20251015Compliance Filing.pdf

HIQAHO R®
RECEIVED
LISA C. LANCE OCTOBER 15, 2025
Corporate Counsel IDAHO PUBLIC
Ilance(Widahopower.com UTILITIES COMMISSION
October 15, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-25-33
Idaho Power Company's Annual Compliance Filing to Update the Load and
Gas Forecast in the Incremental Cost Integrated Resource Plan Avoided Cost
Model
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Annual Compliance Filing in
the above-entitled matter. If you have any questions about the attached documents,
please do not hesitate to contact me.
Attachment No. 1 to the Annual Compliance Filing is confidential. Please handle the
confidential information in accordance with the Protective Agreement to be executed in
this matter.
Sincerely,
/0
C
Lisa C. Lance
LCL:cd
Attachments
1221 W. Idaho St(83702)
P.O.Box 70
Boise, ID 83707

LISA C. LANCE (ISB No. 6241)
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]
Ilance(a-Mdahopower.com
dwalkerCa-)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY'S ANNUAL )
COMPLIANCE FILING TO UPDATE THE ) CASE NO. IPC-E-25-33
LOAD AND GAS FORECASTS IN THE )
INCREMENTAL COST INTEGRATED ) IDAHO POWER COMPANY'S
RESOURCE PLANAVOIDED COST ) ANNUAL COMPLIANCE FILING
MODEL. )
Idaho Power Company ("Idaho Power" or "Company") hereby respectfully submits
to the Idaho Public Utilities Commission ("Commission") this filing in compliance with
Order Nos. 32697 and 32802 to update the load forecast, natural gas forecast, and long-
term contract changes used in the Incremental Cost Integrated Resource Plan ("ICIRP")
avoided cost methodology. In compliance with Order No. 34913, this filing updates the
Peak Hours and Premium Peak Hours used to calculate capacity payments for energy
storage qualifying facilities ("QF").
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 1

I. INTRODUCTION
In Order No. 32697, the Commission determined that the inputs to the ICIRP
avoided cost methodology, utilized for all proposed Public Utility Regulatory Policies Act
of 1978 ("PURPA") QF projects that exceed the published rate eligibility cap, will be
updated every two years upon acknowledgement of the utility's Integrated Resource Plan
("IRP") filing, with the exception of the load forecast and the natural gas forecast, which
should be updated annually. Discussing the timetable for updates to the ICIRP
Methodology, the Commission explained:
We find that, in order to maintain the most accurate and up-
to-date reflection of a utility's true avoided cost, utilities must
update fuel price forecasts and load forecasts annually —
between IRP filings . . . In addition, it is appropriate to consider
long-term contract commitments because of the potential
effect that such commitments have on a utility's load and
resource balance . . . We further find it appropriate to consider
PURPA contracts that have terminated or expired in each
utility's load and resource balance. We find it reasonable that
all other variables and assumptions utilized within the IRP
Methodology remain fixed between IRP filings (every two
years).
Order No. 32697, p. 22. Though the Commission originally set June 1 as the annual filing
date, it agreed on reconsideration that updates to gas and load forecasts used in the
ICIRP methodologies should occur on October 15 of each year. Order No. 32802, p. 3.
In considering implementation of PURPA with respect to energy storage QFs, the
Commission determined that the avoided cost of capacity should be paid only on
production during the hours identified as the Company's Peak Hours and Premium Peak
Hours. Order No. 34794, p. 14. The Commission also agreed that the updates to Peak
and Premium Peak Hours should be included in the annual October 15 update to the
other ICIRP method inputs. Order No. 34913, p. 6.
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 2

The load forecast, natural gas forecast, contract information, and Peak Hours and
Premium Peak Hours designations for battery storage capacity payments that are set
forth below are presented in compliance with the pertinent Commission Orders and will
be incorporated into Idaho Power's ICIRP avoided cost methodology. Consistent with the
Commission's directives, this methodology will be used by Idaho Power as the starting
point for the negotiation of its contractual avoided cost rates as of January 1, 2026.
II. LOAD FORECAST
Consistent with prior updates, Idaho Power is updating its load forecast to the most
recent available 50th percentile forecast. Idaho Power's most recent load forecast from
September 2025 shows an increase in customer loads over the 20-year period, as
compared with the September 2024 load forecast used in the Company's previous annual
update approved in December 2024.' The increase is due to the Company's re-estimation
of all major retail customer class usage and growth as well as updates related to electric
service agreements and special contracts to include the most recent assessment of load
and energy requirements by those customers. The updated load forecast and a
comparison to the September 2024 load forecast is included in Confidential Attachment
1. This information is being marked and treated as confidential because it is confidential
and proprietary Company information that has not yet been shared publicly.
III. NATURAL GAS PRICE FORECAST
The Company's proposal in this case relies on the most recent S&P Platts long-
term natural gas forecast, including Henry Hub and Sumas Basis Annuals (the "Platts
See In the Matter of Idaho Power Company's Filing to Update the Load and Gas Forecasts in the
Incremental Cost Integrated Resource Plan Avoided Cost Model, Case No. IPC-E-24-40, Order No. 36434
(Dec. 30, 2024).
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 3

long-term forecast"), which was published in August 2025, to update the natural gas price
forecast in ICIRP avoided cost calculations. This is a continuation of the methodology
employed by the Company for the IRP planning case natural gas price forecast in its 2023
IRP,2 which was acknowledged by the Commission in Order No. 36233, and the
methodology utilized by the Company for the IRP planning case natural gas price forecast
in its 2025 IRP3, which was filed at the end of June 2025 and remains pending.
The Company acknowledges that in last year's update, the Commission ultimately
directed Idaho Power to file a three-year natural gas forecast update as a compliance
filing, utilizing the latest NYMEX forward prices to determine avoided cost rates from
contracts signed after January 1, finding that was appropriate until the effective date of
the next natural gas price forecast annual update. Order No. 36233, p.6. In part, the
Commission's findings in that case were driven by a recognition that Company's filed
natural gas forecast was significantly different than the NYMEX forecast in the first few
years of the forecast. In this filing, the Company has reviewed the Platts long-term
forecast against NYMEX trading levels for current term markets (as of the timing of this
filing) and it believes the proposed natural gas forecast is the most accurate and up-to-
date reflection of the inputs to Idaho Power's current avoided costs.
Because the Platts long-term forecast is subscription-based and proprietary, this
information has been included in Confidential Attachment No. 1, which contains a table
and a graph setting forth information from the Platts long-term forecast published August
2025 compared with the Company's natural gas forecast approved in Order No. 36464 in
2 In the Matter of Idaho Power Company's 2023 Integrated Resource Plan, Case No. IPC-E-23-23
Application (filed Sept. 29, 2023).
3 In the Matter of Idaho Power Company's 2025 Integrated Resource Plan, Case No. IPC-E-25-23
Application (filed June 27, 2025).
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 4

last year's annual update, Case No. IPC-E-24-40. The most recent Platts long-term
forecast reflects an approximate average six percent decrease in natural gas prices
compared to the Company's last update.
IV. CONTRACT TERMINATIONS, EXPIRATIONS, AND ADDITIONS
Idaho Power currently has six non-PURPA, long-term power purchase agreements
with projects that are online: Elkhorn Valley Wind (101 megawatts ("MW")), Raft River
Geothermal (13 MW), Neal Hot Springs Geothermal (22 MW), Jackpot Solar (120 MW),
Black Mesa Energy Solar (40 MW), Franklin Solar (100 MW), and Pleasant Valley Solar
(200 MW), which came online in March 2025. The Company has one non-PURPA long-
term battery services agreement with a battery energy storage system ("BESS") that
came online in May 2025, the Kuna BESS (150 MW/600 MWh). Idaho Power also has
129 contracts with online PURPA QFs with a total nameplate capacity of 1 ,128.58 MW.
Table 1 below provides a list of new and terminated contracts since the last update
in October 2024. New ESAs and terminated or expired contracts, as well as new complete
ESA applications, are all included in the ICIRP model on a continuous basis. New and
Commission-approved non-PURPA power purchase agreements or resource
acquisitions are also included in the model on a continuous basis.
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 5

Table 1: Contract Updates
PURPA Replacement Agreements Entered Into Since Last Update'
Resource Tvce Project Name State ContractTvce Contract Date Project Size(MWI IPUC Case Number
CoGen Simplot Pocatello ID PURPA ESA replacement contract 11/4/2024 15.9(10 aMW energy or less) IPC-E-24-43
Hydro HaileyCSPP ID PURPA ESA replacement contract 1/29/2025 0.037 IPC-E-25-04
Hydro Hazelton A CSPP ID PURPA ESA replacement contract 9/3/2025 8.69(nameplate) IPC-E-25-30
7.70(max capacity)
Wind Fossil Gulch ID PURPA ESA replacement contract 9/26/2025 10_50 IPC-E-25-31
TOTAL NAMEPLATE 34
Note 1:This section lists new contracts with existing facilities(i.e.,PURPA replacement contracts)that have been entered into since last year's update.Nameplate capacity total
represents nameplate capacity of the projects,with the exception of Hazelton A,for which max capacity is used.
New Projects Not Yet On-Line'
Resource Tvce Project Name State Contract Type Contract Date Project Size(MW) IPUC Case Number
Solar Blacks Creek Energy Center-CEYW ID Non-PURPA CEYW PPA 10/11/2024 320 IPC-E-24-42
Wind Jackalope Wy Non-PURPA PPA and BTA 10/29/2024 600 IPC-E-24-46
Solar Crimson Orchard ID Non-PURPA PPA 2/7/2025 100 IPC-E-25-10
BESS Crimson Orchard ID Non-PURPA Battery Services Agreement 2/7/2025 1D0(POI I imited with the solar) IPC-E-25-10
Solar Blacks Creek Energy Center-80MW ID Non-PURPA PPA 8/8/2025 80 IPC-E-25-27
TOTAL NAMEPLATE 1100
Note 2:This section lists new PURPA contracts with projects that are not yet online that have been entered into since last year's update,as well as new non-PURPA contracts that
have been executed and Commission-approved since last year's update_Nameplate capacity total represents nameplate capacity of the projects,with the exception of Crimson
Orchard,for which the point of interconnection limit of 100 MW is used.
Termn-Md/Expired Agreements'
Contract Termination
Resource Tvce Project Name State Contract Type Date Proiect Size IMW) IPUC Case Number
Wind Jackalope Wy Non-PURPA PPA and BTA 9/4/2025 600 IPC-E-24-46 and
IPC-E-25-28
Wind Fossil Gulch ID PURPA ESA-expiration of prior agreement 9/30/2025 10.5 IPC-E-04-19
CoGen Simplot Pocatello ID PURPA ESA-expiration of prior agreement 3/1/2025 15.9(10 aMW energy or less) IPC-E-21-33
Hydro HaileyCSPP ID PURPA ESA-expiration of prior agreement 6/25/2025 0.037 IPC-E-20-16
Solar Durkee Solar OR Termination due to failure to meet COD 2/6/2025 3 OPUC docket 141
TOTAL NAMEPLATE 629
Note 3:This section lists PURPA and non-PURPA contracts that have expired or terminated since last year's update.
V. PEAK AND PREMIUM PEAK HOURS
In this year's update, Idaho Power has refreshed its analysis of Peak and Premium
Peak Hours for use in pricing energy storage projects using the Loss of Load Probability
("LOLP") methodology as the primary basis for identifying these hours. The LOLP
methodology offers a more objective and capacity-based framework as compared to the
existing methodology; it is also consistent with how Idaho Power identifies other PURPA-
related metrics such as the capacity deficiency date. The existing methodology relies on
synthesizing multiple data sources—including forecasted load, actual load net of solar,
Western Energy Imbalance Market ("WEIM") prices, and LOLP results.
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 6

As the Company has gained experience relying on the existing methodology, Idaho
Power has found the method, initially directed by Order No. 34913, depends on manual
comparison of different data sources — and involves subjective judgment in selecting
hours. Moving to full reliance on the more objective and capacity-based LOLP
methodology results in a more transparent and data-driven framework. Also of note, the
Company has applied the LOLP methodology in other proceedings to identify the timing
of capacity-based risk for pricing, performance, and program design.
The LOLP methodology, which has been implemented in Idaho Power's past three
IRP filings via the internally developed Reliability & Capacity Assessment Tool ("RCAT"),
calculates the probability of demand exceeding available generation for every hour over
the planning period. The 2025 IRP LOLP-based timing of highest risk analysis indicates
that the hours with the highest LOLP values are concentrated in the summer months,
particularly in the late afternoon and evening. These hours represent the greatest risk of
capacity shortfall and are therefore the most appropriate for identifying Peak and
Premium Peak Hours for battery storage capacity payments. This finding regarding the
timing of the most critical needs is consistent with the determinations in past updates.
In preparation of its filing, the Company developed Peak and Premium Peak Hours
using both methods to allow for ease of Commission review as it considers the merits of
modifying the underlying methodology applied. That is, the Company developed Peak
and Premium Peak Hours under the existing methodology as established by Order No.
34913, which is based on forecasted load, current year load net of solar generation, and
current year WEIM prices. The Company separately completed an analysis relying fully
on the LOLP capacity-based framework.
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 7

The two methods identify similar highest risk hours in the summer. Of note, the
more objective LOLP-based method also identifies hours of higher risk in the winter. While
the number of months considered has increased under the LOLP methodology basis to
now include winter, summer remains the highest risk season and payments will be
weighted based on the monthly LOLE percentages provided in Table 6 of the 2025 IRP
Appendix D. The modeling results from both methodologies are included in Confidential
Attachment 1, which contains proprietary and non-public load forecast information.
The table below shows the results of the two methods:
Table 2: Comparison of Methodologies
ppr Existing Methodology 9pr Proposed Update
Summer Peak Hours July: 1:OOpm through 10:OOpm June 15 to September 15: 3:OOpm to
August: 3:OOpm to 8:OOpm 11:00pm
Summer Premium Peak July: 6:OOpm through 10:OOpm June 15 to September 15: 6:OOpm to
Hours August: 6:OOpm to 8:OOpm 11:00pm
Winter Peak Hours No winter hours identified November 15 to February 15: 5:OOam
to 10:00am and 4:OOpm to 10:00pm
Winter Premium Peak No winter hours identified November 15 to February 15: 6:OOam
Hours to 9:OOam and 5:OOpm to 8:00 pm
In advance of this filing, Idaho Power met with Commission Staff to discuss the
potential update as part of this year's compliance filing. As the Company discussed with
Staff, the proposed methodology results in a more objective, data-driven determination of
Peak and Premium Peak Hours, and is consistent with Idaho Power's approach in other
proceedings. The Company's widespread implementation of the LOLP methodology that
has been acknowledged by the Commission in various dockets reinforces the validity of
the identified hours and supports the use now and in the future of LOLP as a robust,
capacity-based method for determining risk timing. Accordingly, the Company believes
the methodology is reasonably modified as part of this compliance filing.
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 8

VI. CONCLUSION
Idaho Power hereby respectfully submits this updated load forecast, natural gas
forecast, contract information, and Peak and Premium Peak Hours in compliance with the
Commission's directives in Order Nos. 32697, 32802, and 34913 and requests that the
Commission accept and approve the same.
Respectfully submitted this 15th day of October 2025.
,�a G
LISA C. LANCE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S ANNUAL COMPLIANCE FILING - 9

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-33
IDAHO POWER COMPANY
CONFIDENTIAL ATTACHMENT NO. 1
Load Forecast, Natural Gas Price Forecast, and Updated
Analysis Regarding Peak and Premium Peak Hours

ATTACHMENT 1
IS CONFIDENTIAL AND WILL BE PROVIDED TO THOSE PARTIES THAT EXECUTE
THE PROTECTIVE AGREEMENT IN THIS MATTER