20251117Final_Order_No_36848.pdf

Office of the Secretary
Service Date
November 17,2025
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-25-15
COMPANY'S APPLICATION FOR ITS )
FIRST ANNUAL UPDATE TO THE EXPORT ) ORDER NO. 36848
CREDIT RATE FOR NON-LEGACY ON- )
SITE GENERATION CUSTOMERS FROM )
JUNE 1, 2025 THROUGH MAY 31, 2026, IN )
COMPLIANCE WITH ORDER NO. 36048 )
On April 1,2025,Idaho Power Company("Company")applied to the Idaho Public Utilities
Commission ("Commission") to update the Export Credit Rate ("ECR") for non-legacy on-site
generation customers from June 1, 2025 through May 31, 2026, and to approve the Company's
corresponding proposed changes to Schedule 6, Residential Service On-Site Generation
("Schedule 6"), Schedule 8, Small General Service On-Site Generation ("Schedule 8"), and
Schedule 84, Large General, Large Power, and Irrigation On-Site Generation Service ("Schedule
84").
On September 30,2025,the Commission issued a Final Order,implementing the ECR with
modifications as set forth by the Final Order and suspending the annual update to the ECR until
April 1, 2028. Order No. 36785.
On October 21, 2025,the city of Boise City("Boise City") and Sierra Club and Vote Solar
("SCNS") filed Petitions for Reconsideration. On October 27, 2025, Clean Energy Opportunities
for Idaho ("CEO") filed Comments Re: Petitions for Reconsideration. On October 28, 2025,
SCNS filed an additional Cross Petition for Reconsideration. On October 28, 2025, the Company
filed an Answer to Boise City and SCNS's Petitions for Reconsideration.
With this Order, we deny these Petitions for the reasons described below.
ORDER NO. 36785
In Order No. 36785, the Commission approved the Company's Application to update the
ECR for non-legacy on-site generation customers, subject to mitigation and modifications,
effective October 1, 2025. The Commission found it reasonable to limit the change in the avoided
energy value to a 40% decrease from the current ECR's avoided energy value, applied to both the
summer and non-summer months. Id. at 24. The Commission also suspended the annual update
ORDER NO. 36848 1

requirement of Order No. 36048 until April 1, 2028, and ordered the Company to maintain the
ECR rates until the 2028 update.Id. at 25.
BOISE CITY'S PETITION FOR RECONSIDERATION
Boise City requested the Commission grant reconsideration by written briefs and
comments. Boise City Petition at 1. Boise City believed that Order No. 36785 did not address the
underlying issues that caused the need for the Commission to mitigate the ECR and that there were
still questions of law and policy that should be heard on reconsideration.Id. at 1-2.
Boise City believed that even though the Commission found the ECR methodology to be
reasonable when it was constructed, the Commission could reevaluate the methodology if it
produced unfair results. Id. at 2. Boise City requested the Commission: 1) deny the ECR update;
2) direct the Company to update the basis of the avoided energy value component of the ECR; 3)
cap future decreases of the ECR to 20%; and 4) establish an ECR update cycle of 3 or 4 years. Id.
Boise City believed these requests would better fulfill the Commission's intent than the mitigation
ordered in Order No. 36785.Id.
Boise City requested that the Commission deny the ECR update. Id. Boise City believed
the focus should not have been on avoiding subsidizing customer-generators, but instead, about
providing fair compensation to customer-generators.Id. Boise City believed that the Company had
economic incentives to reduce the value of exports from customer-generators and that it was, and
continues to be,the responsibility of the Company and Commission to achieve a fair compensation
structure. Id. at 3. Boise City argued that even though ratepayers could see an increase to their
monthly bill through the Power Cost Adjustment ("PCA"), it was not enough to justify paying
customer-generators an unfair price for the power they produce. Id. Boise City also argued that if
the Company continued to underpay customer-generators and discourage home generation,
ratepayers could see an increase to their base rate because the Company would need to invest in
more generation infrastructure to keep up with demand.Id. at 4.
Boise City requested the Commission direct the Company to update the basis of the
avoided energy value component of the ECR. Id. at 5. Boise City believed that the Commission
should implement policy tools to reduce future price swings, including directing the Company to
provide additional options for determining the avoided energy value. Id. Boise City argued that
using regional wholesale market prices as a proxy for avoided energy costs undervalued the
benefits provided by customer-generators, created fluctuations in the ECR, and did not accurately
ORDER NO. 36848 2

reflect the reality of how the energy produced by customer-generators was consumed on the
Company's system.Id.
Finally,Boise City requested the Commission cap future decreases of the ECR to 20%and
establish an ECR update cycle of 3 or 4 years. Id. at 2 and 6. Boise City interpreted the
Commission's intent in Order No. 36785 to include a policy of gradualism in adjusting the ECR
and believed that a 20% cap would achieve that goal.Id. Boise City believed that the 40% cap on
the avoided energy value and suspension until April 2028 complicated the matters at issue and
delayed the clarification needed to provide an ongoing framework to ensure fair compensation.Id.
SIERRA CLUB AND VOTE SOLAR'S PETITION FOR RECONSIDERATION
SCNS requested the Commission grant reconsideration by written briefs and comments.
SCNS Petition at 2. SCNS requested the Commission grant reconsideration and modify the ECR
methodology through a collaborative stakeholder process prior to the Company's ECR update in
2028.Id.
SCNS believed that by providing mitigation to the ECR, the Commission recognized that
the Company's proposed ECR rate was unjust and unreasonable. Id at 3. SCNS further believed
that while the mitigation efforts put into place by the Commission would assist generation
customers, Order No. 36785 failed to explain how the Commission came to adopt the mitigation
measures, nor dealt with the underlying deficiencies in the ECR methodology. Id. SCNS argued
that while it did not oppose the mitigation measures adopted, the measures were ordered ad hoc.
Id. at 4.
SCNS stated that it identified several shortcomings with the ECR methodology that had
been expressed in Case No. IPC-E-23-14 and the current proceeding. Id. at 4-5. SCNS believed
that the lack of stakeholder review was a cause for concern, as demonstrated by a calculation error
in the Effective Load Carrying Capacity ("ELCC") used to calculate the avoided generation
capacity cost in the 2024 ECR. Id. at 5. SCNS argued that due to the "filed rate" doctrine, the
Commission would be unable to address the underpayment to customers and would continue to be
unsure if future calculations were correct in the future without the stakeholder review. Id. at 5-6.
In addition to the calculation error in the ELCC, SCNS believed that the zero-value assigned to
the avoided transmission costs was also indicative of calculation error that should be reviewed.Id.
at 6.
ORDER NO. 36848 3

SCNS noted the volatility in the avoided energy component of the ECR and believed that
volatility led to Commission Staff s("Staff')recommendation to implement mitigation.Id. SCNS
stated that it had previously recommended using a longer rolling average for the avoided energy
value to reduce volatility and believed that doing so would provide a longer-term improvement to
the ECR calculation instead of a"short-term ad hoc fix."Id. at 6-7.
SCNS recommended the Commission direct Staff to convene a stakeholder working group
to assess modifying the ECR methodology and submit its findings to the Commission for review.
Id. at 7. SCNS believed a stakeholder working group would provide a low-cost means to resolve
technical issues with the ECR methodology prior to the Company's next filing.Id. SONS provided
a proposed timeline for the recommended working group to review the ECR methodology and
submit its findings to the Commission for review prior to the Company's 2028 ECR filing. Id. at
8.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO'S COMMENTS RE: PETITIONS
FOR RECONSIDERATION
CEO submitted Comments in response to Boise City and SCNS's Petitions for
Reconsideration. CEO Comments at 1. CEO stated that it supported the Commission's decision to
suspend the ECR update until 2028. Id. at 2. CEO supported SCNS's proposal to use the time
prior to the 2028 ECR update to consider outstanding issues with regard to the ECR methodology.
Id. CEO stated it also supported Boise City's recommendation to limit future ECR decreases to
20% and limit the update to the ECR to every 3-4 years. Id. CEO believed that the Commission
should consider the balance of fairness and set a higher ECR. Id.
SIERRA CLUB AND VOTE SOLAR'S CROSS PETITION FOR RECONSIDERATION
SCNS filed its Cross-Petition for Reconsideration in response to Boise City's Petition for
Reconsideration. SONS Cross-Petition at 1. SCNS agreed with Boise City that the ECR needed
to fairly compensate customer-generators and that the current ECR risked higher long-term costs
to ratepayers through increased rate-based investment by undervaluing distributed generation. Id.
at 3. SCNS believed that because both SCNS and Boise City viewed the mitigation measures in
Order No. 36785 as an acknowledgement that the calculated ECR was unjust and unreasonable,
there was confirmation that the current methodology could not be relied upon to produce
reasonable results. Id.
ORDER NO. 36848 4

SCNS believed that the evidence in the record supported Boise City's requests to: 1) deny
the ECR update; 2)direct the Company to update the basis of the avoided energy value component
of the ECR; 3) cap future decreases of the ECR to 20%; and 4) establish an ECR update cycle of
3 or 4 years. Id. SCNS agreed that implementing a 20% cap and updating the ECR cycle to 3-4
years would improve rate stability. Id. at 4.
SCNS argued that if the Commission chose to deny Boise City's Petition for
Reconsideration, it should, at a minimum, grant SCNS Petition for Reconsideration and direct
Staff to convene a working group. Id.
IDAHO POWER'S ANSWER TO BOISE CITY AND SCNS'S PETITIONS FOR
RECONSIDERATION
The Company filed an Answer to the Petitions for Reconsideration filed by Boise City and
SCNS ("Petitioners"), requesting the Commission dismiss both Petitions because the Company
believed they failed to comply with Commission procedural rules and improperly sought to reopen
a different/previous docket. Company Answer at 1-2.
The Company stated that the current case was its first annual filing to implement the ECR
methodology approved by Order No. 36048 in Case No. IPC-E-23-14. Id. at 2. The Company
noted that Petitioners did not petition for reconsideration in the methodology case. Id. The
Company believed that the scope of the current case was limited to whether the Company had
properly applied the Commission-approved formula and stated that in Order No. 36785 the
Commission acknowledged the Company's filing complied with the Commission-approved ECR
methodology.Id. at 3. The Company believed that the arguments presented in the Petitions raised
issues that have already been addressed by the Commission and were outside the scope of this
docket.Id. at 4.
The Company argued that both Petitioners presented requests for the Commission to
reconsider the ECR methodology approved in Order No. 36740 through a veiled request to
reconsider Order No. 36785 in the current ECR update case.Id. at 10. The Company believed that
Order No. 36048 is final and that it would be an impermissible collateral attack to grant
reconsideration in this case for the methodology previously ordered in IPC-E-23-14. Id. at 10-11.
The Company stated that many of the issues raised by the Petitioners were considered and
addressed by the Commission in IPC-E-23-14 and that neither party petitioned for reconsideration
at that time.Id. at 12. The Company argued that reconsideration would not be an appropriate forum
ORDER NO. 36848 5

for parties to reargue previously rejected arguments, and that the Petitioners' requests should be
denied.Id.
The Company believed Boise City's Petition failed to establish that Order No. 36785 was
unreasonable, unlawful, erroneous, or not in conformity with the law, as required by the
Commission's Rules of Procedure. Id. at 13. The Company also argued that Boise City's Petition
did not dispute that the Company's 2025 ECR update filing complied with the Commission-
approved ECR methodology,but instead,raised arguments already considered by the Commission
in the ECR methodology case. Id.
The Company believed that Boise City incorrectly inferred "unfairness" in the
methodology based on the Commission's implemented mitigation. Id. at 14. The Company stated
that mitigation was not due to a deficiency in the methodology, but an effort to offset increased
bills for customers impacted by the update to the ECR.Id. The Company also disagreed with Boise
City's assessment that the public comments in the current case demonstrate that the ECR
methodology is inequitable.Id. at 15. The Company stated that it is accountable to more customers
than just those impacted by the ECR and legally obligated to develop mechanisms and proposals
that result in fair, just, and reasonable rates for customers, including not creating cost shifting
between generators and non-generators.Id.
In response to SCNS's Petition, the Company disputed that Order No. 36785 should be
reconsidered due to the mitigation measures being adopted on an ad hoc basis. Id. at 16. The
Company believed that the mitigation measures adopted by the Commission were a hybrid
approach of various mitigation proposals, including Staff's proposal to limit the ECR decrease by
20, 30, or 40%. Id. at 17. The Company believed that Order No. 36785 provided ample
explanations,justifications, and findings of fact for the mitigation measures to be implemented by
the Commission.Id. at 18. The Company also provided numerous examples of prior orders where
the Commission found mitigation to be reasonable to limit the impact of rate changes on customer
bills. Id. at 18-20.
In response to the proposed working group,the Company argued that a similar process had
already been conducted, reviewed, and approved by the Commission in Case Nos. IPC-E-21-21
and IPC-E-22-22. Id. at 24. The Company believed that the Petitioners' request should be denied
because the recommendations in the ECR methodology case relied on years of stakeholder
engagement and technical analysis.Id. at 25.
ORDER NO. 36848 6

COMMISSION FINDINGS AND DECISION
Reconsideration provides an opportunity for a party to bring to the Commission's attention
any question previously determined and thereby affords the Commission an opportunity to rectify
any mistake or omission it may have made. Washington Water Power Co. v. Kootenai
Environmental Alliance, 99 Idaho 875, 879, 591 P.2d 122, 126 (1979). Under Idaho Code § 61-
626(1), a petition for reconsideration must be filed within 21 days of the order being issued. Once
a petition for reconsideration is filed,there is a seven-day period for persons to file a cross-petition
addressing the issues raised in the original petition.
The Commission now considers Boise City's and SCNS's Petitions for Reconsideration
requesting the Commission reexamine the ECR methodology used to update the ECR for non-
legacy on-site generation customers.
As explained in Order No. 36785, the Commission decided not to consider proposals and
concerns regarding the ECR methodology in IPC-E-25-15 as they fell outside the scope of the
current case and had already been previously litigated. Order No. 36785 at 23. The Commission
further explained that "comprehensive review of each component of the ECR calculation" had
been provided in Order No. 36048.Id. The focus of the current case was not to further address the
ECR methodology, but rather to implement it as directed in Order No. 36048. The Commission
reviewed the Company's Application to update the ECR in accordance with the directives of Order
No. 36048 and found the Company's filing to be in conformance with the Commission-approved
ECR methodology. Id. at 24. The Commission's reasoning for not addressing the ECR
methodology in the current case still holds true. The development of the methodology was the
result of numerous cases with extensive records and the involvement and input of multiple parties,
including the Petitioners. The Petitioners' concerns regarding the methodology stem from
arguments made and decided on in Order No. 36048. As the implementation of the ECR
methodology was at issue in this case, not the methodology itself, we do not find the Petitioners'
arguments persuasive and deny the Petitioners' requests for reconsideration.
While the Company's filing was found to comply with Order No. 36048, the Commission
decided mitigation was reasonable in the updated ECR.Id. Contrary to the reasoning provided by
the Petitioners, the Commission explained that the mitigation was implemented to "reduce the
impact of recent rate changes."The Commission did not find fault with the ECR methodology,but
instead, acknowledged"that all customers—including non-legacy on-site generation customers—
ORDER NO. 36848 7

have faced increases to their average monthly bills over the past 18 months."Id. The Commission
further recognized "that the updates to the ECR proposed in the Company's Application would
further affect customers in Schedule 6, 8, and 84." Id. These mitigation measures were not
implemented due to any unfair results from the ECR methodology, but rather, as a way to lessen
the impact of bill increases on customers that had already seen increases as a result of unrelated
rate cases.
Ultimately, the Commission found it reasonable to limit the change in the avoided energy
value to a 40% decrease from the current ECR's avoided energy value, applied to both summer
and non-summer months. Id. The Commission's decision was formulated based on the
recommendations of the parties presented in the record, which suggested mitigation measures
ranging from 20-50%. Specifically, Staff provided the following table explaining the impact
mitigation measures would have on the ECR if implemented:
Export Credit Rate by Component(cents/kWh) Max Change current proposed 20%. 30% 40%
Energy Summer 5.65330 1.76820 4.52260 3.95730 3.39200
bicluding integration and losses Non-Summer 4.83650 0.95400 3.86920 3.38560 2.90190
Annual* 5.15660 1.28520 4.13500 3.61810 3.10130
Generation Capacity On-Peak 11.58620 11.90170 11.90170 11.90170 11.90170
Off-Peak 0.00000 0.00000 0.00000 0.00000 0.00000
Annual* 0.78710 1.13600 1.13600 1.13600 1.13600
Transmission& Distribution Capacity On-Peak 0.24560 0.38990 0.38990 0.38990 0.38990
Off-Peak 0.00000 0.00000 0.00000 0.00000 0.00000
Annual* 0.0167 c 0.0372 t 0.0372¢ 0.0372� 0.0372¢
Total Summer On-Peak 17.48500 14.05980 16.81420 16.24890 15.68360
Summer Off-Peak 5.65330 1.76820 4.52260 3.95730 3.39200
Non-Summer 4.83650 0.95400 3.86920 3.38560 2.90190
Annual' 5.96030 2.45850 5.3083 4 4.79140 4.27450
Staff Comments at 10.
While SCNS is correct in their assessment that the Commission did not apply the 40%cap
symmetrically, their understanding of the Commission's reasoning is flawed. Staff s
recommendation to place a symmetrical cap (either upward or downward) was given under the
assumption that the ECR would continue to be updated annually. Instead, the Commission found
it reasonable to suspend the annual update requirement of Order No. 36048 until April 1, 2028,
with the understanding (based on public comments in the record) that non-legacy on-site
generation customers needed time to adjust to the annual update portion of the ECR and to provide
potential on-site generation customers time to review their investment decisions. Order No. 36785
at 24. With the Company maintaining the ECR at the mitigated rates set by Order No. 36785 until
April 1,2028,there was no reason to apply the mitigation symmetrically. Further,the Commission
ORDER NO. 36848 8

ordered the Company's next filing to be in compliance with Order No. 36048,therefore lifting the
mitigation measures and making symmetrical mitigation unnecessary.
For these reasons, the Petitions for reconsideration are denied.
ORDER
IT IS HEREBY ORDERED that the Petitions for Reconsideration are denied.
THIS IS A FINAL ORDER. Any party aggrieved by this Order or other final or
interlocutory Orders previously issued in this case may appeal to the Supreme Court of Idaho under
the Public Utilities Law and the Idaho Appellate Rules.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 17th day of
November 2025.
YRD
DGE, RE I ENT
HN R. HAMMOND JR., COMMISSIONER
DAYN HARDI , COMMISSIONER
ATTEST:
La Calderon Robles
Interim Commission Secretary
I ALegahELECTRICUPC-E-25-15_EMordersUPCE2515_Recon_em.docx
ORDER NO. 36848 9