20260220Application.pdf

-1 A POWER.,
DONOVAN WALKER RECEIVED
Lead Counsel FEBRUARY 20, 2026
dwalker(a)idahopower.com IPC-E-26-03 IDAHO PUBLIC
UTILITIES COMMISSION
February 20, 2026
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-26-03
Application for Approval of the 2032 All-Source Request for Proposals to
Meet Capacity Resource Needs in as Early as 2031
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Application and the Direct
Testimony of Eric Hackett in the above matter.
A Word version of the testimony will be sent in a separate email for the Reporter.
If you have any questions about any of the aforementioned documents, please
do not hesitate to contact me.
Very truly yours,
Donovan E. Walker
DEW:sg
Enclosures
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker(a-)_idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-26-03
APPROVAL OF THE 2032 ALL-SOURCE )
REQUEST FOR PROPOSALS TO MEET ) APPLICATION
CAPACITY RESOURCE NEEDS IN AS )
EARLY AS 2031 . )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho
Code §§ 61-501, 61-502, and 61-503 as well as Rules of Procedure ("RP") 52 and 201
hereby respectfully makes application to the Idaho Public Utilities Commission
("Commission") for an order approving Idaho Power's draft 2032 All-Source Request for
Proposals ("RFP") for Peak Capacity & Energy Resources ("2032 RFP"). The proposed
2032 RFP is necessary to position the Company to meet its obligation to provide safe,
reliable service to its customers.
APPLICATION FOR APPROVAL OF THE 2032 RFP - 1

Accompanying this Application is the Direct Testimony of Eric Hackett which
provides an overview of the competitive resource acquisition process Idaho Power
proposes to undertake to solicit resources to meet identified capacity deficiencies in as
early as 2031, in accordance with the Procedures for Soliciting Large-Supply-Side
Resources ("Solicitation Procedures") approved through Order No. 36898.1 Mr. Hackett
will provide an overview of the draft 2032 RFP, including the 2032 RFP Selection Plan,
the bid evaluation process that the Company proposes to undertake to evaluate resource
bids received through the 2032 RFP that will compete to provide a combination of peak
capacity and energy to help meet Idaho Power's electric energy needs in as early as
2031 , and the 2032 RFP Announcement Plan.
L BACKGROUND
1. Idaho Power is pursuing energy and capacity resources to meet customers'
needs and ensure the Company can continue to reliably meet the growing demands on
its electrical system. Idaho Power's annual capacity position developed to inform its 2025
Integrated Resource Plan ("IRP"), which was filed on June 27, 2025, and acknowledged
on February 17, 2026,2 and reflected current information on the expected timing of major
new loads, the resource procurements the Company has made to date, and other
updates, demonstrated Idaho Power will have future incremental peak capacity and
supply-side resource needs. The 2025 IRP identified a capacity deficiency beginning in
2027 and generally growing through the entire 20-year planning period. Recent regulatory
filings for resources have included refreshed system reliability assessments that built off
Case No. GNR-E-25-01.
2 Case No. IPC-E-25-23, Order No. 36937.
APPLICATION FOR APPROVAL OF THE 2032 RFP - 2

the identified 2025 IRP need and have shown an incremental perfect capacity need of at
least 200 megawatts ("MW") in 2031 and 2032 with a greater need likely in 2032.
2. Under Idaho law, Idaho Power has an obligation to provide adequate,
efficient, just, and reasonable service on a nondiscriminatory basis to all those that
request it within its service area. Idaho Power has experienced and expects sustained
load growth, thereby requiring the addition of new resources. As such, Idaho Power's
proposed 2032 All-Source RFP is necessary to allow the Company to acquire resources
and long-lead equipment, and to allow an appropriate amount of time to procure and
construct additional infrastructure necessary to reliably serve future customer demand.
The size of the proposed resource procurement for the RFP triggers the application of the
Solicitation Procedures.
II. SOLICITATION PROCEDURES
3. Commission Staff ("Staff") initiated a case, Case No. GNR-E-25-01,
requesting the Commission modify its RFP oversight process, as directed by Order No.
36309.3 Staff's primary objective of their proposed oversight process was to establish a
regulatory process that will ensure resources selected by Idaho's investor-owned electric
utilities are least-cost, least-risk and are able to meet the required needs of the system
while also: (1) minimizing the amount of administrative burden and potential delays
needed for utilities to make a resource decision, (2) maximizing the utility's flexibility to
tailor its selection process for a given set of circumstances when requiring additional
resources, and (3) adhering to a set of requirements and guiding principles when
developing its selection process for each new set of resources. Staff included proposed
3 Case No. IPC-E-24-12.
APPLICATION FOR APPROVAL OF THE 2032 RFP - 3

Solicitation Procedures as part of their request.4 Specifically, Staff proposed the
Commission: (1) rescind Order No. 32745 for Idaho Power to comply with the Oregon
RFP guidelines, and (2) direct each utility to apply for and receive Commission approval
for each new RFP prior to issuing it for the acquisition of large supply-side resources.
4. The Commission approved the Solicitation Procedures with Order No.
36898, which will apply to any solicitation for generation or storage resources of 100 MW
or greater for a duration of 10 years or more and is subject to cost recovery from Idaho
customers. The guiding principles suggest the RFP maximize competition between
bidders and is resource-agnostic, soliciting bids from all feasible resource types, that the
selection process is designed to select the least-cost, least-risk resources that satisfy the
system need, and that the RFP and selection process ensure competition, transparency,
confidentiality, and fairness through all stages of the procurement process.
5. The Solicitation Procedures require that prior to issuing an RFP, the utility
must file an application with the Commission to obtain approval. The application should
include the RFP, the RFP Selection Plan, and the RFP Announcement Plan, as well as
any other documents relative to the solicitation. The Solicitation Procedures also require
the application include a justification for the need for new resources. In addition, the
Solicitation Procedures outline a waiver process should a utility opt to defer Commission
pre-approval of its RFP. Finally, the Solicitation Procedures outline the process for which
utilities may follow post-selection of resources procured as a result of the RFP.
4 Staff's Application to Update the RFP Oversight Process.
APPLICATION FOR APPROVAL OF THE 2032 RFP -4

III. THE 2032 RFP
6. Idaho Power's proposed 2032 All-Source RFP is resource-agnostic and
solicits bids from all feasible resource types with sufficient lead time to meet the desired
commercial operation date. The 2032 RFP is soliciting resources totaling an incremental
perfect capacity need of at least 200 MW in 2031 and 2032 with a greater need likely in
2032. However, because the annual capacity positions during the Company's near-term
resource decision making phase can be very fluid, this capacity need is subject to change.
Both resource-based and market purchase proposals must have a commercial operation
date between April 1 and May 31 of the respective year, 2031 and 2032. As a result, all
proposals must have a first delivery date of May 31, 2032, or earlier. The solicitation is
being released to meet the objective of determining the least-cost and least-risk resources
to satisfy the system needs and will be conducted through a fair, transparent, and
confidential evaluation process as defined throughout the draft 2032 RFP.
7. The bid evaluation and selection process, or Selection Plan,5 is designed to
identify the combination and size of the proposed resources that will maximize customer
benefits and will satisfy the projected resource capacity and energy needs while
maintaining reliability. The first phase of the bid evaluation process includes the
screening, evaluation, and ranking of the bids, that will identify a subset of bids, the initial
shortlist, that can be advanced for further evaluation. This process includes a bid eligibility
screening to ensure conformance with the Minimum Requirements of the 2032 RFP and
the price and non-price evaluation to score and rank bids. Idaho Power proposes the
6 As outlined in the Solicitation Procedures.
APPLICATION FOR APPROVAL OF THE 2032 RFP - 5

comprehensive set of the highest ranking and relatively lowest cost bids that combined
meet the requirements of the 2032 RFP will become the initial shortlist.
8. The Company will utilize the IRP modeling tools to identify the least-cost,
least-risk portfolio of projects from the initial shortlist, beginning with a scenario analysis
assessing the performance of the initial shortlist projects under various market conditions
to determine the best performing project proposals. After the portfolios are identified, the
Company will perform a reliability assessment to ensure that the selected portfolio of
resources can meet all hourly load and operating reserve requirements with sufficient
cushion to account for other system uncertainties such as non-normal weather events.
The resulting scenario analysis will produce a preliminary final shortlist of projects based
on their performance and cost under each of the scenarios. Furthermore, an additional
risk analysis will be performed as part of the final shortlist development.
9. The Company will evaluate each portfolio and its ability to perform under
dynamic market conditions by performing a stochastic sensitivity analysis. The stochastic
analysis assesses the effect on portfolio costs when select variables take on values
different from their planning-case levels including, for example, load, natural gas prices,
and hydro generation. The models measure the expected cost of each portfolio in an
uncertain future to understand the range of portfolio costs across the full extent of
stochastic shocks and how the ranges for portfolios differ. The results identify the least-
cost, least-risk projects and their resulting rank on the final shortlist.
10. The Company first plans to post the draft 2032 RFP on the Idaho Power's
Request for New Resources webpage6 coincident to the filing of this proceeding,
6 https://www.idahopower.com/about-us/doing-business-with-us/request-for-resources/
APPLICATION FOR APPROVAL OF THE 2032 RFP - 6

providing notice to the public of the upcoming solicitation. The intent on providing
interested bidders the draft 2032 RFP in advance of the formal solicitation is to ensure
bidders have the opportunity to submit potential projects into the annual Generator
Interconnection Cluster Request Window for study, which runs from March 1, 2026,
through April 15, 2026. Because potential bidders will have first been notified on February
20, 2026, of the upcoming solicitation, the draft 2032 RFP proposes a bid due date of
May 29, 2026.
11. To allow sufficient time for 2032 RFP bid submittal and bid evaluation, Idaho
Power is requesting Commission approval of the draft 2032 RFP by April 24, 2026, to
allow for issuance of the final 2032 RFP on April 27, 2026. The Company is aiming for
an identification of the final shortlist on July 17, 2026, and a contract negotiation period
of approximately three months followed by material procurement and resource
construction to better ensure that the selected resources are in-service to meet Idaho
Power's resource needs. The Company believes the draft 2032 RFP and its proposed
timeline are consistent with the Solicitation Procedures established by the Commission.
IV. COMMUNICATIONS AND SERVICE OF PLEADINGS
12. Communications and service of pleadings with reference to this Application
should be sent to the following:
Donovan E. Walker Tim Tatum
Lead Counsel Connie Aschenbrenner
Idaho Power Company Idaho Power Company
1221 West Idaho Street (83702) 1221 West Idaho Street (83702)
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
dwalker idahopower.com ttatum(@.idahopower.com
dockets(c�idaho power.com caschenbrenner(a)_idahopower.com
APPLICATION FOR APPROVAL OF THE 2032 RFP - 7

V. MODIFIED PROCEDURE
13. The Company 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. RP 201,
et seq. If, however, the Commission determines that a technical hearing is required, the
Company stands ready to present its testimony and support the Application in such
hearing.
14. Idaho Power's proposed 2032 RFP is necessary to allow the Company to
acquire resources and long-lead equipment, and to allow an appropriate amount of time
to procure and construct additional infrastructure necessary to reliably serve future
customer demand. In order to allow sufficient time for bid submittal, bid evaluation,
contract negotiation, material procurement and resource construction prior to the
anticipated commercial operation date, Idaho Power respectfully requests that the
Commission set a procedural schedule that would provide for a final order on or before
April 24, 2026.
VI. REQUEST FOR RELIEF
15. Idaho Power respectfully requests that the Commission issue an order
approving Idaho Power's draft 2032 All-Source RFP on or before April 24, 2026. The
proposed 2032 RFP is necessary to position the Company to meet its obligation to provide
safe, reliable electric service to its customers.
DATED at Boise, Idaho this 20th day of February 2026.
DONOVAN E. WALKER
Attorney for Idaho Power Company
APPLICATION FOR APPROVAL OF THE 2032 RFP - 8