20250725Application.pdf

NIOAWKwERO
DONOVAN E. WALKER
Lead Counsel
dwalker(Wjdahopower.com RECEIVED
July 25, 2025
July 25, 2025 IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC FILING I PC-E-25-25
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-25-25
Idaho Power Company's Application for Approval of the Capacity Deficiency
to be Utilized for Avoided Cost Calculations
Dear Commission Secretary:
Attached please find Idaho Power Company's Application to be filed in the above-
entitled matter.
Attachment No. 2 to this Application is confidential and will be sent in a separate
email to the parties after the Protective Agreement has been executed.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
c -�Donovan E.E. Walker
DEW:cd
Attachments

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Idaho Power Company's Application for Approval of the Capacity Deficiency to be
Utilized for Avoided Cost Calculations
Case No. IPC-E-25-25
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Attachment No. 2 to Idaho Power Company's Application dated July 25,
2025, may contain information that Idaho Power Company claims is a confidential trade
secret and business records of a private enterprise required by law to be submitted to or
inspected by a public agency as described in Idaho Code § 74-101 , et seq., and/or § 48-
801, et seq. As such, it is protected from public disclosure and exempt from public
inspection, examination, or copying.
DATED this Friday, July 25, 2025.
Z C()d-,
Donovan Walker
Counsel for Idaho Power Company

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
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]
mgoicoecheaallen(a-),idahopower.com
dwalker(a-)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-25-25
APPROVAL OF THE CAPACITY )
DEFICIENCY TO BE UTILIZED FOR ) APPLICATION
AVOIDED COST CALCULATIONS. )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with RP 52,
the applicable provisions of the Public Utility Regulatory Policies Act of 1978 ("PURPA"),
and Idaho Public Utilities Commission ("Commission") Order Nos. 32697, 33084, 33159,
and 35810 hereby respectfully submits this Application requesting an order for approval
of the capacity deficiency period to be utilized for the Company's avoided cost
calculations. Idaho Power's 2025 Integrated Resource Plan ("IRP") indicates a first
capacity deficit of June 2027, as shown in Attachment 1. Idaho Power asks for
Commission approval of the capacity deficiency period with a first deficit occurring in June
2027. In support of its Application, Idaho Power states as follows:
APPLICATION - 1

I. INTRODUCTION
1. In Order No. 32697, the Commission directed that a case be initiated
outside of each utility's IRP filing for the establishment of the capacity deficiency period
to be utilized in the utility's Surrogate Avoided Resource ("SAR") methodology.
[W]e find it reasonable and fair to subject each utility's
determination of capacity deficiency to further scrutiny.
Therefore, when a utility submits its Integrated Resource Plan
to the Commission, a case shall be initiated to determine the
capacity deficiency to be utilized in the SAR Methodology.
The capacity deficiency determined through the IRP planning
process will be the starting point, and will be presumed to be
correct subject to the outcome of the proceeding.
Order No. 32697, p. 23.
2. In Order No. 33159, the Commission found it just and reasonable to utilize
the same first capacity deficit determination for purposes of the incremental cost IRP
methodology. The Commission stated:
In calculating a QF's ability to contribute to a utility's need for
capacity, we find it reasonable for the utilities to only begin
payments for capacity at such time that the utility becomes
capacity deficient. If a utility is capacity surplus, then capacity
is not being avoided by the purchase of QF power. By
including a capacity payment only when the utility becomes
capacity deficient, the utilities are paying rates that are a more
accurate reflection of true avoided cost for the QF power.
Order No. 33159, p. 7.
3. In Order No. 35810, the Commission found it reasonable that each utility
file its application for a new capacity deficiency date, based on its most recent Integrated
Resource Plan, within 30 days of the filing of the Plan with the Commission. Order No.
35810, p. 3.
4. In Order No. 36070, the Commission provided additional guidance on the
capacity deficiency date filings, including that these filings should use the most recent
APPLICATION - 2

load forecast, should provide information substantiating any proposed inclusion of
Capacity Benefit Margin ("CBM"), should exclude any Western Resource Adequacy
Program ("WRAP") capacity benefit assumptions until the Company has made a binding
commitment to join WRAP, and should only include resources that are sufficiently certain.
Order No. 36070, p. 4.
II. CAPACITY DEFICIENCY PERIOD
5. Idaho Power's current approved capacity deficiency date, as accepted in
Order No. 36226, is June 2026.' Idaho Power filed its 2025 IRP with the Commission on
June 27, 2025, in Case No. IPC-E-25-23.2 Idaho Power's 2025 IRP identifies the first
capacity shortfall as occurring in June 2027.3 The assumptions in the 2025 IRP analysis
resulting in this deficiency date include:
• Idaho Power's 2025 IRP load forecast, which was published January 2025;
• 0 MW of Capacity Benefit Margin;
• 0 MW of WRAP capacity benefit;4
• 0 MW associated with existing PURPA resources entering into new
contracts when their current agreements expire, and 0 MW associated with
new PURPA development;5
See Order No. 36226.
2 Idaho Power Company's 2025 Integrated Resource Plan ("IRP"), Case No. IPC-E-25-23 (filed June 27,
2025).
3 Id. at 142 of the 2025 IRP Report. The assumptions used to identify the capacity deficiency date are
also described on p. 142 and differ in certain respects from the assumptions used in IRP portfolio
development, as described on that page.
4 Id. As discussed on p. 142, the 14 MW of WRAP capacity benefit that is assumed in the IRP portfolio
development is removed from the analysis to determine the pre-portfolio annual capacity positions.
5 Id. As discussed on p. 142, the PURPA assumptions regarding the rates at which existing PURPA
resources enter into new agreements when their existing agreements expire, and regarding rates of new
PURPA development, that are included in some of the IRP portfolios, are removed from the analysis to
determine the annual capacity position.
APPLICATION - 3

• Capacity associated with resources for which there are executed
agreements.
For purposes of this filing, Idaho Power provides the following additional information and
updates to the starting point of the 2025 IRP analysis, consistent with the Commission's
guidance in Order No. 36070:
A. Load Forecast
6. Consistent with the Commission's guidance in Order No. 36070, Idaho
Power updated the analysis to include Idaho Power's most recent load forecast, published
in March 2025. The resulting capacity deficiency date remained the same: June 2027. Of
note, the differences between the January 2025 load forecast used in the 2025 IRP, and
the March 2025 load forecast, are minimal. The differences are shown in Table 1 below
and are due to the March 2025 forecast including updated actual sales and peaks through
2024 and other updates to the model inputs to include the most recent available
information.
APPLICATION - 4

Table 1: January 2025 Load Forecast vs. March 2025 Load Forecast, for 2026-2028
70th Percentile Peak Load Forecast(MW)
Month-Year January 2025 March 2025 Difference
Load Forecast Load Forecast (March-January)
Jan-2026 2,628 2,649 22
Feb-2026 2,491 2,518 26
Mar-2026 2,250 2,265 15
Apr-2026 2,115 2,124 10
May-2026 2,691 2,692 1
Jun-2026 4,000 4,006 6
Jul-2026 4,001 4,007 6
Aug-2026 3,597 3,628 31
Sep-2026 3,235 3,179 (56)
Oct-2026 2,236 2,252 17
Nov-2026 2,521 2,550 29
Dec-2026 2,705 21702 (3)
Jan-2027 2,847 2,868 21
Feb-2027 2,730 2,758 28
Mar-2027 2,475 2,493 17
Apr-2027 2,342 2,354 12
May-2027 2,928 2,934 6
Jun-2027 4,285 4,299 14
Jul-2027 4,286 4,300 14
Aug-2027 3,900 3,935 35
Sep-2027 3,530 3,487 (43)
Oct-2027 2,534 2,562 28
Nov-2027 2,797 21837 40
Dec-2027 2,984 2,987 3
Jan-2028 3,144 3,146 2
Feb-2028 2,939 2,983 44
Mar-2028 2,724 2,748 24
Apr-2028 2,573 2,586 12
May-2028 3,158 3,163 5
Jun-2028 4,523 4,535 12
Jul-2028 4,524 4,536 12
Aug-2028 4,141 4,176 34
Sep-2028 3,753 3,711 (42)
Oct-2028 2,736 2,766 30
Nov-2028 2,989 3,032 43
Dec-2028 3,175 3,181 6
APPLICATION - 5

B. CBM and WRAP Capacity Benefit Assumptions
7. The 2025 IRP assumed 0 MW of Capacity Benefit Margin, and that
assumption has been carried over into the capacity deficiency date analysis here as well.6
Therefore, Capacity Benefit Margin has no effect on the capacity deficiency date. Further,
as discussed above, the 2025 IRP capacity position analysis excluded the 14 MW of
capacity benefit associated with the WRAP program beginning in Summer 2027 that was
ultimately included in the Preferred Portfolio. The WRAP capacity benefit remains
excluded from the analysis in this proceeding.
C. PURPA Replacement Contracts and PURPA Forecasts
8. The 2025 IRP Preferred Portfolio assumed a 75% replacement contract rate
for expiring existing PURPA contracts where historical replacement contract data was not
available, and a forecast rate of new PURPA resource development based on recent
history. The 2025 IRP capacity position analysis excluded both the PURPA replacement
contract rate and the PURPA new development rate. These specific PURPA replacement
rate and new development rate assumptions remain excluded from the analysis in this
proceeding.
D. Future Resources
9. The 2025 IRP capacity position analysis included the contributed capacity
from resources with which Idaho Power has existing agreements. These resources are
listed in Table 2 below.
6 Idaho Power's analysis regarding Capacity Benefit Margin has been described in proceedings before
the Commission, including, for example, Case No. IPC-E-24-16, in the Company's Testimony of Jared L.
Ellsworth, at 14-16.
APPLICATION - 6

Table 2: Executed Agreements for Future Resources Included in Capacity Deficiency Date Analysis
Resource Agreement Agreement Project IPUC
Executed? Approved? 7 Online Date Case No.
200 MW Market Purchase Yes Yes Jun. 2026 IPC-E-24-12
Valmy Unit 1 & Unit 2 Pending Jan. 2026 (Unit 1)&
Conversion to Gas Yes Review May 2026 (Unit 2) IPC-E-25-03
PVS 2 Solar PPA Yes Yes Jun. 2026 IPC-E-24-01
Boise Bench 150 MW BESS Yes Yes Jun. 2026 IPC-E-24-16
Two 50 MW BESS Sites Pending
(Boise Bench Expansion & Yes Review Jun. 2026 IPC-E-24-45
Hemingway Expansion)
Jackalope Wind Yes Yes Jun. 2027 IPC-E-24-46
(PPA& Build-Transfer Agreement)
Crimson Orchard Solar& BESS Yes Pending Apr. 2027 IPC-E-25-10
(PPA& Battery Tolling Agreement) Review
Blacks Creek Solar Yes Yes Dec. 2027 IPC-E-24-42
10. It is not entirely clear as to whether inclusion of future resources that are
"sufficiently certain" as referenced in Order No. 36070 is limited only to those that have
obtained Commission approval, or whether that includes such agreements as those listed
above that have been fully executed following protracted regulatory procurement
proceedings and negotiations and are pending approval with the Commission. The
Company believes in this instance that it is appropriate to include all of the resources
listed above and included in the 2025 IRP capacity deficiency date determination. While
some of them have been approved by the Commission, and others are currently under
Commission review, all are executed agreements for resources that the Company is
relying on to meet its upcoming capacity needs. These resources and agreements were
evaluated against all other options and determined to be the least-risk, least-cost
Agreement approved by Idaho Public Utilities Commission.
APPLICATION - 7

resources to meet the capacity needs, and they were executed with intent to serve those
needs. Thus, they are sufficiently certain to be relied on for the capacity deficiency date
analysis. Inclusion of these resources results in the capacity deficiency date of June 2027.
Additionally, excluding contracted, not-yet-approved resources from the capacity
deficiency analysis could result in the double payment of capacity by customers should a
PURPA QF project come online prior to June 2027.
11. Should the Commission determine that only those resources previously
approved by the Commission should be included in the first capacity deficit determination
for purposes of avoided cost pricing, the Company has also performed the analysis to
determine the capacity deficiency date. That date is June 2026.
12. The Company believes that inclusion of executed agreements for new
resources — including those that are pending Commission review — is appropriate in
determining the capacity deficiency date for PURPA avoided cost pricing, in this case
leading to a June 2027 capacity deficiency date, as shown in Attachment 1.
13. The Company is also including Confidential Attachment 2 setting forth the
seasonal analysis for purposes of the SAR model pursuant to Staff's request in the
Company's last capacity deficiency date filing in IPC-E-23-27. As explained in the
Company's Supplemental Compliance filing in that case, while Idaho Power's method of
determining annual capacity positions does not produce monthly (or seasonal) capacity
position information, the Company understands that the SAR Model distinguishes
summer and winter deficits. As a result, consistent with the approach it used in IPC-E-23-
27, the Company developed seasonal capacity positions using the LOLE methodology
APPLICATION - 8

with a 0.05 event-days per season threshold in order to provide the necessary inputs for
use in the SAR Model, which are set forth in Confidential Attachment 2.
III. MODIFIED PROCEDURE
14. Idaho Power believes that a 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.
If, however, the Commission determines that a technical hearing is required, the
Company stands ready to prepare and present its testimony in such hearing.
IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
15. Communications and service of pleadings with reference to this Application
should be sent to the following:
Donovan E. Walker Camille Christen
Megan Goicoechea Allen Energy Contracts
Regulatory Dockets 1221 West Idaho Street (83702)
1221 West Idaho Street (83702) P.O. Box 70
P.O. Box 70 Boise, ID 83707
Boise, ID 83707 cchristen(a)_idahopower.com
dwalker idahopower.com energycontracts(a�_idahopower.com
mgoicoecheaallen(a�_idahopower.com
dockets(a�idahopower.com
V. CONCLUSION
16. Idaho Power respectfully requests that the Commission issue an order
approving the first capacity deficiency date of June 2027 to be utilized in the Company's
avoided cost determinations under the SAR and IRP methodologies.
APPLICATION - 9

Respectfully submitted this 25th day of July 2025.
DONOVAN WALKER
Attorney for Idaho Power Company
APPLICATION - 10

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

Excerpt from 2025 IRP Report, p. 142-143
11.Preferred Portfolio and Near-Term Action Plan
Annual Capacity Positions
To align with and represent the probabilistic reliability analyses utilized in the 2025 IRP,the
company provides below the annual capacity positions before and after the incorporation of
the Preferred Portfolio resource buildout(Table 11.15).The pre-Preferred Portfolio annual
capacity positions represent the company's resource and load inputs at the time of the 2025
IRP analysis,with the following notable base changes:
• No PURPA replacement contracts and no PURPA forecast
• No 2027 and 2028 resource adjustments
• Exit Bridger units 3 and 4 in 2030
• No WRAP capacity benefit
The resulting capacity deficiency of approximately 54 MW in 2027,and the generally growing
deficit,clearly demonstrates the company's on-going capacity needs.
Table 11.14 Pre and post Preferred Portfolio annual capacity positions
Annual Capacity Position(MW)
Year Existing&Contracted Resource Only Add Preferred Portfolio Resources
2026 61 Length 66 Length
2027 1541 Shortfall 47 Length
2029 (1051 Shortfall 22 Length
2029 (2971 Shortfall 66 Length
2030 (6771 Shortfall 222 Length
2031 (6561 Shortfall 302 Length
2032 (7901 Shortfall 197 Length
2033 (8741 Shortfall 151 Length
2034 (9591 Shortfall 161 Length
2035 (7621 Shortfall 232 Length
2036 (7971 Shortfall 212 Length
2037 (9101 Shortfall 173 Length
2038 (9471 Shortfall 131 Length
2039 (9771 Shortfall 94 Length
2040 11,0111 Shortfall 68 Length
2041 (1,0471 Shortfall 78 Length
2042 (3,0771 Shortfall 55 Length
2043 (3,1461 Shortfall 60 Length
20" (L171) Shortfall 64 Length
2045 (1,265) Shortfall 64 Length
r=ge .:? 2025 Integrated Resource Plan

Il.Preferred Portfolio and Near-Term Action Plan
The first month of deficiency was determined to be the first month that exceeded a
0.0083 event-days per year LOLE (or 0-1 divided by 12)on the first year of capacity deficiency
(2027)- Fur LhiN IRP,Lfre fir�,L rtrurrllt uver LhdL Llrre�,ltuhf wdN June 2027,d>>Iruwn in Figure 11.1-
Monthly LOLL ortfall t hreshold
007
Q 006
is
u
n 005
x
w
'o
0 004
`o
N
N
0-03
2
t
c
0 0.02
n
N
0 001
000 — _ 1 ■ — _ _ ■
ago oso �a P eT ` °i' pc`o e, d�
figure 11.1 First month of capacity shortfall
More information on the LOLE-derived capacity position calculation can be found in the System
Reliability Modeling—Portfolio Analysis section of Appendix D—System Reliability and
Regulating Reserves.

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-25
IDAHO POWER COMPANY
CONFIDENTIAL
ATTACHMENT NO. 2

Seasonal Capacity Positions
Annual Positions
Capacity Deficiency Update- Position (MW)
Annual at LOLE Threshold of 0.1 Event-Days per Year
Contracted Contracted &Approved
Year Difference
Resources Resources
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2033
2039
2040
2041
2042
2043
2044
2045

Summer Positions
Capacity Deficiency Update - Position (MW)
Summer at LOLE Threshold of 0.05 Event-Days per Year
Contracted Contracted &Approved
Year Difference
Resources Resources
2026
2027
2O2S
2029
2O3C
2031
2032
2033
2034
2035
2036
2037
2035
2039
2040
2041
2042
2043
204=1
2045

Winter Positions
Capacity Deficiency Update - Position (MW)
Winter at LOLE Threshold of 0.05 Event-Days per Year
Contracted Contracted &Approved
Year Difference
Resources Resources
2026
2027
2023
2029
2030
2031
2032
2033
2034
2035
2036
2037
2033
2039
2040
2041
2042
2043
2044
2045