20251002Reply Comments.pdf

@MDAHO POWER.
MEGAN GOICOECHEA ALLEN RECEIVED
Corporate Council October 02, 2025
mgoicoecheaallen(didahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
October 2, 2025
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
RE: Case No. IPC-E-25-12
In the Matter of Idaho Power Company's Application for a Determination
of 2024 Demand-Side Management Expenses as Prudently Incurred
Dear Ms. Barrios-Sanchez:
Attached for electronic filing is Idaho Power Company's Reply 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,
4I' v�,�oic�e UR QQ�iri,
Megan Goicoechea Allen
MGA:sg
Attachment

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: (208) 388- 6936
mgoicoecheaal len6a�idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-25-12
DETERMINATION OF 2024 DEMAND- )
SIDE MANAGEMENT EXPENSES AS ) IDAHO POWER COMPANY'S
PRUDENTLY INCURRED. ) REPLY COMMENTS
Idaho Power Company ("Idaho Power" or "Company") respectfully submits the following
Reply Comments in response to Comments filed by Idaho Public Utilities Commission
("Commission") Staff("Staff") on September 18, 2025.
I. REPLY COMMENTS
In its Comments, Staff concludes that the Company's Demand-Side Management("DSM")
programs are well managed and cost-effective' and recommends the Commission approve
$34,873,2912 in DSM-related expenditures as prudently incurred.3 Staff also provides an analysis
of the Rider balance, discusses program performance, and recommends that the Commission
find that the Company complied with Order No. 36331.4
' Staff Comments at 2.
2 Staff's recommendation is consistent with the Company's filed request (see Application, pages 1 and
18).
3 Staff Comments at 12.
41d.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

A. 2024 Expenditures
In its Application, Idaho Power requested the Commission approve $25,922,708 in Idaho
Rider expenses as prudently incurred. As the Company was preparing its response to an audit
request issued in this case, it identified it had incorrectly duplicated two transactions during 2024,
which resulted in the 2024 DSM prudence request being overstated by$527. Upon identifying the
error, Idaho Power made a correcting journal entry in August 2025. Accordingly, the Company
respectfully requests the Commission issue an order finding $34,872,764 in 2024 DSM
expenditures prudently incurred, which includes $25,922,181 in Idaho Rider expenses and
$8,950,583 in Demand Response ("DR") program incentives.
B. Rider Balance
In its Comments, Staff stated that as of December 31, 2024, the Rider had a positive, or
over collected, balance of $7,570,508. Staff highlighted a recent reduction to the Rider that
occurred as part of the Company's 2023 general rate case and noted that the current overfunded
balance suggests that the Rider rate may be too high.5 The Rider is a balancing account and the
Company endeavors to match collection with expenditures over time. To that end, the Company
monitors the Rider balance monthly, which includes maintaining a forecast of expected
expenditures. Based on current expected expenditures, the year-end 2025 Rider balance is
anticipated to generally remain in line with year-end 2024. However, the Company notes that
several large commercial and industrial custom projects are anticipated to be completed before
year-end, and the timing of these completions will significantly influence the Rider's overall
balance. Therefore, delays in these projects could result in the Rider's overall balance being
higher than currently forecasted until such projects are completed. The Company will continue to
monitor the Rider balance and if it is determined an adjustment is warranted, will seek to time that
adjustment coincident with other rate changes as to minimize volatility for customers.
5 Id., at 5.
IDAHO POWER COMPANY'S REPLY COMMENTS -2

II. CONCLUSION
Idaho Power appreciates the collaboration with Staff to continually improve its energy
efficiency offerings. The Company respectfully requests that the Commission issue an order: (1)
finding $25,922,181 in Rider funds and $8,950,583 in DR program incentives, for a total of
$34,872,764, as prudently incurred DSM expenses; and (2) finding that the Company complied
with Order No. 36331.
Respectfully submitted this 2nd day of October 2025.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 2nd day of October 2025, 1 served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S REPLY
COMMENTS upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff Hand Delivered
Erika K. Melanson U.S. Mail
Idaho Public Utilities Commission Overnight Mail
11331 W. Chinden Blvd., Bldg No. 8 FAX
Suite 201-A (83714) FTP Site
PO Box 83720 X Email — Erika.Melanson(a-)puc.idaho.gov
Boise, ID 83720-0074
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS -4