20260128Staff Comments.pdf

RECEIVED
January 28, 2026
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
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 IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-26-01
APPROVAL OF THE SECOND )
AMENDMENT OF THE FIRM ENERGY )
SALES AGREEMENT BETWEEN IDAHO ) COMMENTS OF THE
POWER COMPANY AND CYCLE ) COMMISSION STAFF
HORSESHOE BEND WIND, LLC )
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 January 12, 2026, Idaho Power Company ("Company") applied to the Commission
requesting the Commission issue an order approving the Second Amendment to the Firm Energy
Sales Agreement ("FESA")between the Company and Cycle Horseshoe Bend Wind, LLC.
The original FESA contained published avoided cost rates approved in Order No. 29391,
which were not changed in the First Amendment. However, these rates only ran through the end
of 2025,even though the 20-year contract term does not expire until February 28,2026. Therefore,
the Company proposes the Second Amendment to include additional avoided cost rates through
the end of the contract term based on the same published avoided cost rates approved in Order No.
29391.
STAFF COMMENTS 1 JANUARY 28, 2026

STAFF ANALYSIS
Staff reviewed the proposed avoided cost rates for 2026 contained in the Second
Amendment and confirms that they are correct. The proposed avoided cost rates for 2026 are
from the same order(i.e. Order No. 29391) that determined the avoided cost rates contained in
the original FESA. Staff recommends that the Commission approve the Second Amendment.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the proposed Second Amendment to the
FESA between the Company and the Cycle Horseshoe Bend Wind, LLC.
Respectfully submitted this 28th day of January 2026.
Jeffrey R. Loll
Deputy Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\IPC-E-26-01 Comments.doex
STAFF COMMENTS 2 JANUARY 28, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 281h DAY OF JANUARY 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-26-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E. WALKER ENERGY CONTRACTS
LISA C. LANCE IDAHO POWER COMPANY
IPC DOCKETS PO BOX 70
IDAHO POWER COMPANY BOISE ID 83707-0070
PO BOX 70 E-MAIL: energycontractsgidahopower.com
BOISE ID 83707-0070
E-MAIL: dwalker(cr�,idahopower.com
llancegidahopower.com
dockets(aidahopower.com
PATRICIA JORD: , SECRETARY
CERTIFICATE OF SERVICE