter may be processed by Modified Procedure; (2) approving the
proposed changes to Schedule 72, effective January 1, 2026, and (3) finding that the
Company has satisfied its compliance obligation from the 2023 General Rate Case Order
No. 36042 to update the O&M Charge in Schedule 72, Generator Interconnections to
PURPA Qualifying Facility Sellers, to reflect current operating metrics and assumptions.
APPLICATION - 5

Respectfully submitted this 8th day of May 2025.
Donovan Walker
Attorney for Idaho Power Company
APPLICATION - 6

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day of May 2025, 1 served a true and correct
copy of the within and foregoing APPLICATION upon the following named parties by the
method indicated below, and addressed to the following:
Commission Secretary Hand Delivered
Idaho Public Utilities Commission U.S. Mail
11331 W. Chinden Blvd., Bldg No. 8 Overnight Mail
Suite 201-A (83714) FAX
PO Box 83720 FTP Site
Boise, ID 83720-0074 X Email
M4,'�-
Christy Davenport, Legal Assistant
APPLICATION - 7

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-22
IDAHO POWER COMPANY
ATTACHMENT NO. 1

Idaho Power Company First Revised Sheet No. 72-12
Cancels
I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 72-12
SCHEDULE 72
GENERATOR INTERCONNECTIONS
TO PURPA QUALIFYING FACILITY SELLERS
(Continued)
SECTION 2: INTERCONNECTION OF GENERATION FACILITIES (Continued)
VESTED INTEREST (Continued)
5. In no circumstance will Vested Interest refunds exceed 100 percent of the refundable
portion of any party's cash payment to the Company.
6. Vested Interest refund payments may be waived by notifying the Company in writing.
7. All existing agreements' refund provisions will be governed and administered under the
provisions in effect at the time the agreement was entered into between the Company and Seller or
Additional Applicant.
OPERATION AND MAINTENANCE OBLIGATIONS AND EXPENSES
The Company will operate and maintain Company furnished Interconnection Facilities, as well as
any Seller-Furnished Facilities transferred to the Company. Seller will pay the Company a monthly
operation and maintenance charge equal to a percentage of the Construction Cost and Transfer Cost
paid by the Seller. The monthly percentage charged will be as follows:
Facilities rated 138 kV and 161 kV: 0.28%
Facilities rated below 138 kV: 0.96%
The cost upon which an individual Seller's operation and maintenance charge is based will be
reduced by subsequent Vested Interest refunds. Additional Applicants who are Sellers will pay the
monthly operation and maintenance charge on the amount they paid as an Additional Applicant.
Seller-Furnished Facilities not transferred to the Company will be operated and maintained by the
Seller at the Seller's sole risk and expense.
The monthly operating and maintenance charges stated above will be applied as a percentage of
the applicable original interconnection investment.
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs
Effective — January 1, 2026 1221 West Idaho Street, Boise, Idaho

Idaho Power Company First Revised Sheet No. 72-13
Cancels
I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 72-13
SCHEDULE 72
GENERATOR INTERCONNECTIONS
TO PURPA QUALIFYING FACILITY SELLERS
(Continued)
SECTION 2: INTERCONNECTION OF GENERATION FACILITIES (Continued)
IDAHO POWER COMPANY
UNIFORM INTERCONNECTION
AGREEMENT
(PURPA)
This Interconnection Agreement ("Agreement") is effective as of the day of
20_, between hereinafter called "Seller," and Idaho Power
Company, hereinafter called "Company."
RECITALS
A. Seller will own or operate a Generation Facility that qualifies for service under Idaho
Power's Commission-approved Schedule 72 and any successor schedule.
B. The Generation Facility covered by this Agreement is more particularly described in
Attachment 1.
AGREEMENTS
1. Capitalized terms used herein shall have the same meanings as defined in Schedule 72
or in the body of this Agreement.
2. This Agreement and Schedule 72 provide the rates, charges, terms and conditions under
which the Seller's Generation Facility will interconnect with, and operate in parallel with, the Company's
transmission/distribution system. Terms defined in Schedule 72 will have the same defined meaning in
this Agreement. If there is any conflict between the terms of this Agreement and Schedule 72, Schedule
72 shall prevail.
3. This Agreement is not an agreement to purchase Seller's power. Purchase of Seller's
power and other services that Seller may require will be covered under separate agreements. Nothing
in this Agreement is intended to affect any other agreement between the Company and Seller.
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs
Effective — January 1, 2026 1221 West Idaho Street, Boise, Idaho

Idaho Power Company First Revised Sheet No. 72-14
Cancels
I.P.U.C. No. 30, Tariff No. 101 Original Sheet No. 72-14
SCHEDULE 72
GENERATOR INTERCONNECTIONS
TO PURPA QUALIFYING FACILITY SELLERS
(Continued)
SECTION 2: INTERCONNECTION OF GENERATION FACILITIES (Continued)
IDAHO POWER COMPANY
UNIFORM INTERCONNECTION
AGREEMENT
(PURPA)
(Continued)
AGREEMENTS (Continued)
4. Attached to this Agreement and included by reference are the following:
Attachment 1 —Description and Costs of the Generation Facility, Interconnection Facilities,
and Metering Equipment.
Attachment 2 — One-line Diagram Depicting the Generation Facility, Interconnection
Facilities, Metering Equipment and Upgrades.
Attachment 3— Milestones For Interconnecting the Generation Facility.
Attachment 4 — Additional Operating Requirements for the Company's Transmission
System Needed to Support the Seller's Generation Facility.
Attachment 5— Reactive Power.
Attachment 6 — Description of Upgrades required to integrate the Generation Facility and
Best Estimate of Upgrade Costs.
5. Effective Date, Term, Termination and Disconnection.
5.1 Term of Agreement. Unless terminated earlier in accordance with the provisions
of this Agreement, this Agreement shall become effective on the date specified above and remain
effective as long as Seller's Generation Facility is eligible for service under Schedule 72.
5.2 Termination.
5.2.1 Seller may voluntarily terminate this Agreement upon expiration or
termination of an agreement to sell power to the Company.
5.2.2 After a Default, either Party may terminate this Agreement pursuant to
Section 6.5.
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs
Effective — January 1, 2026 1221 West Idaho Street, Boise, Idaho

Idaho Power Company QFigiRaLFirst Revised Sheet No. 72-12
Cancels
I.P.U.C. No. 30, Tariff No. 101 Fourth Reyosed0riginal Sheet No. 72-12
SCHEDULE 72
GENERATOR INTERCONNECTIONS
TO PURPA QUALIFYING FACILITY SELLERS
(Continued)
SECTION 2: INTERCONNECTION OF GENERATION FACILITIES (Continued)
VESTED INTEREST (Continued)
5. In no circumstance will Vested Interest refunds exceed 100 percent of the refundable
portion of any party's cash payment to the Company.
6. Vested Interest refund payments may be waived by notifying the Company in writing.
7. All existing agreements' refund provisions will be governed and administered under the
provisions in effect at the time the agreement was entered into between the Company and Seller or
Additional Applicant.
OPERATION AND MAINTENANCE OBLIGATIONS AND EXPENSES
The Company will operate and maintain Company furnished Interconnection Facilities, as well as
any Seller-Furnished Facilities transferred to the Company. Seller will pay the Company a monthly
operation and maintenance charge equal to a percentage of the Construction Cost and Transfer Cost
paid by the Seller. The monthly percentage w+14Lchafirged will be as follows: annually on the anniversary
of the Forst Energy Date in acGordaRGo with the folleWiRg tohloc•
Facilities rated 138 kV and 161 kV: 0.28%
Facilities rated below 138 kV: 0.96%
TABLE 1: MONTHLY OPERATION AND MAINTENANCE CHARGES FOR 138 kV and 161 L\/
Yeaf 4 2 3 4 5 6 7 3 0 46 44 42
O&M Charge elk e.2796 e.289; 0.299; 0.3e9; e 2296 0..3396 0.36% 9.36% 0..38% 0.40% e.419;
Ye&F 43 44 45 46 47 46 46 20 24 22 23 24
Q&nn GhaFge 9:43% 9.4 5°6 947% 9 49-4 9.52% 9.54% 0.56% 85/0 9-6% 9.64% 9�/a e.79106
Yeas 25 26 27 28 20 W 34 32 33 34 35 36+
Q&M Charge 9.739; 9.779k 9.899; 9.949; 9.87% 0.94% 9:969k 1-999; a.04% 1.09% 1.149; 9.409k
The cost upon which an individual Seller's operation and maintenance charge is based will be
reduced by subsequent Vested Interest refunds. Additional Applicants who are Sellers will _pay_ the
monthly operation and maintenance charge on the amount they paid as an Additional Applicant.
Seller-Furnished Facilities not transferred to the Company will be operated and maintained by the
Seller at the Seller's sole risk and expense.
TABLE 2: MONTHLY OPERATING AND MAINTENANCE CHARGES BELOW 4, U\/
Yeaf 4 2 3 4 5 6 7 3 0 40 44 42
Q&n n Charge 9.479!0 94{°0 9.52% 934% 9:56% 9:59% 9.619; 9.649; 9.679; 9:709; 9.73% 9.7710
Year 43 44 45 46 47 46 45 20 24 22 23 24
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. 36042 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective —January 1, 20246 1221 West Idaho Street, Boise, Idaho

Idaho Power Company 9rigiRal First Revised Sheet No. 72-12
Cancels
I.P.U.C. No. 30 Tariff No. 101 Fe rth Revos Ori inal Sheet No. 72-12
G&M Charge 0.80% e-89; e-879; ems°; 0.95% 1.00% 1.04% 1-e9 a a4% 1.19% ate°; 1.30%
Yeaf 25 2-6 27 29 2-9 30 34 32 -3 34 05 06*
The monthly operating and maintenance charges stated above in Table 1 and Table 2 will be
applied as a percentage of the applicable original interconnection investment. Thorn monthly operating
and rnaiRteRaRGe Gharges eSGalate annually and are equivalent to 35 year levelized rates of 0 for
Table 1 and 0 701 fE)r Table 7
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No.36042 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective —January 1, 20246 1221 West Idaho Street, Boise, Idaho

Idaho Power Company QFigiRal First Revised Sheet No. 72-13
Cancels
I.P.U.C. No. 30, Tariff No. 101 Fourth Reyosed0riginal Sheet No. 72-13
SCHEDULE 72
GENERATOR INTERCONNECTIONS
TO PURPA QUALIFYING FACILITY SELLERS
(Continued)
SECTION 2: INTERCONNECTION OF GENERATION FACILITIES (Continued)
Where a Seller's Will Litilize IRterGGRReGti0R FaGilities provided LjRder a prie
agFeeFneRt(s) and the GGrnbiRed term(s) of the P i �:jl 88111 Rt(S) is greater than 35 years, the operation
IDAHO POWER COMPANY
UNIFORM INTERCONNECTION
AGREEMENT
(PURPA)
This Interconnection Agreement ("Agreement") is effective as of the day of
20 , between hereinafter called "Seller," and Idaho Power
Company, hereinafter called "Company."
RECITALS
A. Seller will own or operate a Generation Facility that qualifies for service under Idaho
Power's Commission-approved Schedule 72 and any successor schedule.
B. The Generation Facility covered by this Agreement is more particularly described in
Attachment 1.
AGREEMENTS
1. Capitalized terms used herein shall have the same meanings as defined in Schedule 72
or in the body of this Agreement.
2. This Agreement and Schedule 72 provide the rates, charges, terms and conditions under
which the Seller's Generation Facility will interconnect with, and operate in parallel with, the Company's
transmission/distribution system. Terms defined in Schedule 72 will have the same defined meaning in
this Agreement. If there is any conflict between the terms of this Agreement and Schedule 72, Schedule
72 shall prevail.
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. 36942 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective —January 1, 20246 1221 West Idaho Street, Boise, Idaho

Idaho Power Company QFigiRal First Revised Sheet No. 72-14
Cancels
I.P.U.C. No. 30, Tariff No. 101 Fourth Reyosed0riginal -Sheet No. 72-14
SCHEDULE 72
GENERATOR INTERCONNECTIONS
TO PURPA QUALIFYING FACILITY SELLERS
(Continued)
SECTION 2: INTERCONNECTION OF GENERATION FACILITIES (Continued)
IDAHO POWER COMPANY
UNIFORM INTERCONNECTION
AGREEMENT
(PURPA)
(Continued)
AGREEMENTS (Continued)
n this Agreement is inte-d-e-d- to any other agreement be'%vE_,_.. II_,_ &_ panyandSell_
4. Attached to this Agreement and included by reference are the following:
Attachment 1 —Description and Costs of the Generation Facility, Interconnection Facilities,
and Metering Equipment.
Attachment 2 — One-line Diagram Depicting the Generation Facility, Interconnection
Facilities, Metering Equipment and Upgrades.
Attachment 3— Milestones For Interconnecting the Generation Facility.
Attachment 4 — Additional Operating Requirements for the Company's Transmission
System Needed to Support the Seller's Generation Facility.
Attachment 5— Reactive Power.
Attachment 6 — Description of Upgrades required to integrate the Generation Facility and
Best Estimate of Upgrade Costs.
5. Effective Date, Term, Termination and Disconnection.
5.1 Term of Agreement. Unless terminated earlier in accordance with the provisions
of this Agreement, this Agreement shall become effective on the date specified above and remain
effective as long as Seller's Generation Facility is eligible for service under Schedule 72.
5.2 Termination.
5.2.1 Seller may voluntarily terminate this Agreement upon expiration or
termination of an agreement to sell power to the Company.
5.2.2 After a Default, either Party may terminate this Agreement pursuant to
Section 6.5.
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No.36042 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective —January 1, 20246 1221 West Idaho Street, Boise, Idaho