20260220Compliance Filing.pdf

Ow-1 IOFuwER&
MEGAN GOICOECHEA ALLEN RECEIVED
Corporate Counsel FEBRUARY 20, 2026
maoicoecheaallen(a-idahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
February 20, 2026
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-25-16 - Idaho Power Company's 2025 General Rate Case
Notice Regarding Compliance with Non-Revenue Stipulated Agreement -
Irrigation Time-of-Use Offering
Dear Commission Secretary:
Pursuant to Idaho Public Utilities Commission ("IPUC" or "Commission") Order No.
36892 approving the Stipulation and Settlement ("Stipulation") entered into by and among
the Stipulating Parties in the above-captioned proceeding, Idaho Power Company ("Idaho
Power or Company") hereby provides this notice to advise the Commission of the
activities it has undertaken in compliance with the non-revenue stipulated agreement
related to potential development of an optional Agricultural Irrigation Service (Schedule
24) time-of-use ("TOU") offering. More specifically, Section C, Subsection 12 of the
Stipulation, which was included at the request of the Idaho Irrigation Pumpers Association,
provides:
12. Irrigation TOU. Idaho Power commits to immediately initiate
collaborative discussions with the Idaho Irrigation Pumpers Association
("IIPA"), and other interested parties, with the intent of developing an optional
Agricultural Irrigation Service (Schedule 24) TOU offering that could be filed
for IPUC approval as early as January 1, 2026, with the newly established
rate structure becoming effective on or after June 1, 2026. Issues within scope
for this collaborative effort include, but are not limited to, (1) appropriate TOU
rate periods, (2) the extent to which generation and transmission costs are to
be collected through on-peak energy charges, (3) interplay between the
potential TOU offering and the Irrigation Peak Rewards demand response
program and (4) mitigation of fixed cost revenue erosion.
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

Commission Secretary
Idaho Public Utilities Commission
February 20, 2026
Page 2
On November 6, 2025, the Company contacted parties in Case No. IPC-E-25-16,
to gauge interest in participating in collaborative discussions regarding an optional
Schedule 24 TOU offering and requesting that interested parties provide availability and
preferred format (in-person or virtual) for a workshop for the Company to solicit feedback
from several current Schedule 24 customers and those parties who expressed an interest
in participating and to gather additional or alternative approaches for consideration.
Based on the feedback received, the Company held an in-person workshop (with a
remote option available) on December 3, 2025, at Idaho Power's Twin Falls Operations
Center, which covered the following topics:
• An overview of irrigation class load details,
• Possible barriers to TOU participation for typical irrigation customers,
• Value of a TOU program with different pricing periods for capacity/energy,
• Ratemaking implications for recovery of fixed and variable costs, and
• Initial strawman proposals.
Following the workshop, on December 22, counsel for IIPA advised that its client
was not interested in immediately implementing a Schedule 24 TOU offering but preferred
to continue evaluating its feasibility and alternative approaches. The Company was
amenable to this approach and proposed filing a status update with the Commission on
the potential irrigation TOU offering, which IIPA agreed to. On January 30, 2026, the
Company notified the other Stipulating Parties that it will not move forward with
implementing an optional irrigation TOU offering at this time based on IIPA's feedback
and provided them a copy of this letter prior to filing.'
As a result the Company is providing this update to advise the Commission that it
has, in compliance with the Stipulation, immediately initiated collaborative discussions
with the IIPA and other interested stakeholders regarding the potential development of an
optional TOU offering including addressing: (1)appropriate TOU rate periods, (2)the extent
to which generation and transmission costs are to be collected through on-peak energy
charges, (3) interplay between the potential TOU offering and the Irrigation Peak Rewards
demand response program and (4) mitigation of fixed cost revenue erosion. While the
Stipulation noted that the Company could seek Commission approval of such an offering as
early as January 1, 2026 (with an effective date on or after June 1, 2026), the Company
hereby advises the Commission that based on the feedback from IIPA it does not intend
to seek to implement such an offering at this time.
The Company requested that the Stipulating Parties respond with questions or concerns by February
13; as of the time of this filing the Company had not received any responses.

Commission Secretary
Idaho Public Utilities Commission
February 20, 2026
Page 3
The Company appreciates the engagement of its irrigation customers and
stakeholders in this matter and believes the collaborative efforts to date have been
valuable. Idaho Power also appreciates the feedback from IIPA regarding the desired
timing for seeking to implement an irrigation TOU offering and remains open to further
discussions and ongoing collaboration with IIPA to evaluate potential options.
Sincerely, n��^
4wr?I
Megan Goicoechea Allen
MGA:sg