20250724Comments.pdf

0IQAHO Ro
DONOVAN WALKER
Lead Counsel RECEIVED
dwalker(cD.idahopower.com July 24, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
July 24, 2025
VIA ELECTRONIC MAIL
Commission Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714
Re: Case No. GNR-E-25-01
Commission Staff's Application forApproval of an Oversight Process for the
Acquisition of Large Supply-Side Electric Resources
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Comments in the above-
entitled matter. If you have any questions about the attached documents, please do not
hesitate to contact me.
Very truly yours,
Donovan Walker
DEW:cd
Enclosures
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(a-)_idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION )
STAFF'S APPLICATION FOR ) CASE NO. GNR-E-25-01
APPROVAL OF AN OVERSIGHT )
PROCESS FOR THE ACQUISITION ) IDAHO POWER COMPANY'S
OF LARGE SUPPLY-SIDE ) COMMENTS
ELECTRICAL RESOURCES )
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), in
accordance with the Idaho Public Utilities Commission's ("Commission") Rules of
Procedure 201 , and the Notice of Modified Procedure in this matter, Order No. 36662,
hereby respectfully submits the following Comments.
I. BACKGROUND
1. On March 31, 2025, as directed by Order No. 36309, Commission Staff
("Staff") filed a request with the Commission to modify its Request for Proposal ("RFP")
oversight process. The competitive bidding process for which Idaho Power currently
IDAHO POWER COMPANY'S COMMENTS - 1

follows is in accordance with the Public Utility Commission of Oregon ("OPUC") resource
procurement rules, as directed by the Commission. In Case No. IPC-E-10-03, the
Commission sought to establish competitive bidding guidelines for the RFP process.
However, in 2013, the Commission closed Case No. IPC-E-10-03 without establishing
Idaho-specific resource procurement guidelines, but rather directed Idaho Power to follow
the RFP guidelines applicable to its Oregon service area. The Oregon RFP guidelines to
which the Commission referred were later codified into the administrative rules of the
OPUC resource procurement rules. The OPUC resource procurement rules impose
competitive bidding requirements upon an electric utility for the acquisition of a resource
or a contract for more than an aggregate of 80 megawatts (WW") and five years in length,
among other requirements.
2. The acknowledgement of the final shortlist for procurement of resources
under the competitive bidding rules is an extensive process, spanning 15 months or more,
that employs a fair and competitive RFP process. This 15-month timeline is solely related
to the RFP process and due diligence and does not include contract negotiation, contract
execution, material procurement, and construction, which can take another two to six
years, depending on the resource. As such, the Company believes the process is too
lengthy, especially during times of rapid changes in Idaho Power's capacity deficiency.
3. Staff also believes the current RFP process is too lengthy, identifying
systematic flaws and in Case No. IPC-E-24-12, In the Matter of Idaho Power Company's
Application for Approval of a Market Purchase Agreement, recommended these flaws are
addressed for future RFPs. In their final order in that case, Order No. 36309, the
Commission directed Idaho Power to work with Staff"to address any issues and develop
IDAHO POWER COMPANY'S COMMENTS -2

any potential modifications to the RFP process as necessary" and directed Staff to "file a
new case before the Commission and present any requested modification to the RFP
process for consideration by the Commission." Staff's Application in this case is a result
of that order and requests that the Commission (1) rescind Order No. 32745 for Idaho
Power to comply with Oregon RFP guidelines, and (2) direct the Company to apply for
and receive Commission approval of each new RFP prior to issuing it for the acquisition
of large supply-side resources in accordance with the requirements outlined in Staff's
Application.'
II. IDAHO POWER COMMENTS
A. The Company Agrees with Staff's Primary Objective for the Modifications to
the RFP Oversight Process.
4. Staff identified the primary objective of their proposal "is to establish a
regulatory process that will ensure resources selected by Idaho's investor-owned electric
utilities ("Utility" or "Utilities") are least-cost and least-risk and are able to meet the
required needs of the system"2 while also meeting other specified criteria. The first of
those criteria is "minimizing the amount of administrative burden and potential delays
needed for Utilities to make a resource decision." Idaho Power agrees with Staff's
assessment and supports the recommendation to modify the RFP oversight process to
reduce delays in resource procurement decisions.
5. As noted by Staff Witness Mr. Matthew Suess when discussing the 2026
RFP process, "the entire RFP solicitation process took approximately 17 months from
when Idaho Power filed its initial application with the Oregon Public Utilities Commission
GNR-E-25-01 Application, page 7.
2 Id., page 1.
IDAHO POWER COMPANY'S COMMENTS - 3

("OPUC") in September 2022, until the final selection list was approved in February
2024."3 The lengthy process makes it difficult for the Company, and developers of projects
that did not make the final shortlist, or those lower on the shortlist whose contract
negotiations may occur after higher ranked projects, to maintain project schedules and
material procurement timelines to ensure proposed commercial operation dates are met.
The process length hinders development of resource projects and impacts the Company's
ability to meet future capacity needs. This is evidenced in Case No. IPC-E-24-45, Idaho
Power's request for a Certificate of Public Convenience and Necessity ("CPCN") for 100
MW of battery energy storage, where two alternative resources were procured when the
Company was unable to contract with any of the remaining 2026 projects bid into the
2026 RFP, including both final shortlist projects and initial shortlist projects due to
developers' inability to maintain the submitted project timelines. A streamlined RFP
oversight process is necessary to minimize potential delays in the procurement of
resources.
6. The second criteria recommended by Staff is to establish a regulatory
process that is "[m]aximizing the Utility's flexibility to tailor its selection process for a given
set of circumstances when requiring additional resources.114 Idaho Power recognizes the
value of Staff's proposed Procedures for Soliciting Large Supply-Side Resources outlined
in Attachment A to Staff's Application ("Attachment A") and the flexibility the Standard
Solicitation Process will provide when preparing and executing an RFP to acquire
resources. Staff's proposed guidelines that require the Company to file an application
requesting approval of the RFP will afford Idaho Power the opportunity to support its
3 Direct Testimony of Mr. Suess, page 4.
4 GNR-E-25-01 Application, page 1.
IDAHO POWER COMPANY'S COMMENTS -4

proposed solicitation, providing all necessary documentation to substantiate the
solicitation. In addition, the Waiver Process allows for the opportunity to request a waiver
from the guidelines should a unique, time-sensitive resource acquisition arise. Idaho
Power appreciates Staff's recognition "that oversight of each Company's solicitation
process should be applied as infrequently as possible to minimize regulatory impact"5 and
believes the proposed procedures attempt to do so.
7. Finally, Staff's recommended criteria is that the regulatory process
11adher[es] to a set of requirements and guiding principles (Attachment A to the
Application)when developing its selection process for each new set of resources."6 Idaho
Power appreciates Staff's streamlined Procedures for Soliciting Large Supply-Side
Resources as outlined in Attachment A and supports implementation of the guiding
principles and procedures detailed therein. As discussed, the existing competitive bidding
process Idaho Power is required to follow is an extensive process that spans 15 months
or more for approval of the final shortlist of resources identified under the competitive
bidding rules. This timeline does not include the additional time needed for contract
negotiation and contract execution, nor does it account for the subsequent proceedings
necessary in Idaho when contracts are executed: the request for a CPCN for Company-
owned resources or approval of agreements associated with third-party resources.
Combined, these processes add a minimum of one year to the already lengthy
procurement process.
8. Staff's proposal significantly reduces the procurement period, better
positioning the Company to meet resource acquisition timelines. Furthermore, Staff's
5 GNR-E-25-01 Application, page 4.
6 GNR-E-25-01 Application, page 1.
IDAHO POWER COMPANY'S COMMENTS - 5

proposed Idaho process is in line with the intent of the existing Oregon process to ensure
a fair and impartial competitive bidding process, offering the opportunity for the Company
to adhere to the competitive bidding guidelines in each jurisdiction without the burden of
additional steps that would extend an already lengthy process. The guiding principles and
procedures detailed in Attachment A will allow for the continued procurement of resources
under a fair and competitive RFP process while also reducing gaps inherent in the existing
processes.
B. Idaho Power Supports Staff's Proposed Application of the Procedures for
Soliciting Large Supply-Side Resources.
9. The Company appreciates Staff's recognition that "[o]nly the most
financially consequential investments would be subject to additional regulatory oversight"'
and the resulting recommendation that the guiding principles and procedures detailed in
Attachment A apply to those supply-side generating or storage resources 100 MW or
greater and for a duration of 10 years or more to minimize the "regulatory burden."$ As
evidenced in Idaho Power's recent requests for CPCNs to acquire resources to be online
in 2023, 2024, 2025, 2026 and 2027,9 all of these resources, with the exception of one,
would meet the higher threshold of 100 MW and a 10-year duration; only the 200 MW
market purchase agreement approved in Case No. IPC-E-24-12 would have been
excluded from the requirement to be procured under the competitive bidding guidelines.
Furthermore, Staff's proposal to exclude transmission resources from the proposed
guidelines would have excluded the same market purchase resource from the RFP
GNR-E-25-01 Application, page 4.
8 GNR-E-25-01 Application, page 4.
9 Case Nos. IPC-E-22-13, IPC-E-23-05, IPC-E-23-20, IPC-E-24-12, IPC-E-24-16, IPC-E-24-45, IPC-E-24-
46, and IPC-E-25-10.
IDAHO POWER COMPANY'S COMMENTS - 6

oversight process. Of the least-cost, least-risk resources procured since 2023, which
includes both Company-owned resources and third-party resources, the movement of the
application to supply-side generating or storage resources 100 MW or greater and for a
duration of 10 years or more would have had little impact on the acquisitions required to
be competitively procured under Commission oversight.
10. Idaho Power further supports Staff's proposal that the oversight process
excludes transmission resources. In addition to being homogenous in type as Staff
suggested,10 the Company has discovered through both the issuance of RFPs and
through attempts to procure in the short-term, wholesale bilateral energy purchase
opportunities can be time limited. There are few counterparties that have the willingness
to submit a bid to commit surplus generation capacity to a sale that will not be fully
negotiated and executed for a year or more in advance, as the All-Source RFPs typically
request. This is evidenced by the bids submitted in both the 2026 and 2028 RFPs, which
combined, solicited resources beginning 2026 and beyond, and only one market
purchase bid was submitted.
11. While the Company supports Staff's proposed guidelines apply to those
supply-side generating or storage resources, excluding transmission resources, 100 MW
or greater and for a duration of 10 years or more, Idaho Power proposes the guidelines
also exclude those resources the Company procures under contractual arrangements
with a specific customer. For example, under the Clean Energy Your Way ("CEYW")
program, customers may collaborate with Idaho Power to construct a dedicated
renewable energy resource to meet their specific sustainability or carbon reduction goals.
10 GNR-E-25-01 Application, page 5.
IDAHO POWER COMPANY'S COMMENTS - 7

Under this arrangement, the customer pays for the resource procured on their behalf. The
Company received a waiver of the competitive bidding rules from the OPUC" for
resources procured on behalf of a customer and proposes the new Idaho guidelines also
include an exemption for resources procured on behalf of a specific customer for which
the cost of that resource is assigned to that specific customer.
III. CONCLUSION
12. Idaho Power acknowledges and appreciates the extensive work by Staff to
develop the guidelines outlined in Attachment A and believes the guiding principles and
procedures address the issues inherent in the Oregon competitive bidding rules. The
Company supports Staff's recommendation that the Commission (1) rescind Order No.
32745 for Idaho Power to comply with the Oregon RFP guidelines, (2)direct the Company
to apply for and receive Commission approval of each new RFP prior to issuance for the
acquisition of large supply-side resources in accordance with the requirements outlined
in Attachment A, and (3)exempt from the Idaho RFP guidelines resources procured under
contractual arrangements with a specific customer for which the customer pays for the
resource procured on their behalf.
DATED at Boise, Idaho this 24th day of July 2025.
f&)wk L
DONOVAN E. WALKER
Attorney for Idaho Power Company
" Docket UM 2226, Order No. 22-082.
IDAHO POWER COMPANY'S COMMENTS - 8

CERTIFICATE OF SERVICE
HEREBY CERTIFY that on the 24th day of July, 2025, 1 served a true and correct
copy of Idaho Power Company's Comments upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Chris Burdin U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email Chris.Burdin(a)_puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Avista Utilities Hand Delivered
David J. Meyer U.S. Mail
Shawn Bonfield Overnight Mail
P.O. Box 3727 FAX
1411 E. Mission Ave. MSC 13 X Email - david.meyer(a)_avistacorp.com
Spokane, WA 99220 shawn.bonfield(a).avistacorp.com
AvistaDockets(aD-avistacorp.com
Industrial Customers of Idaho Hand Delivered
Peter J. Richardson U.S. Mail
Richardson Adams, PLLC Overnight Mail
515 N. 27th St. FAX
Boise, ID 83702 X Email — peter _richardsonadams.com
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Austin W. Jensen FAX
Holland & Hart LLP X Email daruesch hoffCa)_hol land hart.com
555 17th Street, Suite 3200 tnelson hol land ha rt.corn
Denver, CO 80202 awlensen(a)_hol land hart.com
karoach _hollandhart.com
aclee(o)_hollandhart.com
NIPPC Hand Delivered
Greg M. Adams U.S. Mail
Richardson Adams, PLLC Overnight Mail
515 N. 27th St. FAX
Boise, ID 83702 X Email — greg richardsonadams.com
IDAHO POWER COMPANY'S COMMENTS - 9

Irion Sanger Hand Delivered
Sanger Law, PC U.S. Mail
4031 SE Hawthorne Blvd. Overnight Mail
Portland, OR 97214 FAX
X Email — irion sanger-law.com
Rocky Mountain Power Hand Delivered
Mark Alder U.S. Mail
Joe Dallas Overnight Mail
1407 West North Temple, Suite 330 FAX
Salt Lake City, Utah 84116 X Email — mark.alder(a).pacificorp.com
Joseph.dal las(cD-pacificorp.com
C9 >
Christy Davenport
Legal Administrative Assistant
IDAHO POWER COMPANY'S COMMENTS - 10