20260112APPLICATION.pdf

RECEIVED
January 12, 2026
JEFFREY LOLL (ISB #11675) IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702-0074
(208)-334-0318
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION STAFF'S )
APPLICATION TO UPDATE IDAHO POWER ) CASE NO. IPC-E-26-02
COMPANY'S COST OF CAPITAL INPUTS IN )
THE SURROGATE AVOIDED RESOURCE ) APPLICATION
METHODOLOGY )
Pursuant to the Public Utility Regulatory Policies Act of 1978 ("PURPA") and the
implementing regulations of the Federal Energy Regulatory Commission ("FERC"), the Idaho
Public Utilities Commission ("Commission") has approved a Surrogate Avoided Resource
("SAR") Methodology for calculating published avoided cost rates for qualifying cogeneration
and small power production facilities ("QFs") under applicable resource-specific eligibility caps.
Idaho Power Company's ("the Company") latest general rate case (Case No. IPC-E-25-16) has
triggered an update of the cost of capital inputs in the SAR Model.
In support of this Application, Commission Staff represents as follows:
I. BACKGROUND
The Commission calculates published avoided cost rates for QFs under applicable
resource-specific eligibility caps. The SAR Model uses each utility's approved cost of capital
information from their general rate cases.
On December 30, 2025, the Commission issued Order No. 36892 in the Company's most
recent general rate case, Case No. IPC-E-25-16, where a 9.6% return on equity ("ROE") and a
7.410% overall rate of return("ROR")were approved based on a non-specified cost of debt and a
non-specified capital structure, with an effective date of January 1, 2026.
APPLICATION 1

II. THE UPDATES
Because the cost of debt and the capital structure were not specified in Case No. IPC-E-
25-16, Staff proposes to use the currently authorized capital structure' in the SAR Model(49.27%
common equity and 50.73% long-term debt) and impute the cost of debt based on the capital
structure. The imputed cost of debt is 5.283%.
Staff first updated the cost of debt of 5.283% and the return on equity of 9.6% on Tab
"IPCoCapCarChg" of the SAR Model, which calculates the Company's Carrying Charge Rate.
Staff also added a note on Tab"IPCoCapCarChg",which says the following: "For Cost of Capital
as a result of IPC-E-25-16, the cost of debt is imputed based on the capital structure authorized in
Case No. IPC-E-08-10. The cost of debt will be updated if and when a new capital structure is
authorized in a subsequent case."
Next, Staff updated Cell D64(UTILITY WEIGHTED COST OF CAPITAL)and Cell D65
(CAPITAL CARRYING CHARGE) of Tab "AVOID NEW".
Lastly, Staff updated Tab "IPCOStorage(WinterCapacity)" and Tab
"IPCOStorage(SummerCapacity)" to ensure that avoided cost of capacity for energy storage QFs
reflects the updated cost of capital information.
Included in this Application are the following Attachments:
a. An updated SAR Model with all the updates incorporated as mentioned above;
b. Attachment A (IPCO Avoided Cost Rates for New Contracts); and
c. Attachment B (IPCO Avoided Cost Rates for Replacement Contracts).
III. MODIFIED PROCEDURE
Commission Staff believes that a hearing is not necessary to consider the issues presented
herein and respectfully requests that this Application be processed under Modified Procedure, i.e.,
by written submissions rather than by hearing. Commission Rules of Procedure 201-204. If,
however, the Commission determines that a technical hearing is required, the Commission Staff
stands ready to prepare and present its testimony in such hearing.
1 The capital structure currently used in the SAR Model was approved in Order No. 30722 in Case No.IPC-E-08-10.
APPLICATION 2

IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
Communications and service of pleadings, exhibits, orders, and other documents relating
to this proceeding should be sent to the following:
Jeffrey Loll Yao Yin
Deputy Attorney General Idaho Public Utilities Commission
Idaho Public Utilities Commission P.O. Box 83720
P.O. Box 83720 Boise, ID 83702-0074
Boise, Idaho 83702-0074 [e-mail]
j eff.loll(&puc.Idaho.gov
V. REQUEST FOR RELIEF
Commission Staff respectfully requests the Commission issue an order: (1)authorizing this
matter to be processed by Modified Procedure; and (2) updating the SAR Model as described
herein and approving the updated published avoided cost rates shown in the attachments.
Respectfully submitted this 12th day of January, 2026.
Jeffrey Loll
Deputy Attorney General
APPLICATION 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of January 2026, 1 served the foregoing
APPLICATION,in Case No. IPC-E-26-02,Via E-Mail to the following:
Donovan Walker
Camille Christen
Idaho Power Company
1121 W. Idaho Street 83702
P.O. Box 70
Boise, ID 83707-0070
[e-mail]
CChri stengidahopower.com
[e-mail]
energycontracts(kidahopower.com
Keri J. H wker
Legal Assistant
APPLICATION 4