20251016Staff Comments.pdf

RECEIVED
October 16, 2025
ADAM TRIPLETT IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION TO UPDATE ) CASE NO. IPC-E-25-24
CLEAN ENERGY YOUR WAY )
CONSTRUCTION AGREEMENT PRICING )
ELEMENTS BASED ON THE 2025 IRP ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Adam Triplett, Deputy Attorney General,
submits the following comments.
BACKGROUND
On July 25, 2025, Idaho Power Company("Company"), applied for authority to update
pricing elements for all contracts under its Clean Energy Your Way ("CEYW") Construction
Program that are based on data from the Company's 2025 Integrated Resource Plan("IRP").
The Company represents that its CEYW-Construction Program under Schedule 62 offers
a customized renewable energy option for its largest customers (those on special contracts or
Schedule 19 -Large Power Service). It allows the customers to meet up to 110% of their yearly
energy needs with renewable resources.
STAFF COMMENTS 1 OCTOBER 16, 2025

The Company has three customers participating in the Commission-approved CEYW-
Construction Program: Brisbie, LLC (`Brisbie"), Micron Technology, Inc. ("Micron"), and the
City of Boise.
The Company has continued improving the framework for implementing and managing
the CEYW-Construction Program.
In Order No. 36383, the Commission directed the Company to update pricing for all
CEYW-Construction agreements and Schedule 62 in a single filing within 30 days of submitting
its IRP, to ensure rates reflect the most current and accurate data.
On June 27, 2025, in Case No. IPC-E-25-23, the Company filed its 2025 IRP and is now
submitting this application to update the pricing elements in its CEYW agreements, as required
by Order No. 36383.
The Company requests Commission approval of updates to the following 2025 IRP-based
prices for the Brisbie and Micron Special Contracts, and the City of Boise's CEYW Agreement:
(1)the "Supplemental Energy Price" for Brisbie's Block 2 load service, and (2) the"Mid-
Columbia("Mid-C") Forecast"used to calculate the "Excess Generation Price" for Brisbie,
Micron, and the City of Boise.
STAFF ANALYSIS
Staff reviewed whether both pricing elements of the Supplemental Energy Price and
Excess Generation Price complied with the Commission's Orders and are updated with the 2025
IRP. Staff verified that(1) the Company used a P50 load forecast for determining that both
pricing elements are consistent with Order No. 36383, (2)the calculation methodology for the
Excess Generation Price is aligned with Order No. 35777, and(3) the updated pricing elements
are based on the 2025 IRP data. Finally, Staff recommends that the Commission approve the
updated pricing elements within the CEYW special contracts and agreements, as filed.
Supplemental Energy Price
Staff verified that the Company has updated the avoided cost averages based on a P50
load forecast(50%probability that the forecast will be exceeded) for determining the
Supplemental Energy Price and confirmed that the calculation for the avoided cost averages is
correct.
STAFF COMMENTS 2 OCTOBER 16, 2025

The Supplemental Energy Price is the marginal price average applicable to Brisbie's
Block 2 load service and is based on the avoided cost averages published in the Company's most
recent Commission-acknowledged IRP. In Order No. 36383, the Commission ordered the
Company to use a P50 load forecast to calculate the Supplemental Energy Price and Excess
Generation Price. Using a P50 load forecast complies with cost-of-service ratemaking and the
Commission-approved method for calculating IRP-based avoided cost rates and marginal cost
rates. In Attachment Nos. I and 2 of the Application, the Company used a P50 load forecast
from the recently referenced 2025 IRP for both pricing elements. In addition, Staff verified that
the calculation for the avoided cost averages is correct by averaging the hourly avoided costs, as
shown in the workpaper provided in the Company's response to Staff Production Request No. 1.
Excess Generation Price
Staff confirmed that the hourly Mid-C Forecast, which is used for the Excess Generation
Price, is correctly updated from the 2025 IRP, and its calculation methodology is consistent with
Order No. 35777.
The Excess Generation Price is determined by taking the hourly Mid-C Price Forecast
from the IRP, assumed to be a firm-energy market price, and then adjusting it by 82.4%to
determine a non-firm energy market price. Additionally, the Commission ordered the Company
to apply the 85% adjustment to the hourly Mid-C Forecast to incur a reasonable balance between
compensating energy projects and protecting customers. Order No. 35777 at 17-18.
Consequently, the Excess Generation Price is defined as the lower of(1) 85% of the hourly Mid-
C Forecast, with the non-firm adjustment of 82.4%, or(2) the actual high- or low-load hour Mid-
C market price for each hour. As shown in the Company's response to Staff Production Request
No. 2, the Company provided an example to calculate the Excess Generation Price, applying
both adjustments to the hourly Mid-C Forecast and selecting the lower of the adjusted Mid-C
Forecast or the actual high-or low-load Mid-C price. Staff confirmed that the example is
calculated correctly and complies with Order No. 35777.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the updated pricing elements within the
CEYW special contracts and agreements, as filed.
STAFF COMMENTS 3 OCTOBER 16, 2025

Respectfully submitted this 16th day of October 2025.
Adam Triplett
Deputy Attorney General
Technical Staff. Seungjae Lee
I:\Utility\UMISC\COMMENTS\IPC-E-25-24 Comments.docx
STAFF COMMENTS 4 OCTOBER 16, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16" DAY OF OCTOBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-25-24, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
Idaho Power Company: Idaho Power Company:
DONOVAN E. WALKER TIMOTHY TATUM
MEGAN GOICOECHEA ALL_ EN GRANT T. ANDERSON
IPC DOCKETS IDAHO POWER COMPANY
IDAHO POWER COMPANY 1221 WEST IDAHO STREET (83702)
1221 WEST IDAHO STREET (83702) PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-MAIL:
E-MAIL: tttuxn(c?idhoowcr.co
dwalker(u;idatlopc}��er.con7 jai dcrsc�n(i Idaho�ower.coti�.
Dooicc,echeaallezi(a?idalio ower.uoin
doc.ket5(a;idahopow�cr.com
f
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE