20250919Application.pdf

qNEMQAHOPOWERS
RECEIVED
DONOVAN WALKER SEPTEMBER 19, 2025
IDAHO PUBLIC
Lead Counsel
dwalker(a�idahopower.com UTILITIES COMMISSION
September 19, 2025
VIA ELECTRONIC FILING
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. I PC-E-25-29
Application of Idaho Power Company's for a Certificate of Public
Convenience and Necessity for the Bennett Gas Expansion Project and for
an Associated Accounting Order
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's ("Idaho Power")
Application, the Direct Testimony of Jared Ellsworth, the Direct Testimony of Eric Hackett
and Exhibits, and the Direct Testimony of Courtney Waites in the above matter. Word
versions of the testimonies will be sent in a separate email for the Reporter.
Also attached is a Protective Agreement. The confidential documents will be sent
to the parties who execute the Protective Agreement.
If you have any questions about any of the aforementioned documents, please do
not hesitate to contact me.
Very truly yours,
Donovan E. Walker
DEW:sg
Enclosures
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Application of Idaho Power Company for Approval of a Certificate of Public
Convenience and Necessity for the Bennett Gas Expansion Project and for an
Associated Accounting Order
Case No. IPC-E-25-29
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Direct Testimony of Courtney Waites and Exhibit Nos. 2, and 3 to the
Direct Testimony of Eric Hackett, dated September 19, 2025, may contain information
that Idaho Power Company and a third party claim is a confidential trade secret, business
records of a private enterprise required by law to be submitted or to be inspected by a
public agency, and/or public records exempt from disclosure by state or federal law
(material nonpublic information under U.S. Securities and Exchange Commission
Regulation FD) 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 19th day of September 2025.
Donovan Walker
Counsel for Idaho Power Company

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 IDAHO POWER )
COMPANY'S APPLICATION FOR A ) CASE NO. IPC-E-25-29
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR THE BENNETT ) APPLICATION
GAS EXPANSION PROJECT AND FOR AN )
ASSOCIATED ACCOUNTING ORDER. )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho
Code §§ 61-501, 61-502, 61-503, 61-508, 61-524, 61-526; as well as Rule of Procedure
("RP") 52, 112 and 201 hereby respectfully makes application to the Idaho Public Utilities
Commission ("Commission") for an order (1) granting a Certificate of Public Convenience
and Necessity ("CPCN") for the expansion of the existing Bennett Mountain Power Plant
to include the addition of a cost-effective natural gas-fueled facility providing up to 167
megawatts ("MW") of generation ("Bennett Gas Expansion Project") to meet an identified
capacity deficit in 2028, (2) confirmation of the Company's application of accrual of
APPLICATION FOR A CPCN - 1

Allowance for Funds Used During Construction ("AFUDC")for the Bennett Gas Expansion
Project upon initial procurement activities for the reciprocating internal combustion
engines ("recips"), and (3) approving the commencement of the accrual of AFUDC on
capital expenditures associated with future resource procurements at the time the project
has been deemed viable by the Company. The Bennett Gas Expansion Project is
necessary for Idaho Power to continue to provide safe, reliable electric service in 2028
and beyond.
Accompanying this Application are three sets of testimony. The Direct Testimony
of Jared L. Ellsworth presents the Company's need for new resources to meet an
identified capacity deficit in 2028 as informed by the 2023 Integrated Resource Plan
("IRP") and subsequently further enhanced through system reliability evaluations, which
led to the solicitation through a Request for Proposals ("RFP") seeking to acquire energy
and capacity necessary to address the identified near-term capacity needs. Mr. Ellsworth
then describes the most recent assessment of system reliability and its impact to the
capacity deficit, supporting the acquisition of resources to address the identified near-
term capacity needs.
The Direct Testimony of Eric Hackett provides an overview of the competitive
resource acquisition process undertaken to meet Idaho Power's identified capacity
deficiency, and the resulting fair and competitive RFP process that was fully compliant
with the required Oregon resource procurement rules, leading to the selection of the least-
cost, least-risk resource necessary to meet the Company's electric energy needs in 2028,
the Bennett Gas Expansion Project for which Idaho Power is requesting the Commission
grant a CPCN in this proceeding. The Bennett Gas Expansion Project is a natural gas
APPLICATION FOR A CPCN - 2

facility that will be constructed alongside Idaho Power's existing Bennett Mountain Power
Plant in Mountain Home, Idaho, and will consist of nine, fast-ramping, natural gas fueled
recip units that will provide up to 167 MW of generation.
Finally, the Direct Testimony of Ms. Courtney Waites describes AFUDC and the
commencement of its accrual as soon as funds are expended and committed to a
construction project. For generation resources, this has typically occurred subsequent to
the request for a CPCN. However, Idaho Power has incurred expenditures associated
with the Bennett Gas Expansion Project prior to filing the request for a CPCN and
therefore the Company is requesting the Commission confirm the application of accrual
of AFUDC when expenditures are first incurred for the Bennett Gas Expansion Project
and any viable future resource procurements.
I. CORPORATE STATUS
1. Idaho Power is a corporation incorporated under the laws of the state of
Idaho. Idaho Power is engaged in the business of generating, purchasing, transmitting,
and distributing electric energy and providing retail electric service in the states of Idaho
and Oregon. Idaho Power's principal offices are situated in Boise, Idaho, and its address
is 1221 West Idaho Street, Boise, Idaho 83702. Copies of Idaho Power's Articles of
Incorporation and Certificates of Convenience and Necessity are on file with the
Commission. Idaho Code § 61-528.
II. BACKGROUND
2. The Company's annual capacity positions developed to inform the 2023 IRP
identified deficits of 138 MW of incremental capacity needs in 2028 and 555 MW of
supply-side resource additions in the Preferred Portfolio in 2028. Further, the 2023 IRP
identified incremental capacity needs of 142 MW in 2029 and growing to over 1,150 MW
APPLICATION FOR A CPCN - 3

by 2038. As described more completely in the Direct Testimony of Mr. Ellsworth, the
Company recognizes that during the near-term resource decision-making phase, the
annual capacity positions can be very fluid and therefore regularly performs system
reliability assessments. Idaho Power constantly monitors resource needs, and in the face
of growing loads and deficits has responded with added and appropriate urgency to
acquire additional low-cost, reliable sources of generation and capacity, as evidenced by
the Company's consecutive requests to acquire resources to be online in 2023,' 2024,2
2025,3 2026,4 and 5 2027. Idaho Power expects to acquire additional resources each year
thereafter through 2028 and beyond. See, OPUC Case No. UM 2317, In the Matter of
Idaho Power Company's Application for Approval of 2028 All-Source Request for
Proposals to Meet 2028 Capacity Resource Need.
3. Under Idaho law, Idaho Power has an obligation to provide adequate,
efficient, just, and reasonable service on a nondiscriminatory basis to all those that
request it within its service area. Idaho Power has experienced and expects sustained
load growth, thereby requiring the addition of new resources. To meet its obligation to
reliably serve customer load and fill capacity deficiencies identified in 2028 and beyond,
the Company conducted a competitive solicitation through the issuance of an All-Source
RFP seeking to acquire a combination of energy and capacity resources. Idaho Power
did not define the type of resource (i.e., wind, solar, gas, or battery storage) desired;
however, the Company outlined that the deficit identifies 138 MW of incremental peak
Case Nos. IPC-E-22-06 and IPC-E-22-13.
2 Case Nos. IPC-E-23-05 and IPC-E-23-20.
3 Case Nos. IPC-E-2-29 and IPC-E-23-20.
I Case Nos. IPC-E-24-12, IPC-E-24-16, and IPC-E-24-45.
5Case Nos. IPC-E-24-42, IPC-E-24-46, IPC-E-25-10, and IPC-E-25-27.
APPLICATION FOR A CPCN -4

capacity needs in 2028 and 555 MW of supply-side resource additions in the Preferred
Portfolio in 2028 ('2028 RFP"). The procurement process resulted in the identification of
least-cost, least-risk resources necessary to fill the identified 2028 capacity deficiency of
265 MW. The proposed acquisitions, as described herein, are necessary and required in
order to continue to provide reliable and adequate electric service to Idaho Power's
customers starting in the summer of 2028 and into the future.
III. OREGON PROCUREMENT RULES
4. The Commission, in Case No. IPC-E-10-03, initiated a case seeking to
establish competitive bidding guidelines for the RFP process. In 2013, the Commission
closed Case No. IPC-E-10-03 without establishing Idaho-specific resource procurement
guidelines, but rather directing Idaho Power to follow the RFP guidelines applicable to its
Oregon service territory. The Oregon RFP guidelines to which the Commission referred
were later codified into the administrative rules of the Public Utility Commission of Oregon
("OPUC") resource procurement rules.6 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 MWs and five years in length," among
other requirements.
5. Idaho Power initiated the rule compliant RFP process on February 29, 2024,
to acquire resources to be online in 2028 and beyond. Following feedback from
stakeholders, the Company updated the 2028 RFP to consider bids with later commercial
operation dates, bifurcating the evaluation of the bids, with prioritization of bids with a
commercial operation date by April 1, 2028, ('2028 Bids") followed by bids that could not
6 Oregon Administrative Rule ("OAR") 860-089-0010 et seq.
APPLICATION FOR A CPCN - 5

meet the April 1, 2028, commercial operation date ("Beyond April 2028 Bids"). Idaho
Power's discussion in this case is specific to the evaluation of the Beyond April 2028 Bids
for which the Company ultimately received approval of the final shortlist of bids with a
commercial operation date no later than June 1, 2029 ("2029 Bids") to meet the identified
capacity deficits. The OPUC found that Idaho Power conducted a fair and competitive
resource acquisition procurement process in accordance with the OPUC competitive
bidding rules. OPUC Order No. 25-327, Docket UM 2317, Aug. 30, 2025. The Company
used the results from that approved final shortlist, selecting the most cost-effective project
identified through the extensive competitive bidding process, the Bennett Gas Expansion
Project, to help meet the 2028 capacity deficiency, and for which Idaho Power is
requesting the Commission grant a CPCN in this proceeding.
IV. RESOURCE PROCUREMENT PROCESS
6. On February 29, 2024, Idaho Power commenced the competitive bidding
process, filing a request with the OPUC to (1) approve the selection of London Economics
International LLC ("LEI") as the Independent Evaluator ("IE") for the 2028 RFP, (2)
approve the proposed 2028 RFP scoring and modeling methodology, (3) approve the
draft 2028 RFP, and (4) waive certain competitive bidding rules to allow expedited review
and approval of the 2028 RFP. On April 30, 2024, in a public meeting, the OPUC
approved the Company's use of LEI as the IE again for Idaho Power's 2028 RFP and
evaluation of 2028 resources. The OPUC also approved the concurrent review of both
the scoring and modeling methodologies and the draft 2028 RFP.
7. The Company worked with OPUC Staff and stakeholders to finalize the draft
2028 RFP and on August 16, 2024, Idaho Power formally issued the 2028 RFP, soliciting
APPLICATION FOR A CPCN - 6

bids for (1) energy market purchases and (2) new or existing resources. The 2028 RFP
was well received; the Beyond April 2028 Bids included 83 proposals from 18 different
bidders, with a total of 117 resource bids summing to nearly 20 gigawatts of resources.
The bids included a variety of ownership structures, including many bids that would result
in bidder-owned resources (i.e., PPA's, and Battery Storage Agreements), as well as five
benchmark bids across three sites, submitted by Idaho Power's Power Supply
department.
8. The Direct Testimony of Mr. Hackett details the bid evaluation process
which was consistent and prescriptive as described in the 2028 RFP, ultimately
identifying the 2029 Bids final shortlist which are listed in Confidential Exhibit No. 2 to
Mr. Hackett's Direct Testimony. As required under the OPUC competitive bidding
rules, the OPUC approved Idaho Power's 2029 Bids final shortlist on August 19, 2025,
in a public meeting. Following identification as the most cost-effective project necessary
to meet the identified 2029 capacity deficiency, the Internal Bid Team was provided a
Notice to Proceed with the Bennett Gas Expansion Project.
V. RESOURCE DESCRIPTIONS
9. The bid evaluation process of the project proposals submitted through the
2028 RFP is designed to identify the combination and size of the proposed resources that
will maximize customer benefits while ensuring Idaho Power meets its energy and
capacity needs. Upon conclusion of the approximately 18-month mandated competitive
bidding rule-compliant process, the Company's Internal Bid Team was provided a Notice
to Proceed with the Bennett Gas Expansion Project. The Bennett Gas Expansion Project,
a benchmark resource, will include construction of a natural gas facility alongside Idaho
APPLICATION FOR A CPCN - 7

Power's existing Bennett Mountain Power Plant in Mountain Home, Idaho, and will consist
of nine, fast-ramping, natural gas fueled recips that are flexible enough to provide
between 10 and 167 MW of generation. Since identification on the 2029 Bids final
shortlist, the Company has executed agreements for an Owners Engineer, air permitting
consultants, design services, and for an equipment supply agreement for the recips. In
addition, Idaho Power anticipates executing an Engineering, Procurement, and
Construction contract as early as September 2025 as well.
VI. CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
10. Idaho Power has an obligation to provide adequate, efficient, just, and
reasonable service on a nondiscriminatory basis to all those that request it within its
certificated service territory. Idaho Code §§ 61-302, 61-315, 61-507. The Commission
must assure that the rates Idaho Power charges its customers and that the rules and
regulations by which it provides service are just, reasonable, nondiscriminatory, and non-
preferential. Idaho Code §§ 61-501 , 61-502, 61-503, 61-507, 61-508. The Company
must acquire the Bennett Gas Expansion Project, providing up to 167 MW of natural-gas
fueled generation, to meet the identified capacity deficits on its system in order to comply
with its continuing obligation to serve customers, and thus is requesting an order from the
Commission affirming that the public convenience and necessity requires the same. The
proposed acquisition represents a cost-effective means of providing adequate and
reliable service to the customers in Idaho Power's certificated service territory. The
Commission has the express authority to order a utility to build new structures, or to
upgrade and/or improve existing plant and structures, in order to secure adequate service
or facilities.
APPLICATION FOR A CPCN - 8

Whenever the commission, after a hearing had upon its own
motion or upon complaint, shall find that additions,
extensions, repairs or improvements to or changes in the
existing plant, scales, equipment, apparatus, facilities or other
physical property of any public utility . . . ought reasonably to
be made, or that a new structure or structures should be
erected, to promote the security or convenience of its
employees or the public, or in any other way to secure
adequate service or facilities, the commission shall make and
serve an order directing such additions, extensions, repairs,
improvements, or changes be made or such structure or
structures be erected in the manner and within the time
specified in said order.
Idaho Code § 61-508.
11. A CPCN or Certificate represents the exercise by the Commission of
foundational authority and principles that are necessary in Idaho's system of permitting
regulated, vertically integrated, public utilities to exist and to provide necessary services
to the public. Certificates have been utilized in various ways from the time that Idaho's
statutory system of public utility regulation was enacted by the Legislature in 1913, Idaho
Code § 61-101, et seq., to the present time. After nearly 100 years of legislative
enactments, Commission orders, and Idaho Supreme Court reviews, the Certificate
remains the embodiment of the Commission's fundamental power and authority to, at the
most basic level, authorize and direct a public utility to serve in the public interest. See
Idaho Power& Light Co. v. Blomquist et al., 26 Idaho 222, 141 P.1083 (1914); Idaho Op.
Atty. Gen. No. 87-2, 1987 WL 247587 (Idaho A.G.).
12. In the broadest sense, a Certificate allows a company that meets the
definition of a "public utility" pursuant to Idaho Code § 61-129 to exclusively provide its
service to the public in a specified geographic region, its service territory. It is a codified
part of the "regulatory compact" whereby the utility takes on the exclusive obligation/right
to serve all those requesting service within its service territory and, correspondingly,
submits itself to the rate and service quality regulation of the Commission. In a more literal
APPLICATION FOR A CPCN - 9

sense, a Certificate from the Commission is required for the construction or extension of
a line, plant, or system by any street, railroad, gas, electrical, telephone, or water
corporation. Idaho Code § 61-526. § 61-526 also provides that "if public convenience
and necessity does not require or will require such construction or extension [of a line,
plant, or system] the commission . . . may, after hearing, make such order and prescribe
such terms and conditions for the locating or type of line, plant or system affected as to it
may seem just and reasonable . . . ." A CPCN is required for the utility to construct a new
generation resource or plant but is not required to increase the capacity of existing
generating facilities. Id.
VII. AFUDC ACCRUAL FOR THE BENNETT GAS EXPANSION PROJECT
13. Idaho Power records the accumulation of all costs associated with the
construction of an asset, including the cost of financing the construction expenditures, or
AFUDC, in Federal Energy Regulatory Commission ("FERC")Account 107—Construction
Work in Progress ("CWIP"). When the plant is completed and placed in service, the total
cost of the plant, including AFUDC, is moved to FERC Account 101 — Electric Plant-in-
Service, placing the asset in rate base. For generation resources, typically, once selected
on the final shortlist having been identified as a least-cost, least risk resource, and
subsequently acknowledged by the OPUC, Idaho Power moves the charges to FERC
Account 107 - CWIP as the viability of the project has been confirmed, and AFUDC
commences.
14. Based on industry demand for long-lead materials, and to ensure
commercial operation dates are met, the Company has been incurring capital
expenditures associated with resource procurements prior to acknowledgement of the
final shortlist from the OPUC. In order to secure a position in the queue to purchase the
recips for the Bennett Gas Expansion Project, Idaho Power was required to make a down
APPLICATION FOR A CPCN - 10

payment in April 2025 following identification on the final shortlist, but prior to OPUC
acknowledgement of that final shortlist. This down payment was necessary to ensure the
plant would be operational in time to meet the identified capacity need.
15. A down payment for materials is evidence that capital expenditures are
being incurred and the procurement is necessary to begin construction of the project,
which aligns with FERC's guidance on the commencement of AFUDC accrual. However,
because Idaho Power has not previously been in a position to incur costs associated with
resource procurements prior to receiving for a CPCN, the Company is requesting the
Commission acknowledge it is appropriate to begin the accrual of AFUDC once the
project has been deemed viable and expenditures associated with the resource
procurement have been incurred. This treatment would recognize the required upfront
investments made by the Company in pursuit of cost-effective, necessary resources to
safely and reliably serve customers.
VIII. RATEMAKING TREATMENT FOR THE BENNETT GAS EXPANSION PROJECT
16. Idaho Power is not requesting binding ratemaking treatment for the Bennett
Gas Expansion Project in this case. The Company's request in this case is that the
Commission find Idaho Power has met the requirements of Idaho Code § 61-526 and
issue an order granting a CPCN for the Bennett Gas Expansion Project providing up to
167 NW of natural gas-fueled generation necessary to meet the identified capacity
deficiency in 2028. The Company will make a future filing to address the cost recovery
associated with this project.
IX. FINANCING THE BENNETT GAS EXPANSION PROJECT
17. Idaho Power maintains investment grade credit ratings with Standard &
Poor's Ratings Services and Moody's Investors Service, with a long-term issuer rating of
BBB and Baal , respectively. The Company maintains ready access to the capital markets
APPLICATION FOR A CPCN - 11

and to instruments providing for its liquidity. Idaho Power has a $400 million revolving
credit facility with its banking syndicate, which may be increased to $600 million under
specified conditions, which matures on December 7, 2029. The Company has an option
to request an additional one-year extension of the agreement, subject to certain
conditions. Idaho Power also has authority from state regulatory commissions to issue up
to $1.2 billion in aggregate principal amount of debt securities, $500 million of which
remained available as of August 31, 2025. The Company also has access to commercial
paper markets, as well as a balance of cash and investments on its balance sheet.
18. Additionally, Idaho Power has access to capital and credit outside of
existing mechanisms and instruments, such as through term loans, letter of credit, and
other instruments. IDACORP, the parent entity of Idaho Power, has approximately $104
million dollars of proceeds from common stock issuance that it intends to infuse as equity
to Idaho Power when needed. IDACORP sold an additional 6,434,350 shares of common
stock on various forward sale agreements between November of 2024 and May of 2025
which have not been settled as of August 31, 2025. The approximate cash value of the
forward sale agreements if settled for IDACORP shares is $702 million. The Company
intends to finance the Bennett Gas Expansion Project supplying approximately 167 MW
of natural gas-fueled generation with a combination of available cash and operating cash
flow, available credit facilities and borrowing and debt issuances, and future equity
infusions by IDACORP.
APPLICATION FOR A CPCN - 12

X. COMMUNICATIONS AND SERVICE OF PLEADINGS
19. Communications and service of pleadings with reference to this Application
should be sent to the following:
Donovan E. Walker Tim Tatum
Lead Counsel Vice President, Regulatory Affairs
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
dwalkerCcD,idahopower.com ttatumCcDidahopower.com
dockets idaho power.com
XI. MODIFIED PROCEDURE
20. The Company 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 present its testimony and support the Application in such
hearing.
XII. REQUEST FOR RELIEF
Idaho Power respectfully requests that the Commission issue an order (1) granting
a CPCN for the expansion of the existing Bennett Mountain Power Plant to include the
addition of the Bennett Gas Expansion Project, a cost-effective natural gas-fueled facility
providing up to 167 MW of generation to meet an identified capacity deficit in 2028, (2)
confirmation of the Company's application of accrual of AFUDC for the Bennett Gas
Expansion Project upon initial procurement activities for the recips, and (3) approving the
commencement of the accrual of AFUDC on capital expenditures associated with future
resource procurements at the time the project has been deemed viable by the Company.
APPLICATION FOR A CPCN - 13

DATED at Boise, Idaho this 19th day of September 2025.
DONOVAN E. WALKER
Attorney for Idaho Power Company
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