20260226Comments.pdf

ON -aIQAWPOWER(,)
LISA C. LANCE RECEIVED
Corporate Counsel February 26, 2026
Ilance(Widahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
February 26, 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. I PC-E-26-02
Commission Staff's Application to Update IPC's Cost of Capital Inputs in the
Surrogate Avoided Resource Methodology
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Comments in regard to the
above matter.
If you have any questions about the aforementioned documents, please do not
hesitate to contact me.
Very truly yours,
Lisa C. Lance
LCL:cd
Attachments
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

LISA C. LANCE (ISB No. 6241)
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]
Ilance(a-Mdahopower.com
dwalkerCa-)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION )
STAFF'S APPLICATION TO UPDATE ) CASE NO. IPC-E-26-02
IDAHO POWER COMPANY'S COST OF )
CAPITAL INPUTS IN THE SURROGATE ) IDAHO POWER COMPANY'S
AVOIDED RESOURCE METHODOLOGY ) COMMENTS
Idaho Power Company ("Idaho Power" or "the Company"), in accordance with
Commission Rule of Procedure 203 and the applicable provisions of the Public Utility
Regulatory Policies Act of 1978 ("PURPA"), as well as the Idaho Public Utilities
Commission's ("Commission") Notice of Modified Procedure in this matter, Order No.
36919, hereby respectfully submits the following Comments.
The Commission Staff ("Staff") filed an Application on January 12, 2026,
requesting approval to update the cost of capital inputs used in the Surrogate Avoided
Resource ("SAR") Methodology. These updates include the cost of debt, return on equity
("ROE"), and overall weighted cost of capital. The proposed changes seek to align the
IDAHO POWER COMPANY'S COMMENTS - 1

model inputs with the Commission-approved cost of capital authorized in Idaho Power's
most recent general rate case, Case No. IPC-E-25-16, as approved by Order No. 36892.
The Company has reviewed the information in Staff's Application and the SAR
model provided by Staff in the case file. Idaho Power believes the cost of capital inputs
utilized by Staff have been correctly updated in the model and are consistent with Order
No. 36892. The Company also agrees that Staff's proposed calculations are consistent
with the SAR methodology approved by the Commission.
Respectfully submitted this 26th day of February 2026.
LISA C. LANCE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S COMMENTS - 2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of February 2026, 1 served a true and
correct copy of Idaho Power Company's Comments upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Jeff Loll U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FTP Site
11331 W. Chinden Blvd., Bldg No. 8, X Email jeff.loll puc.idaho.gov
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
Christy Davenport
Legal Administrative Assistant
IDAHO POWER COMPANY'S COMMENTS - 3