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Home My WebLink About20260227Compliance Filing.pdf -0IQAW R® DONOVAN WALKER RECEIVED FEBRUARY 27, 2026 Lead Counsel IDAHO PUBLIC dwalkerC� m idahopower.co UTILITIES COMMISSION February 27, 2026 Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Boulevard Building 8, Suite 201-A Boise, Idaho 83714 Re: Case No. IPC-E-25-22 Idaho Power Company's Application for Authority to Update its Operation and Maintenance Charges Applicable to Schedule 72, Generator Interconnections to PURPA Qualifying Facility Sellers Dear Commission Secretary: Attached please find Idaho Power Company's Compliance Filing to be filed in the above-entitled matter. If you have any questions about the attached documents, please do not hesitate to contact me. Sincerely, Donovan E. Walker DEW:cd Attachments 1221 W. Idaho St(83702) P.O. Box 70 Boise, ID 83707 DONOVAN E. WALKER (ISB No. 5921) LISA C. LANCE (ISB No. 6241) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker(cDidahopower.com IlanceCc)_idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-25-22 AUTHORITY TO UPDATE ITS OPERATION ) AND MAINTENANCE CHARGES ) IDAHO POWER COMPANY'S APPLICABLE TO SCHEDULE 72, ) COMPLIANCE FILING GENERATOR INTERCONNECTIONS TO ) PURPA QUALIFYING FACILITY SELLERS. ) Idaho Power Company ("Idaho Power" or "Company") hereby submits this Compliance Filing pursuant to the Idaho Public Utilities Commission's ("Commission") Order No. 36894 in Case No. IPC-E-25-22. Order No. 36894 approved the Company's Application to update the Schedule 72 operations and maintenance ("O&M") charges applicable to PURPA Qualifying Facility ("QF") generator interconnections effective January 1, 2026, and directed the Company to submit a compliance filing reflecting specific modifications within sixty (60) days of the Order. IDAHO POWER COMPANY'S COMPLIANCE FILING - 1 This filing demonstrates Idaho Power's compliance with each of the Commission's required modifications, including meeting with Commission Staff to review implementation of a voltage-based methodology for transmission O&M rates. As a result of those discussions, the Company determined that the existing Schedule 72 tariff sheets, approved by the Commission through Order No. 369461, remain in compliance with Order No. 36894 and therefore require no revision. Supporting workpapers reflecting the results of the updated methodology are provided as Attachment No. 1 to this filing. I. BACKGROUND On May 8, 2025, Idaho Power filed an Application requesting Commission approval to update the monthly O&M charges in Schedule 72 to reflect current operating metrics and assumptions, consistent with the settlement stipulation approved in Order No. 36042 from the 2023 General Rate Case. The Company proposed updated O&M charges for both transmission-level and distribution-level interconnections, as well as removal of the historic de-levelization process and adopting a levelized average rate. Following the Company's Application, Commission Staff reviewed the proposed updates to Schedule 72 and recommended approval of the revised O&M charges with certain modifications to better align the O&M charges with the voltage class at which QF interconnection facilities are installed. More specifically, Staff recommended applying the transmission O&M charge to all QF facilities operating at 138 kilovolts (*V") and above, incorporating all transmission voltages of 138 kV and above into the calculation of the transmission O&M charge, and using a weighted average of voltage-specific O&M ratios On January 28, 2026, the Company submitted a Compliance Filing, consistent with Order No. 36894 issued on December 31, 2025. The Commission approved that Compliance Filing on February 24, 2026, in Order No. 36946. IDAHO POWER COMPANY'S COMPLIANCE FILING - 2 based on the percentage of QF interconnection capacity connected at each voltage level. Staff also recommended developing a voltage-based methodology for distribution-level O&M rates once sufficient data becomes available. In Order No. 36894, the Commission approved Staff's recommended transmission-level modifications and directed the Company to apply the transmission O&M charge to QF facilities of 138 kV and above, to use all transmission voltages of 138 kV and above in developing the transmission O&M rate, and to calculate the transmission charge using a weighted average based on the proportion of QF interconnection capacity at each voltage level as of December 31, 2024. The Commission further directed the Company to continue using the currently approved methodology for the distribution O&M charge at this time. II. TRANSMISSION-LEVEL WEIGHTED VOLTAGE RESULTS As directed in Order No. 36894, the Company compiled necessary data to use transmission voltage levels of 138 kV and above to develop transmission O&M rates. The Company then calculated the Schedule 72 transmission O&M rate using a weighted average of the resulting O&M rates across all applicable voltage levels based on the proportion of QF interconnection capacity connected as of December 31, 2024. Idaho Power met with Commission Staff on February 2, 2026, to review the results of the updated transmission-level weighted calculations. During the February 2, 2026, meeting, the Company explained that it implemented the voltage-based methodology as ordered and the resulting weighted transmission O&M percentage is the same as the percentage calculated under the prior methodology. Idaho Power maintains a "Transmission Plant by Lines" report that disaggregates total transmission lines plant IDAHO POWER COMPANY'S COMPLIANCE FILING - 3 investment by voltage level. This data serves as the basis for allocating O&M labor, general plant, and administrative and general expenses to each transmission voltage category. Because these allocations scale proportionally with the plant investment assigned to each voltage level, the resulting annual O&M expense as a percentage of total investment converges to the same value across all voltage levels included in the analysis, which results in the same O&M rate for each voltage level. The Company reviewed these results and walked through the calculation with Staff. The associated workpapers are included as Attachment No. 1 to this filing but are summarized in the following table. As of December 31, 2024, transmission- interconnected QFs only exist at two voltage levels, 138 kV and 230 kV. As a result, only those two voltages are used in the calculation. Calculated Total Interconnection Weighted Monthly O&M Interconnection Capacity Monthly O&M Rate Capacity (MWs) Weighting Rate 138 kV 0.26% 547 68.37% 0.18% 161 kV 0.26% - - - 230 kV 0.26% 253 31.63% 0.08% 345 kV 0.26% - - - 500 kV 0.26% - - - Facilities Rated 138 kV and Above 0.26% Because the voltage-based weighted methodology required by Order No. 36894 results in the same transmission O&M rate as the previously approved methodology, the existing Schedule 72 O&M rates approved by the Commission in Order No. 36946, effective January 1, 2026, remain in compliance with the Commission's directive to implement a voltage-based weighted methodology. IDAHO POWER COMPANY'S COMPLIANCE FILING - 4 III. CONCLUSION The Company has updated its methodology to calculate the Schedule 72 transmission-level O&M rate to incorporate all transmission voltages of 138 kilovolts and above, by applying the voltage-based weighted methodology using the proportion of QF interconnection capacity at each voltage level, consistent with the direction provided in Order No. 36894. While the Company has implemented the updated methodology, as directed, it is not submitting new tariff sheets, as the tariff sheets currently in effect reflect the appropriate rate. Finally, the Company appreciates Staff's thorough review and collaboration throughout this compliance process. Respectfully submitted this 27t" day of February 2026. DONOVAN WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S COMPLIANCE FILING - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 27t" day of February 2026, 1 served a true and correct copy of the within and foregoing IDAHO POWER COMPANY'S COMPLIANCE FILING upon the following named parties by the method indicated below, and addressed to the following: IPUC COMMISSION STAFF Hand Delivered Jeffrey R. Loll U.S. Mail Deputy Attorneys General Overnight Mail Idaho Public Utilities Commission X Email - jeff.loll puc.idaho.gov P.O. Box 83720 Boise, ID 83720-0074 IDAHYDRO Hand Delivered C. Tom Arkoosh U.S. Mail Nicholas J. Erekson Overnight Mail Arkoosh Law Offices X Email - tom.arkoosh(a)arkoosh.com 913 W. River St., Ste. 450 nick.erekson(a-)-arkoosh.com P.O. Box 2900 erin.cecil(a)_arkoosh.com Boise, ID 83701 RENEWABLE ENERGY COALITION Hand Delivered Irion Sanger U.S. Mail Sanger Greene, P.C. Overnight Mail 4031 Se Hawthorne Blvd. X Email - irion _sanger-Iaw.com Portland, Or 97214 Christy Davenport Legal Administrative Assistant I BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-25-22 IDAHO POWER COMPANY ATTACHMENT NO. 1 SEE EXCEL SPREADSHEET