20251027Comments on Petitions for Reconsideration.pdf

RECEIVED
October 27, 2025
Kelsey Jae (ISB No. 7899) IDAHO PUBLIC
521 E. 41st St. UTILITIES COMMISSION
Garden City, ID 83714
Phone: [phone]
[e-mail]
Attorney for the Clean Energy Opportunities of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO )
POWER COMPANY'S )
APPLICATION FOR ITS FIRST ) CASE NO. IPC-E-25-15
ANNUAL UPDATE TO THE )
EXPORT CREDIT RATE FOR ) CLEAN ENERGY OPPORTUNITIES
NON-LEGACY ON-SITE ) FOR IDAHO
GENERATION CUSTOMERS FROM )
JUNE 1, 2025 THROUGH MAY 31, ) COMMENTS RE: PETITIONS FOR
2026, IN COMPLIANCE WITH ) RECONSIDERATION
ORDER NO. 36048 )
COMES NOW Clean Energy Opportunities for Idaho ("CEO"), by and through its
attorney of record, Kelsey Jae of the firm Kelsey Jae LLC, hereby submits the following
comments on the Petitions for Reconsideration filed by Intervenors Sierra Club/Vote Solar and
City of Boise.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - COMMENTS - IPC-E-25-15 - 1

Clean Energy Opportunities for Idaho
October 27, 2025
Reference: Case No. IPC-E-25-15, the ECR Update
Subject: Comments of Clean Energy Opportunities in response to petitions for reconsideration
Thank you to the Commission for an order that seeks to navigate a fair and reasonable path forward,
and thank you to the petitioners for reconsideration. Briefly, we add the following comments:
CEO supports the Commission's decision to suspend the next routine ECR update until 2028.
Regarding the Sierra Club/Vote Solar petition, CEO supports the constructive proposal to use this time
prior to the 2028 ECR update to consider outstanding issues. Prior to IPC-E-25-15, there was a choice
to establish a complex methodology for determining the ECR. That raised the bar for the time and
resources invested by stakeholders to weigh in on issues with the methodology that have surfaced. It
seems fair and practical to provide a venue in which those issues and alternatives can be given full
consideration. The messier the matter, the more value there is in interactive dialogue.
CEO is also supportive of the City's petition. The City represents a broad range stakeholder interests,
which adds weight to their recommendation of a 20% limit to future ECR decreases. We agree that
alternatives to ensure stability and a reasonable degree of predictability should be addressed. We do
not take a position at this time on how to achieve that, though we agree a 3-4 year cadence for updates
should be one of the options considered. We agree there are problems with the methodology for
calculating the ECR energy value that merit review and the consideration of alternatives.
Stepping back from this docket: As financially grounded advocates for the long-term interests of
Idahoans, let's consider the balance of fairness at a higher level. If it remains unchanged, the
Company's current methodology for allocating costs in a general rate case does not protect residential,
small general service, or irrigator customers from both the direct and indirect cost growth caused by
large load customers.' In terms of other drivers of rate increases, the Company now attributes climate
change as a cause for increasing its requested Return on Equity2 (which increases rates for all) and for
wildfire risks' (with wildfire mitigations costs noted as a contributor to rate increases).
Under a monopoly, on-site generation is one of the few options for ratepayers to gain agency over their
power costs and - as many commenters describe - to be "part of the solution" to mitigate climate
change, which is now driving up costs for all. To be clear, CEO is not proposing an expansion in scope
beyond the quantifiable concerns addressed in the petitions. The point is: The Commission has leeway
to set a higher ECR, appease the requests of the petitioners, or otherwise give on-site generators the
benefit of the doubt without disrupting the balance of fairness.
/4�u,-
Courtney White
Managing Director, Clean Energy Opportunities for Idaho
' From 2024—2031, Idaho Power's 2025 IRP plans for firm loads/special contracts to grow from 8% to 36% of
total company kWh sales (Appendix A.)The Company's current methodology allocates disproportionately more
capacity costs to residential, small general service, and irrigators. The direct and indirect costs cause by
unprecedented growth in large load additions drive a potential for rate increases and exposure to cost shifting that
overshadow assertions of cost-shifting related to on-site generation by several orders of magnitude.
2 IPC-E-25-16, Thompson Direct 33:10-14. Per the Company's expert witness, Moody's listed "Heightened
wildfire risk"as one of the Company's credit challenges, a fact the Company used to request a higher ROE.
3 IPC-E-25-16, Thompson Direct on behalf of Idaho Power, 33:3-4: "Climate change has increased wildfire risk for
utilities in the Northwestern states, such as Idaho Power."

CERTIFICATE OF SERVICE
I hereby certify that on this 27th day of October, I delivered true and correct copies of the
foregoing COMMENTS to the following persons via the method of service noted:
Electronic Mail Delivery(See Order No. 34602)
Idaho Public Utilities Commission
Monica Barrios-Sanchez
Commission Secretary
secretary@ nuc.idaho.gov
Idaho PUC Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
chris.burdin0puc.idaho.gov
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
Connie Aschenbrenner
Mary Alice Taylor
Regulatory Dockets
mgoicoe cheaallenOidahopower.com
dwalkerQ idahopower.com
[e-mail]
[e-mail]
dockets(a)idahopower.com
City of Boise
Jessica Harrison
Katie O'Neil
BoiseCityAttorne,y(a)cityofboise.org
iarrisonOcityofboise.org
koneilQcityofboise.org
Kevin Dickey
bellefourche0l(a)gmail.com
Martha Bibb
marthsbigg(a)gmail.com
Scott Pinizzotto
s.pinizzoto(a)gmail.com
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - COMMENTS - IPC-E-25-15 - 3

Sierra Club & Vote Solar
Rose Monahan
Kate Bowman
Greg Adams
ro se.monahanO sierraclub.org
kbowman@vote solar.org
p,rep,Orichardsonadams.com
'U
Kelsey Jae,Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - COMMENTS - IPC-E-25-15 -4