20251209Staff Comments.pdf

RECEIVED
December 09, 2025
ADAM TRIPLETT IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 10221
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION TO ) CASE NO. IPC-E-25-34
IMPLEMENT THE RESIDENTIAL AND )
SMALL FARM CREDIT RATE EFFECTIVE )
JANUARY 1, 2026, THROUGH DECEMBER ) COMMENTS OF THE
311, 2028 ) COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Adam Triplett, Deputy Attorney General,
submits the following comments.
BACKGROUND
On November 7, 2025, Idaho Power Company ("Company") applied for authorization to
implement the Bonneville Power Administration's ("BPA")residential and small farm energy
rate credit from January 1, 2026, through December 31, 2028. The Company's proposed rate
credit would result in a $19,888,200 decrease in credits compared with those currently applied to
eligible Idaho customers' bills. The Company requested an effective date of January 1, 2026.
The residential and small farm energy rate credit results from the Company's agreement
with BPA regarding the Residential Exchange Program ("REP"). The BPA administers the REP.
The REP allows participating utilities to pass the benefits of the low-cost Federal Columbia
River Power System to eligible residential, small farm, and irrigation customers through credits
on their power bills. The Company and BPA are parties to a Settlement Implementation
STAFF COMMENTS 1 DECEMBER 9, 2025

Agreement for the REP. Through this agreement the Company passes REP benefits on to its
eligible customers.
STAFF ANALYSIS
Staff reviewed the Company's Application and the BPA Fiscal Year("FY") 2026-2028
Final Average System Cost Report, audited the initial inputs, and independently recalculated the
rate. The Company correctly calculated the rate of$0.000305 per kilowatt-hour("kWh")based
on an Idaho jurisdictional annual allocation of REP benefits of$3,014,809 million annually.
Staff recommends the Commission approve the proposed Electric Service Schedule 98 -
Residential and Farm Energy Credit ("Schedule 98") as filed.
The current Schedule 98 rate is $0.003447 per kWh. This credit was established in 2023
based on an annual BPA REP credit of$22.9 million to eligible Idaho customers through a credit
to their energy rates for two years beginning January 1, 2024. The Company proposes
implementing a new rate credit of$0.000305 per kWh, representing Idaho's portion of benefits
from the BPA REP. Residential and small farm customers will be eligible to receive $3,014,809
annually on a system basis for calendar years 2026 through 2028. This annual amount is a
$19,888,200 decrease per year from the 2024-2025 exchange period.
Average System Cost
The REP benefits are allocated to the utilities based upon each utility's Average System
Cost("ASC") in comparison to BPA's Priority Firm ("PF") Exchange Rate and upon a two-year
average of the utility's historic eligible residential and small farm loads. A utility's ASC and the
resulting benefits are determined through an ASC filing and review process administered by
BPA and conducted every two years. BPA issued the FY 2026-2028 (October 2025 through
September 2028) final ASC report for Idaho Power in July 2025. The Company's ASC for FY
2026-2028 is $60.47 per megawatt-hour("MWh"). The Company's ASC exceeds BPA's PF
Exchange Rate of$60.07 per MWh by $0.40 per MWh. This $0.40 per MWh difference results
in an annual benefit of$3,014,809 on a system basis for the FY 2026-2028 exchange period, a
decrease of$19,888,200 per year from the FY 2024-2025 exchange period.
STAFF COMMENTS 2 DECEMBER 9, 2025

Rate Design
The Company will continue to pass through the benefit amount on a uniform cents per
kWh basis to all qualifying electric energy delivered to Idaho customers taking service under
Schedules 1, 3, 5, 6, 7, 8, 9, 15, and 24. The Company will pass the benefits through at the new
credit rate every month for qualifying residential and small farm electricity consumption
beginning January 1, 2026. Qualifying irrigation consumption will continue to be accrued
monthly and passed through to irrigation customers each December, concurrent with the
Company's annual Idaho kWh and property tax rebate program. The irrigation benefits
distributed each December correspond to a prior 12-month period ending September 30.
Monthly benefits for qualifying irrigation customers are limited to each customer's actual
monthly energy consumption or 222,000 kWh, whichever is less.
CUSTOMER NOTICE AND PUBLIC COMMENTS
The Company proposes to notify customers via bill message in compliance with Rule
125, IDAPA 31.01.01.125.02 after receiving the Commission's approval. As of December 9,
2025, the Commission has received no comments from customers.
STAFF RECOMMENDATION
Staff recommends that the Commission approve Schedule 98 as filed, providing
customers a credit of$0.000305 per kWh for rate schedules 1, 3, 5, 6, 7, 8, 9, 15, and 24
effective January 1, 2026, through December 31, 2028.
Respectfully submitted this 9th day of December 2025.
L/�— :/�t /� —7
Adam Triplett
Deputy Attorney General
Technical Staff. Ty Johnson
I:\Utility\UMISC\COMMENTS\IPC-E-25-34 Comments.docx
STAFF COMMENTS 3 DECEMBER 9, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 91h DAY OF DECEMBER 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-25-34, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
Idaho Power Company:
LISA C. LANCE, COUNSEL
GRANT T. ANDERSON, PRICING AND TARIFF MGR.
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707
E-MAIL:
llance&idahopower.com
dockets(d,idahopower.com
ganderson&idahopower.com
aapperson(d),idahopower.com
PATRICIA JORDAA, SECRETARY
CERTIFICATE OF SERVICE