20251113Comments.pdf

Irion Sanger, ISB No. 12488
Sanger Greene PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Tel: [phone]
Fax: [phone]
[e-mail]
Counsel for Renewable Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) Case No. IPC-E-25-23
COMPANY'S 2025 INTEGRATED )
RESOURCE PLAN ) RENEWABLE ENERGY
COALITION'S COMMENTS
I. INTRODUCTION
In accordance with the Idaho Public Utilities Commission's ("Commission")
October 6, 2025 Notice of Modified Procedure, the Renewable Energy Coalition
("Coalition" or"REC")provides the following comments on Idaho Power's 2025
Integrated Resource Plan ("IRP").
Idaho Power's plan to acquire over 4,000 megawatts ("MW") of new resources,
including 1,445 MW of solar and 700 MW of wind, while simultaneously shedding
cheaper, existing wind and solar qualifying facility ("QF") resources under the Public
Utilities Regulatory Policies Act("PURPA") should be concerning. Existing projects
provide significant value to Idaho Power and its customers, especially during the time of
generation build out to meet growing load. Idaho Power and the Commission should
encourage rather than discourage continued generation by existing QFs that are generally
less risky and lower cost than new generation. Existing QFs are generally keen to renew
RENEWABLE ENERGY COALITION COMMENTS Page 1

their contract upon expiration; however, Idaho Power's planning assumptions and the
Commission's harmful policies towards existing wind and solar QFs, limit the economic
incentive for existing QFs to provide lower cost resources for Idaho's customers upon
contract expiration.
Regardless of whether the Commission maintains its current policies, Idaho
Power's use of essentially a 28%renewal/replacement rate over 20 years for QFs with
resource types for which replacement rate data was not available, namely wind and solar
QFs, is not reasonable or accurate. Idaho Power effectively assumes that only 13% of
Idaho Power's current nameplate capacity from operating wind QFs will be available to
Idaho Power at the end of the planning period. This means that Idaho Power is planning
on a drop from 562 MWs to 75 MWs, a loss of a massive 487 MWs of existing and
operating installed wind capacity over the planning period. The Commission should
conclude Idaho Power's current QF wind and solar renewal methodology is imprudent,
and direct Idaho Power to adjust its QF wind and solar renewal methodology in future
IRPs.
Il. COMMENTS
A. Idaho Power Is Inaccurately Modeling Renewal of Existing Wind and Solar
QFs
Idaho Power's 2025 IRP assumes that existing wind and solar QFs will not renew
due to the existing wind and solar QF contracting policies. As existing QF contracts
expire—many of which expire just a few years from now in the early 2030s—Idaho
Power assumes a 75%renewal rate for wind and solar QFs because the utility does not
RENEWABLE ENERGY COALITION COMMENTS Page 2

have historical data.' The key, however, is that Idaho Power applies the 75%proxy rate
every two years due to Idaho's two-year wind and solar QF maximum contract length.
For example, if eight QF contracts were to expire in 2030, Idaho Power would assume
that only six of them would renew their contract.2 Because the Commission instituted a
two-year contract policy for IRP-based contracts, all six renewal contracts would expire
in 2032. Idaho Power then assumes that only 4.5 of those contracts would renew in 2034,
3.375 would then renew in 2036 and so on.3 Taken to its completion and assuming an
average QF wind contract expiry date of 2031, Idaho Power assumes that only 75 MW of
the current 562 MW(13%) of QF wind will continue to exist at the end of the 20-year
planning horizon.
2031 562.82 2039 178.08
2033 422.12 2041 133.56
2035 316.59 2043 100.17
2037 237.44 2045 75.134
2045 compared to 2031 13%5
As a result, Idaho Power's resource deficit is increased by 487 MW, further"justifying"
Idaho Power's acquisition of more expensive new generation to make up the difference.
Idaho Power's proposed modeling of QF wind and solar renewals is not aligned
with the Commission's guidance for IRPs (or Resource Management Reports). The
Commission does not approve or acknowledge a utility's IRP, but instead reviews a plan
' In re Idaho Power 2023 IRP, Oregon Public Utility Commission ("OPUC")
Docket No. LC 84, Order No. 24-285, Appendix A at 34-37 (Aug. 26, 2024).
2 8 * 75%= 6.
3 6 * 75%=4.5; 4.5 * 75% =3.375.
4 Figures multiplied by 75% every two years.
5 75.13 /562.82 * 100 =—13%.
RENEWABLE ENERGY COALITION COMMENTS Page 3

to determine prudence of a utility's management decisions.6 Regarding a utility's
resource need, the utility is supposed to analyze "the most probable 20-year scenario" of
the utility's expected resource procurement. Assuming an inaccurate QF wind and solar
renewal rate is not the most probable scenario or prudent.
B. It Is Important to Accurately Model Renewal of Existing QFs Because
Existing QFs Are Likely to Renew and Provide Many Benefits and Cost
Savings
Typical wind farms are built with a minimum 30-year design life, however, nearly
all QF projects with Idaho Power are operating under 20-year contracts.$ Therefore, it is
more likely than not that a QF will renew or seek to enter into a new contract with Idaho
Power at the conclusion of its current contract if avoided cost rates and contract length
are acceptable. A new QF can often decide in which utility's service territory it wants to
locate to achieve the best outcome. However, once operational, the QF has fewer options
to sell its electricity, because it will likely incur significant transmission charges if it
wants to sell to a more distant utility. While some QFs are able to sell to a more distant
utility, the vast majority continue to sell to their currently interconnected utility.
Therefore, existing QFs are more likely to renew or enter a new contract with the utility
to which they are already directly interconnected.
Existing QFs also have already been constructed and are more economic to
operate than new projects which have more significant capital and interconnection costs
and are riskier. Importantly, existing QF projects are operating assets that have much
6 In re Idaho Electric Utility Conservation Standards and Practices, Case No. U-
1500-165, Order No. 22299 at 3 (Jan. 26, 1989).
7 Case No. U-1500-165, Order No. 22299 at 6.
8 See Attachment A, Idaho Power Response to RECs Request for Production No. 4,
Attachment 2, Tab "All PURPA QFs Data"with column 0) filtered for wind
projects and column (e) filtered for only"Active and Online"projects.
RENEWABLE ENERGY COALITION COMMENTS Page 4

more project life to be utilized and can offer power at lower rates than new
assets. Existing QF projects do not have any permitting risks, fuel risks, tariff risks,
Federal tax credit risks, construction risks, equipment procurement risks, transmission
study risks, and completion schedule risks. This collectively helps to contribute to lower
power prices, compared to new projects, which benefits Idaho Power and ratepayers.
New generation is more expensive than existing generation in several ways.
First, inflation has dramatically increased construction costs for materials and labor.
Second, tax credits for wind and solar will no longer be available for projects placed into
service after December 31, 2027.9 Third, as utilities across the country seek to fill
generation gaps caused by increasing load growth similar to Idaho Power, demand for
generation components will also increase placing upward pressure on costs. Fourth,
tariffs have increased the costs of materials used in generation. Fifth, transmission
constraints increase transmission costs and require construction of new transmission.
Many of these additional costs can be avoided if Idaho Power relied more heavily on
existing wind and solar QFs renewing their contracts.
Development of new wind in Idaho has become significantly more difficult over
the past few years, which increases the need and chances that low-cost existing wind
projects will continue to operate. The expiration of federal production tax credits, the
United State Department of Interior("DOI") direction requiring approval by the
Secretary of the Interior for all wind projects on federal lands and waters with an
"elevated review", the DOI cancellation of the Lava Ridge Wind Project, and the
9 See H.R. 1 (2025)https://www.congress.gov/bill/119th-congress/house-bill/1 (a
small exception applies to those projects that pass the Physical Work Test prior to
July 2026).
RENEWABLE ENERGY COALITION COMMENTS Page 5

passages of new Idaho laws to increase siting and compliance burdens,10 all point toward
elevated reliance on existing projects for decreased cost and increased reliability.
During Idaho Power's 2023 IRP, the Coalition reached out to the operators of the
wind QF projects regarding wind QF renewal. The Coalition received responses from
those projects and at the time 30 of the 32 projects had informed the Coalition they intend
to enter into contracts with Idaho Power after their current contracts expire or some have
not yet made a final decision, which account for about 607 MW. This was about 94
percent of the projects and about 97 percent of the Idaho Power wind QF contract
capacity. Subsequently,members of the Coalition reached out to the remaining QFs,
which confirmed that 100% of the QFs planned to renew their QF contracts. This
demonstrates Idaho Power's existing wind QFs plan to renew, which does not align with
how Idaho Power has modeled wind and solar QFs in the current IRP.
C. Implementation of Idaho's Current PURPA Policies Did Not Consider
Existing QFs Seeking to Renew Their Contract, Leading to Idaho Power
Planning to Acquire Significant New Resources at Higher Costs
The Commission's current policies related to published rates and contract length
will negatively affect QF renewal rates. This, in turn, hurts Idaho customers. These
policies were designed to address new projects, but they have unintended and harmful
consequences on existing QFs. If these consequences are not addressed, then Idaho
Power will likely over procure resources and potentially miss out on more cost-effective
to Jamie Ptacek,Idaho: 2025 Energy and Climate Policies Recap, Clean Energy
Transition Institute (June 25, 2025),
https://www.cleanenerg_ytransition.org_/post/idaho-2025-energy-and-climate-
policies-recap; Kaitlyn Hart,New Idaho bill forces wind farms to get rid of"Red
Light District'' (June 2, 2025), https://www.eastidahonews.com/2025/06/new-
idaho-bill-forces-wind-farms-to-get-rid-of-red-li ght-district/.
RENEWABLE ENERGY COALITION COMMENTS Page 6

renewing wind and solar QFs. At this time, the Coalition is not requesting the
Commission address or revise its current policies in terms of how they impact QF
renewals, and any changes to those policies should occur in a separate proceeding. The
Coalition only provides this information as contextual background and in anticipation
that Idaho Power may argue that QFs are unlikely to renew their contracts because of the
Commission's PURPA policies.I I
In Case No. GNR-E-I1-03, the Commission reduced the size of wind and solar
QFs eligible for published rates to 100 kilowatts ("kW").12 Published rates for all other
resource types remained available at up to 10 average megawatts ("aMW"). New QF
contracts above those thresholds receive IRP-based rates.
In Case No. IPC-E-15-01, the Commission approved Idaho Power's application to
reduce the contract terms for wind and solar QFs from 20 years to two years.13 One
reason the Commission changed the contract term to two years was because Idaho had
made significant advancements towards the goal of encouragement of PURPA resources
and there were capacity surpluses.14 Idaho Power stated in its Application, "[t]he
Company has 461 MW of PURPA solar capacity under contract to be on-line in 2016,
and an additional 885 MW of PURPA solar capacity in the queue actively seeking
11 In re Idaho Power 2025 IRP, OPUC Docket No. LC 87, Idaho Power's Reply
Comments at 11-12 (Oct. 6, 2025).
12 See In re the Commission's Review of PURPA QF Contract Provisions Including
the Surrogate Avoided Resource (SAR) and Integrated Resource Planning (IRP)
Methodologies for Calculating Avoided Cost Rates, Case No. GNR-E-11-03,
Order No. 32697 (December 18, 2012).
13 In re Idaho Power Company's Petition to Modify Terms and Conditions of
PURPA Purchase Agreements, Case No. IPC-E-15-01, Order No. 33357 at I
(Aug. 20, 2015).
14 Case No. IPC-E-15-01, Order No. 33357 at 24.
RENEWABLE ENERGY COALITION COMMENTS Page 7

PURPA energy sales agreements to be on-line in 2016."15 Prior,between 2008 and 2012,
Idaho Power saw 555 MW of wind QFs come online. The Commission noted that
PURPA additions at the time "extends the utilities' capacity surpluses to 2024 for Idaho
Power and 2028 for PacifiCorp."16
In its 2025 IRP, Idaho Power presents a very different planning paradigm than it
did in 2015. The IRP identifies a need to acquire over 3,500 MW of new generation, and
coal-to-gas conversion for an additional 611 MW. New acquisitions include 700 MW of
wind and 1,445 MW of solar. Thus, Idaho Power has a significant energy and capacity
need that can be filled by both new and existing generation.
Over the last 10 years, Idaho's PURPA contract policies have led to very little
new QF resources—35.5 MW from a mix of hydro, solar, biomass, and cogeneration—
have come online since 2018. However, many QF contracts were signed prior to the
contract length reduction in IPC-E-15-01 and are expiring in the near term. Between
2026 and 2032, Idaho Power will see 1,198 MWs of QF wind come to the end of their
respective contracts.17 Idaho Power would be facing an even larger resource deficit if
those contracts were not renewed.
It appears the Commission did not consider the current situation where a large
number of existing and operating projects would be renewing their contracts when
instituting the aforementioned changes to PURPA policies in Idaho. Indeed, Idaho
Power's Application in IPC-E-15-01 stated, "the Company believes the continued
15 Case No. IPC-E-15-01, Application at 2 (Jan. 30, 2015).
16 Case No. IPC-E-15-01, Order No. 33357 at 24.
17 See Idaho Power Response to RECs Request for Production No. 4, Attachment 2,
Tab "All PURPA QFs Data."
RENEWABLE ENERGY COALITION COMMENTS Page 8

creation of 20-year term contracts places undue risk on customers at a time when Idaho
Power has sufficient resources to meet customer demands."18 Now, Idaho Power's
failure to utilize existing generation when Idaho Power does not have sufficient resources
to meet customer demand has the opposite effect. This will place undue cost and risk on
customers to acquire more expensive new generation.
Any failure of existing QFs to renew their contracts immediately translates into
negative consequences for customers, as it forces the utility to replace the lost capacity
and energy with more expensive resources. Non-renewal, therefore, undermines the core
IRP objective of planning to secure dependable power and prudent decision-making, at
the lowest cost to best serve Idaho customers. The Commission should require Idaho
Power to update its QF policies to ensure that these less risky and lower cost existing
generation resources are able to continue selling power and are part of its future as well
as current resource portfolio. There is no reasonable circumstance in which Idaho
Power's existing wind QF resources drop from 562 MWs to 75 MWs and are replaced by
more expensive and riskier wind generation, negatively impacting Idaho Power's
customers. The only reasonable explanation is that Idaho's QF policies cause such a
precipitous drop.
III. CONCLUSION
The Coalition appreciates the opportunity to comment on Idaho Power's 2025
IRP. The Commission should find Idaho Power's QF wind and solar renewal
methodology imprudent. The Commission should then direct Idaho Power to update its
QF wind and solar renewal methodology in future IRPs. Idaho's policies toward new
18 Case No. IPC-E-15-01, Application at 2 (emphasis added).
RENEWABLE ENERGY COALITION COMMENTS Page 9

wind and solar QFs will have unintended and harmful consequences for existing QFs and
Idaho Power's customers. This will cause Idaho Power to acquire more expensive new
generation rather than less expensive existing generation.
Dated this 13th day of November 2025.
Respectfully submitted,
Irion A. Sanger, ISB o. 12488
Sanger Greene, PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Telephone: [phone]
Fax: [phone]
[e-mail]
Of Attorneys for the Renewable Energy Coalition
RENEWABLE ENERGY COALITION COMMENTS Page 10

CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 13th day of November 2025, I caused to be served
a true and correct copy of the foregoing document upon the following individuals in the
manner indicated below:
Electronic Mail Only(See Order No. 35058):
Idaho Public Utilities Commission
Commission Secretary
secretary�ic,puc.idaho.gov
Idaho Public Utilities Commission
Commission Staff
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
Tim Tatum
Riley Maloney
m goicoecheaallengidahopower.com
dwalkerkidahopower.com
docketsgidahopower.com
ttatum(kidahopower.com
rmaloney&idahopower.com
mbabbitt(kidahopower.com
Idaho Irrigation Pumpers Association
Eric L. Olsen
Lance Kaufinan
elo(kechohawk.com
taysha(k echohawk.com
lancegaeginsi ht�com
Micron Technology
Austin Rueschhoff
Thorvald A.Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland&Hart, LLP
darueschhoff(a�hollandhart.com
tnelson&hollandhart.com
awj ensen(a�hollandhart.com
karoach(cr�,�hollandhart.com
aclee(khollandhart.com
tlfriel(cr�,hollandhart.com
RENEWABLE ENERGY COALITION COMMENTS Page 11

NW Energy Coalition and Renewable Northwest
Benjamin J. Otto
Lauren McCloy
Derek Goldman
Mike Goetz
Kathie Chamberlain
Kyle Unruh
benknwenergy org
laurenknwenergy.org
derekknwenergy.org
mikekrenewablenw.org
katherine krenewab lenw.org
kylekrenewablenw.org
Irion A. Sanger
RENEWABLE ENERGY COALITION COMMENTS Page 12

Attachment A
Idaho Power Response to RECs Request for Production No. 4, Attachment 2,
Tab "All PURPA QFs Data"

Response to REC's Request for Production No.4—Attachment 2
Project Number Project Name Contract Type Contract Status County Physical State Contract State Plant Size Facility Type Contract Date(if First Energy First Energy Operational Operational Contract PUCCase Number Mail
Location project Contract Data Est Data Actual Data Est Data Actual Termination Amount(May
date is missing Data Vary from
date=1-1-1900) Replacement? Nameplate)
21615101 Bennett Creek Wind Farm PURPA Active and Online Elmore ID ID 21000 Wind 12/20/2006 3/31/2007 9/15/2008 12/31/2007 12/15/2008 12/15120281PC-E-06-35 21000
12618240 Benson Creek Windfall PURPA Active and Online Baker OR OR 10000 Wind 10/9/2013 9/1/2016 3/812017 12/31/2016 3/23/2017 3/23/2037 RE 123 10000
31765170 Bull Butte Wind Park PURPA Active and Online Cassia ID ID 21300 Wind 5/5/2005 10/30/2005 12/3/2010 9/1/2010 2/1/2011 2/1/2031 IPC-E-05-18 21300
31315050 Camp Reed Wind Park PURPA Active and Online Elmore ID ID 22500 Wind 7/9/2009 9/30/2010 12/21/2010 9/30/2010 12/31/2010 12131/20301PG-E-09-18 22500
31318100 Cassia Wind Farm LLC PURPA Active and Online Twin Falls ID ID 8400 Wind 4/7/2006 8/31/2006 2/16/2009 12/31/2006 3/24/2009 3/24/2029 IPC-E-06-10 840a
21615115 Cold Springs Windfarm PURPA Active and Online Elmore ID ID 23000 Wind 11/12/2010 1.131/2011 8/11/2012 12/31/2012 12/812012 12/812032 IPC-E-10-38 23000
21615120 Desert Meadow Windfarm PURPA Active and Online Elmore ID ID 23000 Wind 11/12/2010 12/31/2011 7/27/2012 12/31/2012 12/8/2012 12/8/2032 1PC-E-10-39 23000
12618230 Durbin Creek Windfall PURPA Active and Online Baker OR OR 10000 Wind 10/9/2013 9/1/2016 3/812017 12/31/2016 3/23/2017 3/23/2037 RE 123 10000
31315035 Fossil Gulch Wind PURPA Active and Online Twin Falls ID ID 10500 Wind 9/9/2004 12/15/2004 12/31/2004 1/1/2005 9/30/2005 9/30/20251PC-E-04-19 10500
3176516 Golden Valley Wind Park PURPA Active and Online Cassia ID ID 12000 Wind 5/5/2005 4/30/2006 11/23/2010 6/1/2006 2/l/2011 2/l/2031 IPC-E-05-17 12000
21615120 Hammett Hill Windt— PURPA Active and Online Elmore ID ID 23000 Wind 11/12/2010 12/31/2011 8/2/2012 12/31/2012 12/8/2012 12/8/2032 1PC-E-10-40 23000
31315130 High Mesa Wind Project PURPA Active and Online Twin ID ID 40000 Wind 11/16/2011 11/1/2012 12/812012 12/28/2112 12/27/2012 12/27/2032 IPC-E-11-21
Falls/Elmore 40000
4171:140 Horseshoe Bend Wind PURPA Active and Online Cascade MT ID 9000 Wind 1/6/2004 12/31/2004 2/16/2006 12/31/2004 2/28/2006 2/28120261PC-E-04-1 "00
21615105 Hot Springs Wind Farm PURPA Active and Online Elmore ID ID 21000 Wind 12120/2006 3131/2007 9/15/2008 12/31/2007 12/15/2008 12/15/2028 IPC-E-06-34 21000
12618220 Je6 Creek Windt— PURPA Active and Online Baker OR OR 10000 Wind 10/9/2013 9/1/2016 3/8/2017 12/31/2016 3/23/2017 3/23/2037 RE 123 10000
12618200 Lime Wind Energy PURPA Active and Online Baker OR OR 3000 Wind 12/812010 10/1/2011 11/19/2011 12/31/2011 12/9/2011 12/9/2031 3000
21615130 Mainline Windfarm PURPA Active and Online Elmore ID ID 23000 Wind 11/12/2010 12/31/2011 7/4/2012 12/31/2012 12/8/2012 12/8/2032 1PC-E-10-41 23000
31720190 Milner Dam Wind PURPA Active and Online Cassia ID ID 19920 Wind 10/14/2005 11/1/2006 12/11/2010 5/1/2007 2/1/2011 2/1/20311PG-E-05-30 19920
3131:075 Oregon Trail Wind Park PURPA Active and Online Twin Falls ID ID 13500 Wind 2/18/2005 12/31/2005 12/23/2010 1/15/2006 1/25/2011 1/25/2031 IPC-E-05-8 13500
31315060 Payne's Ferry Wind Park PURPA Active and Online Twin Falls ID ID 21000 Wind 7/9/2009 9/30/2010 12/21/2010 9/30/2010 12/31/2010 12/31/2030 IPC-E-09-20 21000
31315045 Pilgrim Stage Station Wind Park PURPA Active and Online Twin Falls ID ID 10500 Wind 2/18/2005 12/31/2005 12/30/2010 9/1/2010 1/17/2011 1/17/20311PC-E-05-7 10500
12618210 Prospector Windfarm PURPA Active and Online Baker OR OR 10000 Wintl 10/9/2013 0/1/2016 3/8/2017 12/31/2016 3/23/2017 3/23/2037 RE 123 10000
41455300 Rockland Wind Farm PURPA Active and Online Power ID ID 80000 Wind 9/3/2010 7/15/2011 11/3/2011 12/31/2011 12/9/2011 12/9/2036 IPC-E-10-24 80000
21615135 Ryegrass Windburn PURPA Active and Online Elmore ID ID 23000 Wind 11/12/2010 12/31/2011 8/10/2012 12/31/2012 12/812012 12/8120321PG-E-10-42 23000
31618100 Salmon Falls Wind PURPA Active and Online Twin Falls ID ID 22000 Wind 10/14/2005 11/1/2006 1/4/2011 5/1/2007 4/22/2011 4/22/2031 IPC-E-05-33 22000
21615110 Sawiooth Wind Project PURPA Active and Online Elmore ID ID 22000 Wind 9/1/2009 10/31/2012 10/1/2011 12/31/2012 11/1/2011 11/1/2031 IPC-E-09-25 22000
31315055 Thousand Springs Wind Park PURPA Active and Online Twin Falls ID ID 12000 Wind 2/18/2005 12/31/2005 12/23/2010 1/15/2006 1/17/2011 1/17/2031 IPC-E-05-6 12000
31315065 Tuana Gulch Wind Park PURPA Active and Online Twin Falls ID ID 10500 Wind 2/18/2005 12/31/2005 12/23/2010 1/15/2006 1/25/2011 1/25120311PC-E-5-9 10500
31315150 Tuana Springs Expansion PURPA Active and Online Twin Falls ID ID 35700 Wind 8/5/2009 11/1/2009 4/10/2010 6/30/2010 5/14/2010 5/14/2030 IPC-E-09-24 3"00
21615140 Two Ponds Windfarm PURPA Active and Online Elmore ID ID 23000 Wind 11/12/2010 12/31/2011 7/21/2012 12/31/2012 12/8/2012 12/8120321PG-E-10-43 23000
12618245 Wilkes+Spring Windfarm PURPA Active and Online Baker OR OR 10000 Wind 5/23/2014 9/1/2016 3/8/2017 1.112016 3/23/2017 3/23/2037 10000
31315070 Yahoo Creek Wind Park PURPA Active and Online Twin Falls ID ID 21000 Wind 7/9/2009 9/30/2010 12/21/2010 9/30/2010 12/31/2010 12/31/2030 IPC-E-09-19 21000
Page 1 of 1
9/4/10249:47:29 AM Response to REC's Request for Production No.4—Attachment 2

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) Case No. IPC-E-25-23
COMPANY'S 2025 INTEGRATED )
RESOURCE PLAN ) DECLARATION OF JOHN R.
LOWE
I, John R. Lowe, declare under the penalty of perjury as follows:
1. I am the founder and director of the Renewable Energy Coalition(the
"Coalition"). This declaration is based on my personal knowledge and, if called to testify
to the following facts, I could and would competently do so. I submit this declaration in
support of the Coalition's Comments in IPC-E-25-23, Idaho Power's Integrated Resource
Program proceeding.
2. My name is John R. Lowe. I am the founder and director of the Coalition. My
business address is P.O. Box 25576, Portland, Oregon 97298.
3. In 1975, I graduated from Oregon State University with a Bachelor of Science
degree.
4. From 1975 to 2006, I was employed by PacifiCorp. Over most of that 30-year
period, my responsibilities were primarily related to PacifiCorp's contracting and policies
under the Public Utility Regulatory Policies Act of 1978 ("PURPA") throughout the
utility's multi-state service territory, which includes Washington, Oregon, California,
Idaho, Wyoming, and Utah. My responsibilities included all contractual matters arising
under PURPA and supervision of other matters related to both power purchases and
IPC-E-25-23 DECLARATION OF JOHN R. LOWE
Page 1 of 3

interconnections. In that capacity, I was involved in scores of contract negotiations,
helped develop new contract concepts, terms and language, and became familiar with
terminology commonly used in the electric utility industry in utility tariffs and written
power purchase agreements ("PPA") for purchases from qualifying facilities ("QF").
5. Since 2009, I have been directing and managing the activities of the Coalition as
well as providing consulting services to individual members of the Coalition related to
both power purchases and interconnections. My interconnection work at the Coalition
has been primarily related to small generation projects.
6. I have previously reached out or have been copied on email communications to
current wind QF projects selling power to Idaho Power.
7. As of February 7, 2024, I had seen responses from 30 of the 32 wind QF projects.
8. Of the 30 wind QF projects, the majority have indicated they intend to enter into
contracts with Idaho Power after their current contracts expire while some have not yet
made a final decision. At that time, I was not aware of any project that is not intending to
renew. As of the filing of this Declaration, I am not aware of any change to the intent to
renew the contract of any of those 30 QF wind projects. Those 30 projects account for
about 94 percent of the Idaho Power wind QF projects. These 30 projects represent about
607 MW or 97 percent of the Idaho Power wind QF contract capacity.
10. I am aware that other members of the Renewable Energy Coalition have reached
out to QF wind projects in the Idaho Power service territory and all have indicated an
IPC-E-25-23 DECLARATION OF JOHN R. LOWE
Page 2 of 3

intent to renew their contract upon expiration. Below is a list of all the current wind QFs
selling power to Idaho Power.1
Rolapt N,,O Protect Name centred TYPe contrad Bbbe county Ph""I 6bt, c0rrtrad wd,Plan Rft Typa Corrtrad Dab Flnt EnrtgY Fl Em 0q 11 d Op 11...I contract PUC N=N,
Loratlon Dab Eat -Ache Deb Eat -du. T=m 11.
31315035 Fossil Gukh WM PURPA Mc erd Onine win Fab ID ID Id500 WiM 91912004 Tv_­ 12/312004 1I12005 W302005D 9I3020251PGE-9
4171814o Horseshoe B,'WFA 1 12 PURPA Active erM Onine Cescede I 9000 Wind 162004 12/3004 2/162006 21-1- 2202006 2282026 1P 1
21815101 Ed—CreekW Farm PURPA A�Bve eM ONine -Elmore '
ID D 21000 Wnd 11W202006 "ll200] 9I152000 12/3l= 12/152000 12/15I20201PC-E-0
21815105 Hot Sprirps WrH Ferm PURPA A—eM Online Elmore ID ID 21000 Wintl 122W2006 YB1200] 91152000 1221200] 12I152008 12/1520201PC-E4Ifi-34
31318100 Cassle Wind Ferm L. PURPA Acd.eIb Online Falk ID ID 8400 Wind 422006 BI312006 2/162008 12/312006 3242008 3242028IPC-E-06-10_
31315150 Tuene Springs Eapemlon PURPA 1—eM Online Twin Fell ID ID 35700 Wnd W52009 111112 4/102010 W302010 5/1412 ld 5114 2 0 3 0 1PC-E4 V
31315050Cemp Reetl W,.P PURPA A—aM Online Elmore ID ID 225001intl 752W9 W302old 12212010 9OD2010 12/112010 1-20301PC-E-11
31313d6o Payntls Ferry Wnd Perk PURPA Acd.alb Online Falk ID ID 21000 Wind )R2008 W302010 12212010 W302010 12/312010 1218120301PC-E-08-20
313150]0 Yeh00 Creek Wind Perk PURPA Id.eM Online Twin Fell ID ID 21000 Wnd ]I92009 9202010 12212010 9I302010 1W312010 12/3120301�C-E-0&19
31315045 Pilgrim Stage Gt.—Wintl Perk PURPA A—aM Online Twin Fall ID ID 10500 Wintl 2I182005 12/312M 12.010 9112010 1l1]2011 1/1]20311PC-E46]
31315055 ThousaM 6pnrgs Wind PeM PURPA Acd"elb Online Twin Falk ID ID 12000 Wind 2/182005 1291l2005 12232010 1I15I2006 11172011 1/1)20311PGE-056
313150]S Oregon Trail Wind Peh PURPA Md.eM Online Twin Fell ID ID 13500 WrM 2/182005 12/31rz005 1223rz010 1I1W2006 125rz011 125R031 Hp E-0
31315065 Tuene Gulch Wintl PaA PURPA A—arM Online Twin Falls ID ID 10500 Wintl 2/182005 12/312005 12232010 1I152006 1252011 1252031 IPC-ES9
31 Ml]DButleyB WM PeM PURPA Active eM Online Cassla ID ID 21100 Wind SI52005 1W302005 12/3R010 W12010 2/12011 2/120311PGEM18
31]0510D(1n Valey WlM perk PURPA Acdva eM Onliw ID ID 12000 Wnd W52005 4I3g2006 11232010 W120W 111011 2/120311-1-11
31]20190 Milner Oem WirM PURPA ID ID _ _ 2/12011 2 0311PGE-0S30
31618100=.Fell Wintl PURPA AcOve aM Online Twin Falls ID ID 22000 Wintl 1W14I2005 11I120W 11/42011 5I12007 4]222011 42 0311PC-E-0
21615110 Sa Nh w1w P"j"t PURPA Active elk Online Elmore ID _ ID 2200 Wlnd 9112009 10212012 10I12011 12/312012 11I12011 11/120311PC-E-09-25
12610200 Ume Wlnd Energy PURPA Active end Online Baker OR OR 3000 Wind 12R2010 1W12011 11/1W2011 12212011 1_11 12 o,l
41455300 Roc.Wntl Ferm PURPA AcBva aM Online Power ID ID 80000 Wntl W32010 7/1M011 1122011 12/312011 12/82011 1219]20X6 E-1D24
2161511,Cold Springs Windlerm PURPA Md.alb Online Elmore ID ID 2W 0Wind 11I12y2010 1.12011 dl-012 1=12012 12I82012 12/82032--1-
218151200esedMeedowWl.— PURPA Active end Online Elmore ID ID 23000 Wind 11I12r2o10 1 12011 ]2]2013 l=3 12 12/62012 12/&20UH1 E-105
21815125 Hammett Hill Windlerm PURPA AcBva aM Online Elmore ID ID 23000 Wntl 11I122010 12)312011 (VL2012 12/312012 12102012 11/BI20321PC-E-1040
21815130Maicline WinLbrrn PURPA AcOve eM Online Elmore ID ID 23000 Wintl 11I1212o10 1 12011 1/ 012 1=12012 12/02012 12/020321--1-1
F
1135 Rye9ress Wlndiarm PURPA Active end Online Elmore ID ID 23000Wind 11I12r2o10 12912011 81102012 1=12012 12/62012 12/820321PGE10d215140 Two Ponds Wlndbnn PURPA AcBva aM ONine Elmore ID ID 23000 Wnd 11I12I2o10 12I312011 ]212012 12/31/2012 12/82012 12IBY20U:K--1p
1513DHigh MesaWintl Prcltti PURPA AcOve eM ONine ID ID 4 00 Wntl 11I162o11 11I12012 12/82013 12282013 122]2012 12R]20321PGE-11-2619240 BensonCreekWglerm PURPA Active alb Online Baker OR OR lWooWind 1dlIdlN3 W12016 Y 01] 1=12016 323201] 323203]RE 12318230 Duroin Creek WiMlerm PURPA me aM ONine Seker OR OR 10000 WM 10I92013 W1rz016 3R201T 1?/312016 323201] 323rz037 RE 123
18210 Creek Witltl PURPA AcBve eM Online Baker OR OR 10000 WM 109(l013 W12016 1 1] 12(312016 123201] 3I232037 RE10210 Prospector WinOhrm PURPA Active alb Online Baker OR OR loo—nd 1QR2o13 W12016 Y 01] 1L312016 ]23201] 323203]RE 123
122245 ZZW Spring'w"ZZ_ PURPA Md.entl Online Seker OR OR 10000 Wnd 5rz32014 9I12018 3R201] 12/312016 323201] 323203]
I hereby declare that the above statement is true to the best of my knowledge and
belief, and that I understand it is made for use as evidence in court and is subject to
penalty for perjury.
DATED this 13th day of November 2025.
John R. Lowe
1 See also Idaho Power Response to the Coalition Data Request 4, Attachment 2,
tab "All PURPA QFs Data"with column 0) filtered for wind projects and column
(e) filtered for only "Active and Online"projects (Attachment A to the Coalition's
Opening Comments).
IPC-E-25-23 DECLARATION OF JOHN R. LOWE
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