20251016Reply Comments.pdf

-�IQAFIO R®
DONOVAN E. WALKER RECEIVED
Lead Counsel OCTOBER 16, 2025
dwalker(cD_idahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
October 16, 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. 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 Reply Comments to be filed in the
above-entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Very truly yours,
Donovan E. Walker
DEW:cd
Attachments

DONOVAN E. WALKER (ISB No. 5921)
LISA C. LANCE (ISB No. 6241)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker(@idahopower.com
IlanceCo)_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 ) IDAHO POWER COMPANY'S
AVOIDED COST CALCULATIONS. ) REPLY COMMENTS
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and,
pursuant to Idaho Public Utilities Commission's ("Commission") Rules of Procedure 201-
204, hereby respectfully submits the following Reply Comments in response to
Comments filed by Commission Staff ("Staff") on October 2, 2025.
I. BACKGROUND
On July 25, 2025, Idaho Power Company filed an Application with the Commission
requesting approval of a capacity deficiency date of June 2027, to be utilized in avoided
cost determinations under the Surrogate Avoided Resource ("SAR") and Integrated Cost
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

IRP ("ICIRP") methodologies. This filing was made in accordance with Commission Order
Nos. 32697, 33084, 33159, 35810, and 36070, which collectively establish the framework
for determining capacity deficiency periods outside of the Integrated Resource Plan
("IRP") docket.
The Company's 2025 IRP identifies a first capacity shortfall in June 2027, based
on a resource stack that includes executed agreements for new resources. The
Application reflects Idaho Power's commitment to transparency and alignment with
Commission guidance, including the exclusion of resources that do not yet have a high
level of certainty, as well as WRAP capacity benefits.
On October 2, 2025, Commission Staff submitted comments recommending that
the Company file a compliance update to revise its capacity deficiency analysis. Staff's
recommendations focus on the inclusion criteria for future resources and the operational
exit dates for Jim Bridger Units 3 and 4. Staff asserts that only approved PURPA
contracts, Certificate of Public Convenience and Necessity ("CPCN") approved
resources, and executed non-PURPA contracts not requiring pre-approval should be
included in the analysis. Staff further recommends using the original technical useful lives
for Jim Bridger Units 3 and 4 until greater certainty is available.
Idaho Power appreciates Staff's review and offers the following responses to
address the recommendations.
II. STAFFS RECOMENDATIONS
A. Contracts and Capacity Project Approvals
In their comments, Commission Staff acknowledges that the capacity deficiency
date identified through the IRP process is presumed to be correct. Staff references Order
No. 32697, outlining that, "The capacity deficiency determined through the IRP planning
IDAHO POWER COMPANY'S REPLY COMMENTS - 2

process will be the starting point, and will be presumed to be correct subject to the
outcome of the proceeding." Staff Comments, p. 2. Despite this presumption, Staff
recommends that Idaho Power file updated capacity positions through a compliance filing
that includes resources to reflect modified criteria related to which contracts and
resources should be included when determining a capacity deficiency period.
Specifically, Staff recommends that Idaho Power file updated capacity positions
through a compliance filing utilizing the resource assumptions outlined below:
1. For non-PURPA contracts that do not require pre-approval, include all
executed contracts;
2. For resources that require a Certificate of Public Convenience and
Necessity ("CPCN")-only include projects that have received a CPCN,
3. For PURPA projects, only include projects with Commission-approved
PURPA contracts.
Staff further explains that "executed" means all parties involved have signed the contract
and "approved" means the contract has been approved by the Commission. Staff's
recommendation is grounded in its interpretation of Order No. 35834, issued in
PacifiCorp's capacity deficiency case in 2022. This order directs that:
[t]he Company shall update the L&R to only include approved
contracts where pre-approval is necessary, or executed
contracts where pre-approval is unnecessary, but the contract
is signed by the parties. Since the deficit date is used to set
rates for QFs, which impacts customer rates, until contracts
are approved or have a high level of certainty, costs are not
known and measurable and should not be included in the
Company's L&R (Order No. 35834, p. 9).
However, Staff's comments do not reference the portion of the order language that
allows for inclusion of certain resources that are not yet approved. In its order, the
Commission indicated that until contracts are approved or"have a high level of certainty,"
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

they should not be included to determine a capacity deficiency date. The Company's filing
is consistent with the standard established by the full ordering language as it only included
resources with executed agreements that — with a high level of certainty— are expected
to come online and contribute capacity to the system.
B. Risk of Excluding Resources with High Certainty
Under Staff's proposal, the Boise Bench Expansion and Hemingway Expansion
battery storage facilities (currently under review in Case No. IPC-E-24-45) would not be
included in the analysis of resources for the determination of the capacity deficiency
period because a CPCN has not yet been issued by the Commission. These resources
were selected through competitive procurement processes, are under contract and are
expected to contribute capacity beginning in the summer of 2026. As such they are
appropriately included in all 2025 IRP portfolio scenarios and sensitivities and in the
analysis to determine a capacity deficiency date.
Because the Company's proposed deficiency date is June 2027, Staff's
recommendation to exclude 2026 projects (the Boise Bench Expansion and Hemingway
Expansion battery projects) would affect the capacity deficiency date being established
in this case. Removing these projects would shift the first capacity deficiency date from
June 2027 to June 2026, which has the potential of causing customers to incur higher
costs associated with capacity for the summer of 2026 than they otherwise would with the
inclusion of the projects, as the Company has proposed.
The Company believes that non-PURPA resources with executed agreements and
a clear path to development should be considered sufficiently certain for inclusion in the
capacity deficiency analysis. Excluding such resources could result in avoided cost rates
that do not reflect actual system needs, leading to the double payment of capacity by
IDAHO POWER COMPANY'S REPLY COMMENTS - 4

customers without a corresponding reliability benefit. To illustrate, consider if the
Company were to file a CPCN for a new 400 MW plant expected to be online in a given
year— that resource could provide sufficient capacity for multiple years. However, under
Staff's proposal, if the Commission had not yet issued a CPCN in that case, the Company
would seek to establish a capacity deficiency date that could result in multiple years of
duplicative avoided cost payments for capacity that is not actually needed or providing
customer benefit.
Idaho Power's approach ensures that customers pay for capacity only when it is
truly needed, maintaining fairness and cost-effectiveness in PURPA implementation. The
Company also believes the Commission need not adopt a strict application of criteria as
Staff suggests — the Company is required to submit a filing, like this one, following the
issuance of each IRP for the Commission to determine a capacity deficiency date. The
Commission ultimately has the authority to determine what resources are reasonably
included in that determination and in this case, Idaho Power requests the Commission
approve its requested capacity deficiency date of June 2027.
C. Jim Bridger Units 3 and 4 Exit Dates
Staff recommends that Idaho Power use the original technical useful lives of Jim
Bridger Units 3 and 4 in its capacity deficiency analysis, rather than the 2030 exit dates
used in the Application. Staff explains that "[t]he Company assumes that Jim Bridger 3
and 4 will exit in 2030... However, Staff believes that due to the remaining amount of
uncertainty that still exists regarding the timeframe for continued use of these two units,
Staff recommends that the operational exit dates... reflect the original technical useful
lives." Staff Comments, p. 3.
IDAHO POWER COMPANY'S REPLY COMMENTS - 5

Idaho Power recognizes that uncertainty remains regarding the operational future
of Jim Bridger Units 3 and 4. The Company used the 2030 dates to align with the
Commission-approved depreciation schedules but acknowledges that these dates may
not reflect the actual retirement timeline. Idaho Power is open to revisiting the exit dates
in future IRPs as more information becomes available and will continue to monitor
developments that may affect the operational status of these units. However, the
Company notes that changing the retirement dates from 2030 to a date further in the
future will not have an impact on the capacity deficiency year established in this case and
therefore, is not necessary to change at this time.
D. Compliance Filing
Staff recommends that Idaho Power submit a compliance filing to update its
capacity deficiency analysis based on revised resource inclusion criteria and updated
Bridger exit dates. As noted previously, the only change that would affect the June 2027
capacity deficiency date is the exclusion of the two 2026 battery projects pending CPCN
approval (excluding those resources would result in a June 2026 capacity deficiency
date). All other recommended adjustments, such as the treatment of Jim Bridger Units 3
and 4 exit dates, impact years beyond June 2027 and do not materially affect avoided
cost calculations for new qualifying facilities. Accordingly, it is not necessary for the
Commission to direct Idaho Power to submit a compliance filing, as it can issue an order
establishing the capacity deficiency date based on information already on the record.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6

III. CONCLUSION
Idaho Power appreciates Staff's review and the opportunity to respond. The
Company respectfully requests that the Commission:
1. Approve the first capacity deficiency date of June 2027 for use in
avoided cost determinations under the SAR and ICIRP methodologies;
and,
2. Decline to require a compliance filing in this case.
Respectfully submitted this 16t" day of October 2025.
DONOVAN WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 7

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 16th 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:
Erika K. Melanson Hand Delivered
Deputy Attorneys General U.S. Mail
Idaho Public Utilities Commission Overnight Mail
P.O. Box 83720 FAX
Boise, ID 83720-0074 X Email - erika.melanson(c)_puc.idaho.gov
IdaHydro Hand Delivered
C. Tom Arkoosh U.S. Mail
Nicholas J. Erekson Overnight Mail
Arkoosh Law Offices FAX
913 W. River St., Ste. 450 X Email — tom.arkoosh(o),arkoosh.com
P.O. Box 2900 nick.erekson(c�arkoosh.com
Boise, ID 83701 erin.cecil(a-).arkoosh.com
at4tw
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 8