20251210Supplemental Comment - Redacted.pdf

RECEIVED
DECEMBER 10, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
C. Tom Arkoosh, ISB No. 2253
Nicholas J. Erekson,ISB No. 9325
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
Telephone: [phone]
Facsimile: [phone]
Email: tom.arkooshkarkoosh.com
nick.erekson(a,arkoo sh.com
Admin copy: erin.cecil&arkoosh.com
Attorneys for IdaHydro
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) Case No. IPC-E-25-22
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO UPDATE ITS ) SUPPLEMENTAL COMMENT OF
OPERATION AND MAINTENANCE ) IDAHYDRO
CHARGES APPLICABLE TO SCHEDULE )
72, GENERATOR INTERCONNECTIONS )
TO PURPA QUALIFYING FACILITY )
SELLERS. )
COMES NOW the Idaho Hydroelectric Power Producers Trust, an Idaho Trust, d/b/a
IdaHydro ("IdaHydro"), by and through its counsel of record, C. Tom Arkoosh and Nicholas J.
Erekson of Arkoosh Law Offices, and pursuant to the Amended Notice of Modified Procedure,
Order No. 36833, entered on November 6, 2025, hereby submits the following Supplemental
Comment of IdaHydro:
I. BACKGROUND
Under normal operations (without a PURPA Qualifying Facility ("QF")), Idaho Power
Company ("Idaho Power" or the "Company") would simply bear the operations and maintenance
costs ("O&M") of maintaining its own interconnection facilities. Such O&M is just part of being
a utility. Idaho Power now claims, however, that PURPA changes this equation because the
Commission's avoided-cost modeling builds the utility's own interconnection O&M into the rate
it pays the QF. In other words, Idaho Power's theory is that it has already paid the QF for the
interconnection O&M that the utility would otherwise incur, and this payment relieves Idaho
Power from having to cover the costs of actual maintenance going forward. Idaho Power then uses
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 1

Schedule 72 as the tool to shift that cost back onto the QF by charging the QF the very same
category of O&M that Idaho Power says it already embedded in the avoided-cost rate.
The problem is that Idaho Power does not know how much of the avoided-cost rate
supposedly represents interconnection O&M, and it does not know how much it actually spends
to maintain interconnection facilities. It is trying to claw back an unknown-sized slice of an
unknown-sized pie. Idaho Power cannot identify the portion of avoided costs it is "recapturing,"
nor can it identify the underlying expense it is allegedly offsetting.
II. SUMMARY OF COMMENT
Idaho Power seeks approval of a Schedule 72 methodology that is fundamentally
inconsistent with federal law. It is built on assumptions Idaho Power cannot verify and costs Idaho
Power cannot identify. The Company cannot say what interconnection O&M it has purportedly
embedded in avoided-cost payments (Delgado Dep. 16:1-19:17) and cannot say what
interconnection O&M costs it actually incurs because Idaho Power chooses not to track them.
(Maloney Dep. 19:11-23; 35:3-16, 22-24). Without either figure, Idaho Power cannot make the
showing PURPA requires,which is that any Schedule 72 charge reflects only the incremental costs
"in excess of what the utility would have spent in its normal operations. (18 C.F.R. §§
292.101(b)(7))
Rather, the Company's proposed tariff relies on a proportionality formula that it has never
validated,never audited, and never compared to actual experience (Maloney Dep. 35:3-16, 20-24;
Sloan Dep. 22:12-23:7). Idaho Power concedes that it does not know whether its model over-
collects, under-collects, or is accurate. (Maloney Dep. 35:3-25, 37:1-5; Sloan Dep. 22:12-23:7,
27:5-17).1
However, PURPA does not tolerate that kind of guesswork. Nor should this Commission.
Idaho Power's Schedule 72 theory is the regulatory equivalent of a contractor who refuses to keep
receipts, guesses at what the job might have cost, and then sends a second invoice labeled"extra"
without ever showing there was a first one. He insists he already credited the customer some
undefined amount, claims the new bill is only for the "excess," and when asked how he knows,
shrugs and points to a spreadsheet that never once separates labor from materials. No court would
'As discussed on the record at the October 28, 2025,hearing,there is a difference between precision and accuracy.
The Company's avoided-cost modeling is complex and precise,but is in no way accurate.
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 2

tolerate that as proof of an overrun. Neither does PURPA allow the parties and the Commission to
pretend it is good enough, simply because the overrun is dressed up as a Schedule 72 tariff.
A utility may recover only its incremental "excess" interconnection costs, nothing more.
But a utility that does not know either the avoided interconnection cost or the actual
interconnection cost cannot demonstrate compliance with that standard.
III. COMMENT
Idaho Power's proposal attempts to substitute convenience for accuracy and modeling for
measurement. However, a methodology based on untested averages cannot satisfy PURPA
requirements. A record devoid of actual O&M cost information cannot support approval. And a
tariff that risks systematic over-recovery (or under-recovery) cannot stand.
A. Idaho Power Cannot Identify or Quantify Interconnection O&M Embedded in
Avoided-Cost Payments
The record demonstrates that Idaho Power cannot identify, quantify, or verify any
interconnection-specific O&M embedded in the avoided-cost rates. (Delgado Dep. 13:21-14:12;
14:21-15:11; 17:12-25). The Company cannot identify a single place in the Surrogate Avoided
Resource ("SAR") or Incremental Cost Integrated Resource Plan ("ICIRP") models where
interconnection O&M is isolated or quantified. (Id.) Although the Company now asserts (after
initially stating the opposite)Z that QFs "already receive" avoided interconnection O&M through
the SAR and ICIRP proxy-resource methodologies,Idaho Power's own witnesses testified that the
avoided-cost model used by the Commission does not allow them to isolate interconnection O&M
at any level of detail. (Id.) Rather, the avoided-cost framework lumps all O&M into broad proxy-
resource categories and provides no breakout for interconnection facilities at all. (Id.)
Dr.Delgado confirmed that the avoided-cost framework incorporates only broad categories
of fixed and variable O&M for proxy gas generators, with no breakout for interconnection
facilities, and that he could not point to any avoided O&M attributable to PURPA interconnections
within those rates (Id.) Idaho Power, therefore, cannot locate or quantify any interconnection-
related O&M that is supposedly included in avoided-cost payments. In other words, Idaho Power
has no basis whatsoever for claiming QFs have prepaid any particular level of costs.
2 Idaho Power's initial response to Interrogatory No. 8 stated that interconnection O&M was not included in the
avoided-cost calculation. The Company later reversed course in a supplemental response, asserting the opposite.
Because IdaHydro's original comments were based on the Company's initial position,this supplemental comment is
necessary to address the implications of Idaho Power's changed testimony.
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 3

The Company admitted it conducted no independent analysis, no study, or quantitative
work of its own to support the claim that avoided-cost rates prepay interconnection O&M(Delgado
Dep. 23:2-15). There is no evidence showing how much interconnection O&M is embedded in
avoided-cost rates,what assumptions underlie that amount, or whether the level of assumed O&M
for the gas-turbine proxy has any relationship to the O&M that Idaho Power actually performs on
Schedule 72 facilities. Idaho Power admits it lacks the ability to compare avoided O&M to actual
O&M, or avoided O&M to the proposed Schedule 72 charges, because it has no avoided-cost
breakout(Id.; 15:17-18, "...If you don't have the breakdown,you cannot compare them.") and no
record of actual interconnection O&M(Delgado Dep. 17:12-19:22;23:2-15).Ms. Sloan confirmed
that Idaho Power does not track interconnection O&M per facility at all, no work orders, no
accounts, and has no current ability to extract interconnection-specific O&M from its current
accounting system(Sloan Dep.23:1-22).3 Without such information,Idaho Power has not assessed
whether avoided-cost rates already include too much, too little, or anything at all in
interconnection-specific O&M:
Q: ...we don't know whether the amount under Schedule 72 is greater than the
amount that was included under the avoided cost modeling or whether it's less than;
correct?
A. Correct.
(Delgado Dep. 19:11-15)
It follows that Idaho Power cannot demonstrate that the proposed Schedule 72 charges
recover only"excess"O&M as required by PURPA.Therefore,the Commission has no evidentiary
basis to prevent double-recovery,under-recovery, or ensure compliance with federal law.
Idaho Power is blind on both sides of the PURPA equation: it does not know what, if
anything, is embedded in avoided-cost payments, and it does not know what it actually spends.
A utility that cannot answer either question cannot possibly demonstrate that its tariff recovers only
"excess"costs,and the Commission cannot prevent double-recovery or under-recovery on a record
this empty.
3 She did admit,however,that the accounting system could be changed to account for actual interconnections O&M
(Sloan Dep.23:18-22,"We would have to implement a new system to do so.").
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 4

B. Idaho Power Cannot Identify or Quantify the Actual Interconnection O&M It
Seeks to Recover Under Schedule 72
The Company openly admits it does not track interconnection O&M in any meaningful
way: no asset-level work orders, no cost codes, no accounting mechanism that distinguishes
interconnection maintenance from general system operations (Sloan Dep. 23:1-22, Maloney Dep.
19:11-23). Once a QF interconnection is built, it disappears into Idaho Power's system-wide
accounting pool, apparently making it impossible for the Company to know what it historically
spent on individual facilities. (Id.)
Mr. Maloney acknowledged this directly: Idaho Power does not differentiate
interconnection O&M from anything else. (Maloney Dep. 19:11-12, "So we do not differentiate
interconnection O&M to system O&M, it's all one in the same. ') Ms. Sloan confirmed it: the
Company's chosen accounting system does not segregate O&M by facility; all costs are aggregated
across entire regions or functional groups under the accounting method chosen by Idaho Power.
(Sloan Dep. 23:9-11; 26:3-6.) In other words, Idaho Power is attempting to charge QFs for a
category of cost it chooses not to even measure.
Instead of relying on actual cost, Idaho Power applies a system-wide O&M-to-plant ratio
(approximately 20%)to interconnection facilities (Maloney Dep. 15:3-11; 15:17-16:5). This is not
excess cost allocation by QF causation; it is cost allocation by assumption. Idaho Power applies
the same ratio to all transmission equipment, regardless of function, complexity, or maintenance
profile. (Sloan Dep. 8:10-20; Maloney Dep. 15:3-16). It has never validated this ratio. (Maloney
Dep. 35:3-24). It has never compared it to real interconnection maintenance experience. (Id.) It
has never even checked whether the ratio produces results remotely consistent with actual O&M.
(Id.;see also Sloan Dep. 27:4-17). Idaho Power simply assumes proportionality and then builds a
tariff on that assumption.
The Company's testimony makes clear that Idaho Power does not know whether this model
over-collects or under-collects O&M (Maloney Dep. 35:3-24, Sloan Dep. 27:4-17). Idaho Power
has no idea whether its Schedule 72 charge over-collects or under-collects O&M because it has no
actual O&M data to test the model against. On this record, even Idaho Power cannot say whether
its own tariff is too high, too low, or anywhere near accurate. (Id.)
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 5

PURPA requires the recovery of incremental interconnection O&M,not whatever number
happens to fall out of a system-wide average. Idaho Power's inability to quantify the actual O&M
it seeks to charge makes its entire Schedule 72 proposal structurally and legally unsound.
C. Idaho Power Admits It Could Track Interconnection O&M If Directed, But Has
Chosen Not To
Idaho Power's testimony makes clear that the Company is not incapable of tracking
interconnection O&M, it simply has not done so. The FERC Uniform System of Accounts
expressly permits plant-specific operating and maintenance records, and Idaho Power's own
accounting witness, Ms. Sloan, acknowledged that such tracking is allowed and consistent with
FERC practice (Sloan Dep. 25:1-26:10 and Ex. 5). Nothing in the regulatory framework prevents
Idaho Power from assigning work orders,recording maintenance at the facility level, or capturing
interconnection-specific O&M. The obstacle is not legal; it is internal. Idaho Power elected to
adopt an accounting system that aggregates O&M across broad functional groups, even though it
could track actual O&M for each interconnection if it chose to do so (Sloan Dep. 25:13-26:6).
Idaho Power further conceded that if the Commission directed facility-level O&M tracking, the
Company would implement the changes necessary to comply:
Q: And if the PUC, whose employees are sitting here in the room today, directs
Idaho Power to do a certain thing, they'll do it.
A: We should figure out a way to do it.
(Sloan Dep. 17:3-6).
The testimony is unambiguous:the Company has the ability to track interconnection O&M,
and the only reason it does not is because its current system was not designed for that purpose
Indeed, Idaho Power acknowledged that its work-order structure could be modified to isolate
interconnection O&M,but it has not taken steps to do so(Sloan Dep. 23:16-23, "...We would have
to implement a new system to do so.")
This is not a situation where the data is impossible to obtain. The absence of
interconnection O&M information is entirely self-created. Idaho Power built a system that does
not measure the cost it now seeks to recover, and having chosen not to gather the data, it asks the
Commission to approve a tariff based solely on untested assumptions.A utility cannot decline to
track the relevant cost and then rely on its own lack of information as justification for an O&M
charge. If Idaho Power wants to recover actual incremental O&M, as PURPA requires, then the
Company must measure it. Until it does, the Commission cannot rely on Idaho Power's
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 6

proportionality model,because the Company itself has never compared it to real-world experience.
The cure is straightforward: Idaho Power should be directed to track actual interconnection O&M.
Unless and until that occurs,the Company cannot carry its burden to demonstrate that the proposed
Schedule 72 recovers only incremental costs.
D. Because Idaho Power Does Not Identify Either Avoided Interconnection O&M or
Actual Interconnection O&M, the Commission Cannot Determine Whether
Schedule 72 Recovers Only "Excess" Costs as PURPA Requires
PURPA sets a clear constraint: a utility may recover only those interconnection O&M costs
that are"in excess of the O&M it would have incurred absent the QF.That standard is not optional,
flexible, or advisory. It is the legal line Idaho Power must meet before imposing any O&M charge
on a QF. To apply that standard, the Commission must know two things: (1)what interconnection
O&M the Company already avoids and (2) what interconnection O&M the Company actually
incurs. Idaho Power cannot provide either.Without a baseline cost,the concept of"excess"has no
meaning, because there is no factual point of comparison. The Company is effectively asking the
Commission to calculate an incremental cost without any increment and without any cost.
The Commission also has no ability to determine whether Schedule 72 charges O&M in
excess of that embedded in avoided-cost payments. Idaho Power cannot identify a single dollar of
avoided interconnection O&M within its SAR or ICIRP models. It does not know whether QFs
are already paying too much, too little, or anything at all for interconnection O&M. Without that
information,the Commission cannot ensure QFs are not being charged twice for the same category
of expense or undercharged in a way that distorts avoided-cost accuracy. The absence of this data
makes regulatory compliance a matter of guesswork, not calculation.
Nor can the Commission determine whether Schedule 72 exceeds the actual O&M Idaho
Power incurs on QF interconnections. Idaho Power lacks actual interconnection O&M data
entirely. It does not record it, does not track it, and has never measured it. There is no evidentiary
foundation upon which the Commission can determine whether the proposed tariff bears any
relationship to the real maintenance costs of Schedule 72 facilities. Without actual cost
information, Idaho Power's proportionality model cannot be validated, tested, or trusted.
That leaves a final and fatal gap: the Commission cannot perform the comparison that
PURPA requires. PURPA demands a two-sided analysis, avoided O&M versus incremental O&M,
to determine whether the utility's charges reflect only"excess"costs. Idaho Power cannot produce
the avoided O&M. It cannot produce the actual incremental O&M. Lacking both sides of the
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 7

equation, Idaho Power cannot demonstrate compliance, and the Commission cannot make the
findings necessary to approve the proposed methodology.
A tariff that cannot be tested against the legal standard cannot be approved. Idaho Power's
failure to identify either avoided interconnection O&M or actual interconnection O&M leaves the
Commission with no lawful basis to authorize Schedule 72 as proposed.
E. Customers Are Not Indifferent Under Current Modeling
Idaho Power repeatedly states that Schedule 72 is intended to keep customers"indifferent"
to the addition of PURPA QFs,but the Company's own testimony shows that the current modeling
does not, and cannot, achieve that result.
Idaho Power's testimony reveals that the current model insulates the Company from over
or under collection risk and places all variance on customers. Dr. Delgado candidly acknowledged
that any over-collection or under-collection is a pass-through item in the general rate case(Delgado
Dep. 24:11-21),meaning that customers,not the Company,bear the consequences. (See also Sloan
Dep. 37:8-16, acknowledging that the collected interconnection O&M is allocated to retail
customers).
When a utility faces no risk of inaccurate cost recovery, there is no operational incentive
to ensure accuracy, track actuals, or improve the model. Yet customer indifference requires far
more than this risk-free allocation approach.
Customer indifference requires a demonstration that the O&M charged to QFs equals only
those incremental interconnection costs that would not have existed"but for"the QF. Idaho Power
cannot make that showing. It does not know what interconnection O&M it pays through avoided-
cost modeling, nor does it know what interconnection O&M it actually incurs. Because both sides
of the PURPA excess-cost equation are unknown, there is no basis for concluding that customers
are indifferent.
As discussed supra,Idaho Power has no evidence that the avoided-cost rates it pays to QFs
correctly reflect the interconnection O&M the utility allegedly would have incurred on its own.
If Idaho Power cannot identify the avoided portion of interconnection O&M,it cannot demonstrate
that customers have been held harmless. Likewise,Idaho Power has no evidence that the Schedule
72 charges it seeks from QFs correspond to its actual incremental interconnection O&M. Without
actual cost data, Idaho Power cannot say whether Schedule 72 charges exceed,match, or fall short
of real O&M. Customer indifference cannot be shown when the underlying cost is unknown.
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 8

Idaho Power does not validate its proportionality model against reality and, therefore,
cannot demonstrate that ratepayers are insulated from QF-related costs. The Company's
systemwide O&M-to-plant ratio is applied to interconnection facilities without any evidence that
the maintenance burden of a simple four-pole QF interconnection bears any proportional
relationship to the maintenance burden of Idaho Power's entire transmission system. Mr. Maloney
conceded that the proportionality assumption has never been tested or compared to actual
interconnection O&M (Maloney Dep. 19:11-23; 35:3-24). Ms. Sloan confirmed that Idaho Power
cannot determine whether the resulting Schedule 72 charge over- or under-collects the relevant
O&M (Sloan Dep. 27:11-17). Because the model has not been validated, its outputs cannot
establish customer indifference.
In short, Idaho Power cannot show that customers are indifferent under its current
methodology because it cannot identify the O&M avoided, the O&M incurred, or the accuracy of
the mechanism connecting the two. Customer indifference is not a presumption; it is a factual
demonstration. Idaho Power has provided no evidence necessary to make that showing.
F. QFs Are Overcharged Under Current Modeling
The record demonstrates that Idaho Power's current Schedule 72 methodology not only
risks over-recovery but also systematically produces it. The testimony of Idaho Power's own
accounting and regulatory witnesses, combined with the undisputed figures from the 2023 general
rate case discovery,confirms that QFs are paying far more in interconnection O&M than the utility
can justify under PURPA or even under its own assumptions.
1. The Company's historical collections show extreme over-recovery, up to .
times the cost of the interconnection.
In the 2023 general rate case discovery, Idaho Power produced . years of O&M
assessments collected from QFs. When aggregated, those assessments materially exceeded the
total original construction cost of the interconnections. In Ms. Sloan's deposition, she confirmed
that across all facilities listed in Exhibit 4, Idaho Power collected- more than the total
cost of building the interconnection facilities over a period, though she
declined to comment on whether this amount was reasonable(Sloan Dep. 22:3-9, 12-22, 34:7-23).
In effect,Idaho Power recovered enough O&M to rebuild the entire set of interconnection facilities
every years, even though the Company admits the useful life of those facilities is
approximately 36 years (Sloan Dep. 32:9-19).
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 9

There is no plausible cost-causation theory under which a utility incurs O&M sufficient to
replace the entire asset. separate times during its useful life. This is not maintenance; it is
confiscation.As discussed supra, Idaho Power has never compared the amounts it collects to any
record of actual O&M. In other words, the Company has built a method that floats free of its own
operational reality, and QFs bear the cost of that detachment.
2. The over-recovery is structural, not incidental
The Company's proportionality model assigns O&M based solely on each
interconnection's share of system capital, not on maintenance activity, condition, age,
configuration, or real-world cost drivers (the only difference in treatment is whether the facility is
for distribution or transmission). That ratio (roughly 20%) is applied uniformly without testing or
calibration. The Company's own testimony demonstrates:
a) The proportionality factor is not derived from interconnection maintenance,but
from the whole system. (Maloney Dep. 15:3-16).
b) The Company has never checked whether it matches actual field conditions
(Maloney Dep. 35:3-24).
c) There is no evidence that interconnections bear the same maintenance profile
as system-wide transmission and distribution plant, rather, this is just assumed
(Maloney Dep. 32:5-34:5).
This creates an inherent inflation: interconnections, which are small, limited-scope
facilities, are being charged as though they require the same maintenance intensity as Idaho
Power's full transmission and distribution system, which is orders of magnitude larger and more
complex.
3. Third-Party Comments Corroborate the Magnitude of the Overcharge
Mr. Sorenson and Mr. Farr independently analyzed the same data provided in discovery
and reached the same conclusion: Idaho Power's Schedule 72 mechanism produces O&M charges
vastly disproportionate to any reasonable maintenance expectation and bears no resemblance to
actual maintenance needs.Their comments detail instances where QFs have been charged amounts
that would replace their entire interconnection multiple times over, and where Idaho Power's
proportionality model generates inflated results untethered to any verifiable cost.
This is not a theoretical harm. It is occurring now, under the current tariff, on the basis of
numbers Idaho Power admits it cannot validate.
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 10

A tariff that produces O&M collections equal to■full rebuilds of the asset during one
useful life is not a PURPA-compliant tariff. It is an unlawful over-recovery mechanism.
IV. CONCLUSION
Idaho Power asks the Commission to approve a Schedule 72 methodology without
knowing what interconnection O&M it has already embedded in avoided-cost payments and
without knowing what interconnection O&M it actually incurs.A utility that cannot identify either
side of the PURPA "excess" equation cannot prove incremental cost recovery. Idaho Power's
proposal rests on assumptions, averages, and unverified proportionality factors rather than
evidence, measurement, or cost causation. Until the Company tracks its actual interconnection
O&M and identifies the interconnection O&M it claims to have already paid through avoided-cost
rates, the Commission cannot determine whether any portion of the proposed Schedule 72 charge
represents a lawful "excess" under PURPA. IdaHydro respectfully submits that the Commission
should not approve a tariff built on unknowns. Idaho Power must first produce the data necessary
to show what it spends,what it pays, and whether any true excess exists.
Idaho Power's own theory is that its avoided-cost methodology already includes the
interconnection O&M the utility would have incurred absent the QF. If that is true, Idaho Power
may charge QFs only the portion of actual, demonstrated interconnection O&M that does not
exceed the amount it claims to have prepaid through avoided-cost rates. Any attempt to recover
more than that for normal O&M would constitute an impermissible clawback and violate PURPA's
"excess cost" standard. The Commission should therefore require Idaho Power to establish:
(1)the actual interconnection O&M it incurs and(2)the amount of interconnection O&M it asserts
is embedded in avoided-cost payments,and limit any Schedule 72 charge to the lesser of those two
figures.4
V. REQUESTED RELIEF
In light of the evidentiary gaps and structural flaws in Idaho Power's proposal, IdaHydro
respectfully requests that the Commission decline to approve the Schedule 72 methodology on the
current record and order the following corrective steps:
4 Until the Commission can delineate what portion of the avoided-cost rate paid to the QFs represents interconnection
O&M,IdaHydro would consent to simply using actual costs incurred by Idaho Power to maintain the interconnection
facility.In a future case,it is anticipated that the Commission could make findings with respect to quantifying avoided
interconnection costs prepaid.
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 11

1. Reject Idaho Power's proportional O&M methodology because it is not tied to the
PURPA excess-cost standard.
2. Require Idaho Power to track actual interconnection O&M on a facility-specific basis
consistent with the FERC Uniform System of Accounts.
3. Require Idaho Power to identify and quantify any interconnection O&M it purports to
be embedded in the avoided-cost rates it pays.
4. Require Idaho Power to justify any Schedule 72 O&M charge as a true "excess"under
PURPA
5. Require Idaho Power to charge QFs the actual interconnection O&M as accrued as
shown by discrete billing and invoicing
DATED this 1 Oth day of December 2025.
ARKOOSH LAW OFFICES
Nicholas J. rekson
Attorneys for IdaHydro
SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 12

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the loth day of December 2025, I served a true and
correct copy of the foregoing document(s) upon the following person(s), in the manner indicated:
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SUPPLEMENTAL COMMENT OF IDAHYDRO-Page 14