20251212Staff Comments.pdf

JEFFREY R. LOLL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-22
AUTHORITY TO UPDATE ITS OPERATION )
AND MAINTENANCE CHARGES )
APPLICABLE TO SCHEDULE 72, ) SUPPLEMENTAL COMMENTS
GENERATOR INTERCONNECTIONS TO ) OF THE COMMISSION STAFF
PURPA QUALIFYING FACILITY SELLERS )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney
General, submits the following comments.
BACKGROUND
On May 8, 2025, Idaho Power Company("Company"), applied to the Commission
requesting authority to update its operation and maintenance ("O&M") charges applicable to
Schedule 72, generator interconnections to Public Utility Regulatory Policies Act(PURPA)
qualifying facility("QF") sellers effective January 1, 2026.
On September 16, 2025, Staff filed its initial comments. Although Staff proposed several
modifications to the currently approved method used to determine the O&M charges in Schedule
72, the overall underlying framework behind its recommendations was still the system-average
framework.
STAFF SUPPLEMENTAL COMMENTS 1 DECEMBER 12, 2025

On September 16, 2025, Idaho Hydroelectric Power Producers Trust, an Idaho Trust,
d/b/a IdaHydro, filed its initial comments, suggesting an actual-cost framework that allows QFs
to pay actual interconnection O&M costs.
On October 14, 2025, the Company filed reply comments, supporting Staff s
recommendations related to O&M charges applicable to interconnections at 138 kilovolts (W")
and greater. For interconnections below 138 W, the Company rejected Staffs proposal; and
instead, the Company proposed to either maintain the current methodology or work with Staff to
develop a hybrid method within 60 days of the final order.
On November 6, 2025, the Commission issued Order No. 36833 to allow additional
comments by December 12, 2025, and the Company to submit reply comments by December 19,
2025.
On November 17, 2025, and November 18, 2025, depositions of Company witnesses
were conducted at Arkoosh Law Offices in Boise, Idaho.
STAFF ANALYSIS
Staff maintains that the system-average framework underlying Schedule 72 is reasonable.
Regardless of any future changes to the framework, Staff recommends that the Schedule 72 rates
be updated to comply with the settlement stipulation approved by Order No. 36042 issued in the
Company's 2023 General Rate Case. For the transmission O&M rates, Staff maintains its
original recommendations in its initial comments. For the distribution O&M rates, Staff
recommends using the currently approved method for the update so that both the transmission
O&M rates and the distribution O&M rates can be updated immediately at the same time.
Additionally, Staff recommends that the Commission direct the Company to meet with Staff and
interested parties to discuss the possibility of implementing a fully voltage-based method, instead
of a hybrid method, for the distribution O&M rates in the future, so that the methods for
determining transmission rates and distribution rates can be aligned.
However, if the Commission desires to explore alternatives to the current system-average
framework, Staff recommends the Commission open a new docket to explore them.
Furthermore, if the Commission directs the Company to present an alternative based on direct-
assigned actual O&M cost in the new docket, the alternative should include recovery of ongoing
overhead costs associated with interconnection O&M.
STAFF SUPPLEMENTAL COMMENTS 2 DECEMBER 12, 2025

New Docket
The current case was initiated as a result of the settlement stipulation approved by Order
No. 36042 issued in the Company's 2023 General Rate Case (Case No. IPC-E-23-11)to update
Schedule 72 to reflect the current operating metrics and assumptions. Staff does not believe this
current case is appropriate to challenge the fundamental framework underlying Schedule 72. If
the Commission desires to explore alternatives to the current system-average framework, Staff
recommends that the Commission order a new docket.
Interconnection O&M Overhead Costs
Although there are some actual interconnection O&M costs that can be directly assigned
to a QF, Staff believes there are overhead costs that are ongoing, fixed in nature, and cannot be
directly assigned. For example, the Company is obligated to maintain its distribution system,
which requires the Company to carry sufficient inventory of replacement parts and to have
staffing to maintain its system. Staff believes that these types of costs should be allocated across
all QFs, regardless of whether a QF's interconnection requires O&M work to be done or not.
Staff recommends that if the Commission orders the evaluation of a new framework based on
actual direct-assigned O&M costs, the Company be required to include the ongoing collection of
overhead-related costs from each QF.
STAFF RECOMMENDATION
For transmission O&M rates, Staff maintains its original recommendations in its initial
comments and recommends that the Commission direct the Company to submit a compliance
filing that:
1. Modifies the Schedule 72 language to apply the transmission O&M rates to
transmission lines of 138 kV and above;
2. Uses the voltage-based method to calculate transmission O&M rates;
3. Uses all levels of transmission voltages of 138 kV and above to develop the
transmission O&M rates; and
4. Calculates the transmission O&M rates based on the weighted average of the
transmission O&M rate at each transmission voltage level, weighted by the QF
interconnection capacity percentage at each voltage level as of December 31, 2024.
STAFF SUPPLEMENTAL COMMENTS 3 DECEMBER 12, 2025

For distribution O&M rates, Staff recommends that the Commission approve the
Company proposed distribution O&M rates based on the currently approved method. Staff also
recommends that the Commission direct the Company to meet with Staff and interested parties to
discuss the possibility of implementing a fully voltage-based method, instead of a hybrid
method, for determining the distribution O&M rates in the future, so that the methods for
determining transmission O&M rates and distribution O&M rates can be eventually aligned.
Lastly, if the Commission desires to explore alternatives to the current system-average
framework, Staff recommends the Commission open a new docket to explore them. If the
Commission directs the Company to present an alternative based on direct-assigned actual O&M
cost in the new docket, the alternative should include recovery of ongoing overhead costs
associated with interconnection O&M.
Respectfully submitted this 12th day of December 2025.
Jeffrev R. Loll
Deputy-Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\IPC-E-25-22 Comments.docx
STAFF SUPPLEMENTAL COMMENTS 4 DECEMBER 12, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 121h DAY OF DECEMBER 2025,
SERVED THE FOREGOING SUPPLEMENTAL COMMENTS OF THE COMMISSION
STAFF, IN CASE NO. IPC-E-25-22, BY E-MAILING A COPY THEREOF TO THE
FOLLOWING:
Idaho Power Company: Idaho Power Company:
DONOVAN E. WALKER TIM TATUM
IPC DOCKETS RILEY MALONEY
IDAHO POWER COMPANY IDAHO POWER COMPANY
1221 WEST IDAHO STREET (83702) 1221 WEST IDAHO STREET (83702)
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: E-MAIL:
dwalkergidahopower.com ttatumkidahopower.com
dockets(aidahopower.com rmaloney�ic,idahopower.com
IdaHydro:
C. Tom Arkoosh
Nicholas J. Erekson
Arkoosh Law Offices
913 W. River St., Ste. 450
P.O. Box 2900
Boise, ID 83701
E-MAIL:
tom.arkoo sh(d),,arkoosh.com
nick.ereks on(&arkoo sh.com
erin.cecil(d),,arkoo sh.com
Renewable Energy Coalition:
IRION SANGER
SANGER GREENE, P.C.
4031 SE HAWTHORNE BLVD.
PORTLAND, OR 97214
E-MAIL:
iriongranger-law.com
PATRICIA JORDA9,SECRETARY
CERTIFICATE OF SERVICE