20251118Comments.pdf

RECEIVED
Benjamin J. Otto, ISB No. 8292 November 18, 2025
1407 W Cottonwood Crt. IDAHO PUBLIC
Boise,Idaho 83702 UTILITIES COMMISSION
Telephone: [phone]
[e-mail]
Attorney for the Northwest Energy Coalition
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO.IPC-E-25-16
APPLICATION OF IDAHO POWER )
COMPANY FOR AUTHORITY TO ) STATEMENT OF POSITION
INCREASE ITS RATES AND CHARGES )
FOR ELECTRIC SERVICE IN THE ) THE NORTHWEST ENERGY
STATE OF IDAHO. ) COALITION
The Northwest Energy Coalition ("NWEC") submits this Motion to accept this Statement of
Position supporting the proposed settlement in this docket. The Idaho Public Utilities Commission
Rules of Procedure 255 allows "in any proceeding, any party may move to file . . . statements of
position."IDAPA 31.01.01.255. The Commission granted NWEC motion to intervene in this docket
in Order No 36691. Accepting this motion is appropriate because NWEC is not asserting any facts
beyond those reflected in the settlement documents and no party to the docket is opposing the
resolution of the issues. As described more fully below: NWEC relies on policy arguments to
support the proposed settlement as a reasonable resolution of the issues, aligned with Idaho law and
policy, and in the public interest. To conserve scares resources and facilitate a timely resolution of
this matter,NWEC hereby moves the Commission to accept this Statement of Position in lieu of
filing witness testimony.
Statement of Position
With members in Idaho Power's service territory,NWEC is concerned about any rate
increase, especially considering rising costs all around us. We intervened in this docket to determine
a fair and reasonable balance of controlling rate increases while recognizing the need to maintaining
the aging electric system, harden the grid to address growing wildfire and extreme weather threats,
and address growth, both by current customers and especially new customers. NWEC reviewed the
testimony, the production responses relevant to our issues, and actively engaged in the settlement
negotiations that led to the proposed settlement. As a package, the proposed settlement is a
NWEC Motion and Statement of Position page 1
IPC-E-25-16

reasonable balance of providing Idaho Power an opportunity to recover its prudent expenses while
providing customers the ability to manage bills through personal choices.
The Settlement includes important provisions that benefit the public interest and are primary
issues for NWEC. The total revenue requirement is $89 million less than Idaho Power initially
sought. NWEC views the capital investments and operational costs comprising this revenue
requirement as a fair and reasonable outcome to support reliable and affordable service for
customers. The agreed to rate of return is aligned with the financial metrics and risk profile of the
Company and should support access to financing on reasonable terms. NWEC engaged extensively
in negotiations regarding the cost-of-service methodology and we agree the proposed resolution in
this case is a reasonable settlement of this complex issue that mixes accounting principles with
policy considerations. We align with the other settlement signatories on these aspects of the
settlement.
One area of specific concern for NWEC is residential rate design and the agreement to
maintain the fixed charge at current levels is an essential part of our support. Maintaining the
residential fixed charge at the current level is in the public interest because a design that collects
costs through the volumetric rate empowers individual customers to control their energy bills
through their personal energy choices. High fixed charges limit this ability and instead assume equal
fixed costs for a class of customers with an immense level of difference in fixed cost causation. A
simple example is the difference between homes in dense urban areas, where fixed infrastructure is
shared across many users, compared to homes in remote locations that require more fixed assets to
provide the same service. Combined with the Fixed Cost Adjustment, this package of rate design and
cost tracking appropriately balances the interest of Idaho Power to have an opportunity to recover its
costs with the interests of individual customers to control their own energy bills through their
choices. This design also recognizes the reality that not all residential customers cause the same
amount of fixed costs on the system.
A second important issue for NWEC is the cost-of-service methodology used to both
calculate class revenue requirements and provide a basis for rate design. Cost-of-service goes
beyond pure accounting because it requires important policy consideration about how to assign costs
to different utility functions and assess what functions and which customers are causing costs on the
system. There is no single approach or method that captures this complexity, as reflected by the
various cost-of-service methods this Commission has approved over the years and among Idaho's
utilities. Considering this spectrum of choices,using the cost-of-service information available in this
NWEC Motion and Statement of Position page 2
IPC-E-25-16

docket as a starting point upon which to base the specific resolution in this case is reasonable.
Looking forward,NWEC strongly supports the term in the settlement establishing a process to
review cost of service methodologies for future consideration.
Another forward-looking issue is how to address the dynamic we see all around Idaho—
growing populations and growing businesses driving the need for additional energy infrastructure.
NWEC supports the general notion that the cost causer should pay, but applying this general
principle to specific costs is difficult in the current paradigm of using largely historical data to set
future rates. NWEC supports the settlement term to explore test year methodologies in a workshop.
This term serves the public interest by providing a forum to assess opportunities to address the
source of future costs increases.
Finally, the public has a strong interest in ensuring clean air and a stable climate. The terms
related to the Bridger and Valmy coal plants are a reasonable path to continue the transition away
from coal generation. Meanwhile, the revenue requirement terms to support new solar and battery
facilities will ensure customers enjoy adequate,reliable, and affordable energy services.
Again,NWEC recognizes that rate increases are hard for customers, especially as other costs
continue to escalate. Supporting a rate increase is no small matter. As a package, and in the spirit of
collaboration,NWEC finds proposed settlement strikes an appropriate balance by mitigating the rate
increase and enabling customers to control bills through personal choices. We recommend the
Commission approve the proposed settlement as a reasonable resolution the issues and in the public
interest.
WHEREFORE,NWEC respectfully requests that the Commission accept this Motion and consider
the above Statement of Position. NWEC counsel will attend the technical hearing in this matter and
stands ready to provide any further information that would assist the Commission's decision making.
Respectfully submitted this 18th day of November 2025, by
Benjamin J. Otto
ISB No 8292
Attorney for NWEC
NWEC Motion and Statement of Position page 3
IPC-E-25-16

CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of November 2025, I delivered true and correct copies of the
foregoing MOTION AND STATEMENT OF POSITION of NWEC in IPUC Docket No. IPC-E-25-
16 to the following persons according to Rule 61.03 via electronic mail only.
Benjamin J. Otto
ISB No 8292
Attorney for NWEC
Idaho Public Utilities Commission Idaho Irrigation Pumpers Association Eric L.
Monica Barros-Sanchez Olsen
Commission Secretary Lance Kaufman
[e-mail] [e-mail] [e-mail]
Idaho Public Utilities Commission Federal Executive Agencies
Staff Emily W. Medlyn
Chris Burdin Jelani A.Freeman
Deputy Attorney General U.S Department of Energy
[e-mail]
Dwight Etheridge
Idaho Power Company Exeter Associates, Inc.
Donovan E. Walker [e-mail]
Megan Goicoechea Allen [e-mail]
Timothy Tatum [e-mail]
Connie Aschenbrenner
Matt Larkin Clean Energy Opportunities for Idaho
[e-mail] Kelsey Jae
[e-mail] Courtney White
[e-mail] Mike Heckler
[e-mail] [e-mail]
[e-mail] [e-mail]
[e-mail] [e-mail]
City of Boise Industrial Customers of Idaho Power
Ed Jewell, Deputy City Attorney Peter J. Richardson
Boise City Attorney's Office Richardson Adams, PLCC
Katie O'Neil, Energy Program Manager [e-mail]
City of Boise
[e-mail] Micron Technology,Inc
[e-mail] Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
NWEC Motion and Statement of Position page 4
IPC-E-25-16

Kristine A.K. Roach
Holland&Hart, LLP
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
IdaHydro
Tom Arkoosh
Erin Cecil
Arkoosh Law Offices
[e-mail]
[e-mail]
Kroger
Kurt J. Boehm
Jody Kyler Cohn
Boehem, Kurtz, & Lowry
[e-mail]
[e-mail]
Gannon et.al
John Gannon
Ready Morris
Deborah Fease and Amy Torrance
[e-mail]
[e-mail]
[e-mail]
NWEC Motion and Statement of Position page 5
IPC-E-25-16