20260311Application - Redacted.pdf

04N IQAM R®
DONOVAN WALKER
Lead Counsel RECEIVED
dwa I ker(a)idaho power.corn MARCH 10, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
March 10, 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-26-04
Application of Idaho Power Company for Certificates of Public Convenience
and Necessity for the South Hills and Peregrine Power Plants and for an
Associated Accounting Order
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's ("Idaho Power")
Application, the Direct Testimony of Eric Hackett, the Direct Testimony of Jared Ellsworth,
the Direct Testimony of Adam Richins, the Direct Testimony of Courtney Waites and
Exhibits in the above matter.
Word versions of the testimonies will be sent in a separate email for the Reporter.
The confidential documents will be sent to the parties who execute the Protective
Agreement.
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:cd
Enclosures
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Application of Idaho Power Company for Certificates of Public Convenience and
Necessity for the South Hills and Peregrine Power Plants and for an Associated
Accounting Order
Case No. IPC-E-26-04
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Application, the Direct Testimony of Eric Hackett along with Exhibits 2
and 3 to the Direct Testimony of Eric Hackett, the Direct Testimony of Jared Ellsworth,
the Direct Testimony of Adam Richins, along with Exhibit 5 to the Direct Testimony of
Adam Richins, and the Direct Testimony of Courtney Waites, dated March 10, 2026, may
contain information that Idaho Power Company and a third party claims is a confidential
trade secret, business records of a private enterprise required by law to be submitted or
to be inspected by a public agency, and/or public records exempt from disclosure by state
or federal law (material nonpublic information under U.S. Securities and Exchange
Commission Regulation FD) as described in Idaho Code § 74-101, et seq., and/or § 48-
801, et seq. As such, it is protected from public disclosure and exempt from public
inspection, examination, or copying.
DATED this Tuesday, March 10, 2026.
'6-." '5;&)&a,
Donovan Walker
Counsel for Idaho Power Company

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-26-04
CERTIFICATES OF PUBLIC )
CONVENIENCE AND NECESSITY FOR ) APPLICATION
THE SOUTH HILLS AND PEREGRINE )
POWER PLANTS AND FOR AN )
ASSOCIATED ACCOUNTING ORDER. )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with Idaho
Code §§ 61-501, 61-502, 61-503, 61-508, 61-524, 61-526; as well as Rule of Procedure
("RP") 52, 112 and 201 hereby respectfully makes application to the Idaho Public Utilities
Commission ("Commission") for an order (1) granting a Certificate of Public Convenience
and Necessity ("CPCN") for the South Hills Power Plant, a cost-effective natural gas-
fueled facility providing up to 222 megawatts ("MW") of nameplate generation ("South
Hills") to meet an identified capacity deficit in 2029, (2) granting a CPCN for the Peregrine
Power Plant, a cost-effective natural gas-fueled facility providing 430 MW of nameplate
generation ("Peregrine")to meet an identified capacity deficit in 2030, and (3) confirmation
of the Company's application of accrual of Allowance for Funds Used During Construction
APPLICATION - 1

("AFUDC") for the South Hills and Peregrine plants to coincide with initial procurement
activities for the natural gas-fueled facilities. The South Hills and Peregrine plants are
necessary for Idaho Power to continue to provide safe, reliable electric service in 2029
and beyond.
Accompanying this Application are four sets of testimony. The Direct Testimony of
Eric Hackett begins with an overview of the competitive resource acquisition process
undertaken to meet Idaho Power's identified capacity deficiencies, describing the
extensive Request for Proposals ("RFP") process undertaken in accordance with the
Oregon competitive bidding rules that was used to evaluate the various resources that
competed to provide a combination of peak capacity and energy to help meet Idaho
Power's electric energy needs in 2029 and beyond. Mr. Hackett will then explain how the
South Hills and Peregrine projects, for which Idaho Power is requesting the Commission
grant CPCNs in this proceeding, are least-cost, least-risk resource alternatives necessary
for Idaho Power to continue to provide safe, reliable electric service beginning in 2029.
Next, the Direct Testimony of Mr. Jared Ellsworth discusses the identification of
Idaho Power's need for new resources to meet an identified capacity deficit in 2029 and
2030, as informed by the 2023 Integrated Resource Plan ("IRP") and updated in the 2025
IRP. Mr. Ellsworth will describe the most recent system reliability and capacity deficit
assessments used to inform and identify near-term capacity needs, providing sound
analytical support for the acquisition of the resources discussed in my testimony. Finally,
Mr. Ellsworth will discuss the economic analysis performed to evaluate the South Hills
and Peregrine projects alongside the remaining feasible projects.
APPLICATION - 2

Company Witness Mr. Adam Richins will then provide an overview of Idaho
Power's resource procurement activities and the current challenges of bringing resources
online timely as a result of the Company's load growth across multiple customer sectors
at a time of rising costs, supply chain constraints, permitting obstacles, and constrained
system capacity. Mr. Richins discusses the timelines for procurement activities
associated with natural gas resources that Idaho Power has been monitoring, ultimately
requiring the Company to take immediate action following the identification of the South
Hills and Peregrine natural gas-fueled plants as least-cost, least-risk resources. Lastly,
Mr. Richins describes the natural gas transport and supply landscape in Southern Idaho
and the Company's efforts to secure additional incremental natural gas transport capacity
for the South Hills and Peregrine plants as necessary for Idaho Power to continue to
provide safe, reliable electric service beginning in 2029 and beyond
Finally, the Direct Testimony of Ms. Courtney Waites describes AFUDC and the
commencement of its accrual as soon as funds are expended and committed to a
construction project. For generation resources, this has typically occurred subsequent to
the request for a CPCN. However, Idaho Power has incurred expenditures associated
with the South Hills and Peregrine projects prior to filing the request for a CPCN and
therefore the Company is requesting the Commission confirm the application of accrual
of AFUDC when expenditures are first incurred.
I. CORPORATE STATUS
1. Idaho Power is a corporation incorporated under the laws of the state of
Idaho. Idaho Power is engaged in the business of generating, purchasing, transmitting,
and distributing electric energy and providing retail electric service in the states of Idaho
and Oregon. Idaho Power's principal offices are situated in Boise, Idaho, and its address
APPLICATION - 3

is 1221 West Idaho Street, Boise, Idaho 83702. Copies of Idaho Power's Articles of
Incorporation and Certificates of Convenience and Necessity are on file with the
Commission. Idaho Code § 61-528.
II. BACKGROUND
2. On February 29, 2024, Idaho Power initiated an extensive competitive
bidding process following the resource procurement rules of the Public Utility Commission
of Oregon ("OPUC"), as required by the Idaho Commission at that time, employing a fair
and competitive RFP process that spanned nearly 18-months, in an effort
to acquire resources necessary to meet capacity deficiencies beginning in 2028. The RFP
was issued based upon the Company's annual capacity positions developed to inform the
2023 IRP which identified deficits of 138 MW of incremental capacity needs in 2028 and
555 MW of supply-side resource additions in the Preferred Portfolio in 2028. Further, the
2023 IRP identified incremental capacity needs of 142 MW in 2029 and 369 MW in 2030,
growing to over 1,150 MW by 2038. The 2023 IRP Preferred Portfolio included the
addition of large quantities of cost-effective clean resources including solar, wind, battery
storage, energy efficiency, peaking hydrogen, incremental demand response and
geothermal. Subsequently, the Company's 2025 IRP identified increased incremental
capacity needs of 192 MW in 2029 and 380 MW in 2030 with a total shortfall exceeding
1,000 MW by 2040. While the 2025 IRP Preferred Portfolio included solar, storage, wind,
energy efficiency, and incremental demand response, it also included 550 MW
of incremental natural gas as cost-effective resource additions. Additionally, the most
recent system reliability assessment has identified a capacity deficit of 236 MW in 2029,
increasing to 352 MW in 2030.
APPLICATION - 4

3. 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 a result, in order to meet
its obligation to reliably serve customer load in a least-cost, least-risk manner, Idaho
Power began the competitive solicitation for the acquisition of resources. The Company
conducted a competitive solicitation through the issuance of an All-Source RFP seeking
to acquire a combination of energy and capacity resources. Idaho Power did not define
the type of resource (i.e., wind, solar, gas, or battery storage) desired rather the RFP
targeted resource procurements consistent with the incremental capacity deficiencies in
the 2023 IRP, accepting bids for energy or capacity incremental to its system beginning
in the summer 2028 timeframe and beyond, from market energy purchases or new or
existing resources. The procurement process resulted in the identification of least-cost,
least-risk resources necessary to fill the identified capacity deficiencies of 236 MW and
352 MW in 2029 and 2030, respectively. The proposed acquisitions, as described herein,
are necessary and required in order to continue to provide reliable and adequate electric
service to Idaho Power's customers beginning in 2029 and into the future.
4. The RFP process spanned nearly 18-months, in an effort to acquire
resources necessary to meet capacity deficiencies beginning in 2028, in 2029, and
beyond. The RFP process began with the engagement of an Independent Evaluator
("IE"), with participation from OPUC Staff and stakeholders throughout, and involved a
comprehensive eligibility screening process, the meticulous assessment and scoring of
the resource bids, including benchmark resources, and a rigorous scenario analysis
APPLICATION - 5

followed by a portfolio sensitivity analysis and an additional qualitative factor analysis of
the final shortlist projects. On August 30, 2025, the OPUC approved the final shortlist for
2029 bids, or those bids with a commercial operation date no later than June 1 , 2029
('2029 Bids").
5. To meet the identified capacity deficiencies beginning in 2029, the
Company further evaluated the 2029 Bids final shortlist, noting that because
of the decrease in the Effective Load Carrying Capability ("ELCC") of new solar projects
and the limited ELCC of wind resources, only the remaining BESS projects would have
the potential to fill the capacity deficiencies. Due to concerns with the economics the
battery storage projects, as well as the then recently published 2025 IRP that identified
continued increased peak load and the need for flexible generation resources, Idaho
Power investigated alternative resources, including the benchmark bid on the 2029 final
shortlist that identified a transition from the planned battery storage to a natural gas
resource in 2029, South Hills, as well as an alternative gas resource solution in 2030,
Peregrine. The results of the evaluation indicated the South Hills and Peregrine plants
combined could more economically meet the Company's resource needs by
over the 20-year planning period. These resources are necessary
and required to timely meet the Company's resource needs and continue to provide
reliable and adequate service to Idaho Power's customers starting in the summer of
2029 and into the future.
III. OREGON PROCUREMENT RULES
6. The Commission, in Case No. IPC-E-10-03, initiated a case seeking to
establish competitive bidding guidelines for the RFP process. In 2013, the Commission
APPLICATION - 6

closed Case No. IPC-E-10-03 without establishing Idaho-specific resource procurement
guidelines but rather directing Idaho Power to follow the RFP guidelines applicable to its
Oregon service territory, which was in effect at the time the 2023 IRP identified the
capacity deficiencies in 2028 and beyond. The Oregon RFP guidelines to which the
Commission referred were later codified into the administrative rules of the OPUC
resource procurement rules.' The OPUC resource procurement rules impose competitive
bidding requirements upon an electric utility for the "acquisition of a resource or a contract
for more than an aggregate of 80 MWs and five years in length," among other
requirements.
7. Idaho Power initiated the rule compliant RFP process on February 29, 2024,
to acquire resources to be online in 2028 and beyond. Following feedback from
stakeholders, the Company updated the RFP to consider bids with later commercial
operation dates, bifurcating the evaluation of the bids, with prioritization of bids with a
commercial operation date by April 1, 2028, ("2028 Bids") followed by bids that could not
meet the April 1, 2028, commercial operation date ("2029 and Beyond Bids"). Idaho
Power's discussion in this case is specific to the evaluation of the 2029 and Beyond Bids
for which the Company ultimately received approval of the 2029 Bids final shortlist to meet
the identified capacity deficits.
IV. RESOURCE PROCUREMENT PROCESS
8. On February 29, 2024, Idaho Power commenced the competitive bidding
process, filing a request with the OPUC to (1) approve the selection of London Economics
International LLC ("LEI") as the IE for the RFP, (2) approve the proposed scoring and
Oregon Administrative Rule ("OAR") 860-089-0010 et seq.
APPLICATION - 7

modeling methodology, (3) approve the draft RFP, and (4) waive certain competitive
bidding rules to allow expedited review and approval of the RFP. On April 30, 2024, in a
public meeting, the OPUC approved the Company's use of LEI as the IE again for Idaho
Power's RFP and evaluation of resources. The OPUC also approved the concurrent
review of both the scoring and modeling methodologies and the draft RFP.
9. The Company worked with OPUC Staff and stakeholders to finalize the draft
RFP and on August 16, 2024, Idaho Power formally issued the RFP, soliciting bids for (1)
energy market purchases and (2) new or existing resources. The RFP was well received;
the 2029 and Beyond Bids included 83 proposals from 18 different bidders, with a total of
117 resource bids summing to nearly 20 gigawatts of resources. The bids included a
variety of ownership structures, including many bids that would result in bidder-owned
resources (i.e., PPA's, and Battery Storage Agreements), as well as five benchmark bids
across four sites, submitted by Idaho Power's internal bid team.
10. The Direct Testimony of Mr. Hackett details the bid evaluation process
which was consistent and prescriptive as described in the RFP, ultimately identifying the
2029 Bids final shortlist which are listed in Confidential Exhibit No. 2 to Mr. Hackett's
testimony. As required under the OPUC competitive bidding rules, the OPUC approved
Idaho Power's 2029 Bids final shortlist on August 19, 2025, in a public meeting. To meet
the identified capacity deficiencies beginning in 2029, the Company further evaluated the
2029 Bids final shortlist, noting that only the remaining battery storage projects would
have the potential to fill the capacity deficiencies. However, due to concerns with the
economics of the battery storage projects, as well as the then recently published 2025
APPLICATION - 8

IRP that identified continued increased peak load and the need for flexible generation
resources, Idaho Power investigated additional alternative resources.
V. RESOURCE NEEDS
11. As described more completely in the Direct Testimony of Mr. Ellsworth, the
Company recognizes that during the near-term resource decision-making phase, the
annual capacity positions can be very fluid and therefore regularly performs system
reliability assessments. Idaho Power constantly monitors resource needs, and in the face
of growing loads and deficits has responded with added and appropriate urgency to
acquire additional low-cost, reliable sources of generation and capacity, as evidenced by
the Company's consecutive requests to acquire resources to be online in 2023,2 2024,3
2025,4 2026,5 2027,6 and 2028.7 Utilizing the most up-to-date load and resource inputs a
system reliability assessment was performed, which identified a capacity deficit of 236
MW in 2029, increasing to 352 MW in 2030.
VI. RESOURCE DESCRIPTIONS
12. The bid evaluation process of the project proposals submitted through the
RFP is designed to identify the combination and size of the proposed resources that will
maximize customer benefits while ensuring Idaho Power meets its energy and capacity
needs. Upon conclusion of the approximately 18-month mandated competitive bidding
rule-compliant process, and identification of the need for flexible generation resources,
Idaho Power began investigating alternative resources, including the benchmark bid on
2 Case Nos. IPC-E-22-06 and IPC-E-22-13.
3 Case Nos. IPC-E-23-05 and IPC-E-23-20.
4 Case Nos. IPC-E-22-29 and IPC-E-23-20.
5 Case Nos. IPC-E-24-12, IPC-E-24-16, and IPC-E-24-45.
6Case Nos. IPC-E-24-42, IPC-E-24-46, IPC-E-25-10, and IPC-E-25-27.
Case No. IPC-E-25-29.
APPLICATION - 9

the 2029 final shortlist that identified a transition from the planned battery storage to a
natural gas resource in 2029, the South Hills plant, as well as an alternative gas resource
solution in 2030, the Peregrine plant.
13. The South Hills plant, the benchmark resource formerly known as the Milner
project, will be located in Twin Falls County, Idaho, along the south bank of the Snake
River, and will consist of twelve, fast-ramping, natural gas-fueled reciprocating engines
that are flexible enough to provide up to 222 MW of generation. The plant will be
immediately west of the Company's existing 138-kilovolt substation in Milner, Idaho and
will have a commercial operation date of June 1, 2029. South Hills will use the equipment
suppliers of the similarly designed Bennett Gas Expansion Project, providing technology
consistency between the two resources.
14. The Peregrine plant will be located in the proposed Peregrine Energy
Center, a 160-acre site in Elmore County, Idaho. This site is ideally located near existing
and planned transmission lines, near an existing natural gas pipeline and can easily be
accessed via a public road. Using the H Frame simple cycle combustion turbine
technology, which provides greater flexibility in generation because they can operate in
various conditions, with lower emissions, Peregrine will provide 430 MW of nameplate
generation and will have a commercial operation date of June 1, 2030.
15. After identification of the South Hills and Peregrine gas-fired plants as
potential resource additions, a cost-effectiveness analysis was performed, comparing the
two alternative resources to all remaining feasible 2029 and later final shortlist projects
("feasible 2029 Projects") received through the RFP solicitation. This evaluation was
performed in a manner consistent with the analyses performed to evaluate the RFP bids
APPLICATION - 10

received, commencing with Aurora's Long-Term Capacity Expansion modeling to develop
portfolios to meet the identified capacity needs through the selection of resource options
that are least-cost for a variety of alternative future scenarios while meeting reliability
criteria. Once the portfolios are created, Idaho Power uses Aurora to determine the
operating costs of the portfolios for the 20-year planning timeframe. The results indicated
that as efficient, flexible, dispatchable resources, South Hills and Peregrine offer least-
cost, least-risk resource alternatives to meeting the Company's identified capacity
deficiencies.
VII. CERTIFICATES OF PUBLIC CONVENIENCE AND NECESSITY
16. 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
certificated service territory. Idaho Code §§ 61-302, 61-315, 61-507. The Commission
must assure that the rates Idaho Power charges its customers and that the rules and
regulations by which it provides service are just, reasonable, nondiscriminatory, and non-
preferential. Idaho Code §§ 61-501, 61-502, 61-503, 61-507, 61-508. The Company
must acquire two natural gas-fueled facilities, the South Hills plant, providing up to 222
MW of generation, and the Peregrine plant, providing 430 MW of nameplate generation,
to meet the identified capacity deficits on its system in order to comply with its continuing
obligation to serve customers, and thus is requesting an order from the Commission
affirming that the public convenience and necessity requires the same. The proposed
acquisition represents a cost-effective means of providing adequate and reliable service
to the customers in Idaho Power's certificated service territory. The Commission has the
express authority to order a utility to build new structures, or to upgrade and/or improve
existing plant and structures, in order to secure adequate service or facilities.
APPLICATION - 11

Whenever the commission, after a hearing had upon its own
motion or upon complaint, shall find that additions,
extensions, repairs or improvements to or changes in the
existing plant, scales, equipment, apparatus, facilities or other
physical property of any public utility . . . ought reasonably to
be made, or that a new structure or structures should be
erected, to promote the security or convenience of its
employees or the public, or in any other way to secure
adequate service or facilities, the commission shall make and
serve an order directing such additions, extensions, repairs,
improvements, or changes be made or such structure or
structures be erected in the manner and within the time
specified in said order.
Idaho Code § 61-508.
17. A CPCN or Certificate represents the exercise by the Commission of
foundational authority and principles that are necessary in Idaho's system of permitting
regulated, vertically integrated, public utilities to exist and to provide necessary services
to the public. Certificates have been utilized in various ways from the time that Idaho's
statutory system of public utility regulation was enacted by the Legislature in 1913, Idaho
Code § 61-101, et seq., to the present time. After nearly 100 years of legislative
enactments, Commission orders, and Idaho Supreme Court reviews, the Certificate
remains the embodiment of the Commission's fundamental power and authority to, at the
most basic level, authorize and direct a public utility to serve in the public interest. See
Idaho Power& Light Co. v. Blomquist et al., 26 Idaho 222, 141 P.1083 (1914); Idaho Op.
Atty. Gen. No. 87-2, 1987 WL 247587 (Idaho A.G.).
18. In the broadest sense, a Certificate allows a company that meets the
definition of a "public utility" pursuant to Idaho Code § 61-129 to exclusively provide its
service to the public in a specified geographic region, its service territory. It is a codified
part of the "regulatory compact" whereby the utility takes on the exclusive obligation/right
to serve all those requesting service within its service territory and, correspondingly,
submits itself to the rate and service quality regulation of the Commission. In a more literal
APPLICATION - 12

sense, a Certificate from the Commission is required for the construction or extension of
a line, plant, or system by any street, railroad, gas, electrical, telephone, or water
corporation. Idaho Code § 61-526. § 61-526 also provides that "if public convenience
and necessity does not require or will require such construction or extension [of a line,
plant, or system] the commission . . . may, after hearing, make such order and prescribe
such terms and conditions for the locating or type of line, plant or system affected as to it
may seem just and reasonable . . . ." A CPCN is required for the utility to construct a new
generation resource or plant but is not required to increase the capacity of existing
generating facilities. Id.
VIII. AFUDC ACCRUAL FOR THE SOUTH HILLS AND PEREGRINE PLANTS
19. Idaho Power records the accumulation of all costs associated with the
construction of an asset, including the cost of financing the construction expenditures, or
AFUDC, in Federal Energy Regulatory Commission ("FERC")Account 107—Construction
Work in Progress. When the plant is completed and placed in service, the total cost of the
plant, including AFUDC, is moved to FERC Account 101 — Electric Plant-in-Service,
placing the asset in rate base. The Company typically commences accrual of AFUDC as
soon as funds are expended and committed to a construction project, which, for
generation resources, has typically occurred subsequent to the request for a CPCN.
20. Based on industry demand for long-lead materials, and to ensure
commercial operation dates are met, the Company has been incurring capital
expenditures associated with resource procurements prior to filing a request for a CPCN.
In order to secure a position in the queue to purchase the turbine for Peregrine, Idaho
Power was required to make a down payment in June 2025. In addition, a payment for
the reciprocating engines for South Hills will be made in the next two months. These down
APPLICATION - 13

payments are necessary to ensure the plants will be operational in time to meet the
identified capacity needs.
21. A down payment for materials is evidence that capital expenditures are
being incurred and the procurement is necessary to begin construction of the project,
which aligns with FERC's guidance on the commencement of AFUDC accrual. However,
because Idaho Power will incur costs associated with resource procurements prior to
receiving a CPCN, the Company is requesting the Commission acknowledge it is
appropriate to begin the accrual of AFUDC once the South Hills and Peregrine had been
deemed viable and expenditures associated with the resource procurements have been
incurred. This treatment would recognize the required upfront investments made by the
Company in pursuit of cost-effective, necessary resources to safely and reliably serve
customers.
IX. RATEMAKING TREATMENT FOR SOUTH HILLS AND PEREGRINE
22. Idaho Power is not requesting binding ratemaking treatment for the South
Hills or Peregrine plants in this case. The Company's request in this case is that the
Commission find Idaho Power has met the requirements of Idaho Code § 61-526 and
issue an order granting a CPCN for South Hills, providing up to 222 MW of natural gas-
fueled generation, and for Peregrine, a natural gas-fueled facility providing 430 MW of
nameplate generation, both of which are necessary to meet the identified capacity
deficiencies in 2029 and beyond. The Company will make a future filing to address the
cost recovery associated with these plants.
X. FINANCING THE SOUTH HILLS AND PEREGRINE PLANTS
23. Idaho Power maintains investment grade credit ratings with Standard &
Poor's Ratings Services and Moody's Investors Service, with a long-term issuer rating of
BBB and Baal, respectively. The Company maintains ready access to the capital markets
APPLICATION - 14

and to instruments providing for its liquidity. Idaho Power has a $400 million revolving
credit facility with its banking syndicate, which may be increased to $600 million under
specified conditions, which matures on December 6, 2030. The Company has an option
to request two additional one-year extension of the agreement, subject to certain
conditions. Idaho Power completed a successful $350 million first mortgage bond offering
in February 2026 under existing regulatory authority, all of which was held in cash and
liquid short-term investments as of March 4, 2026. In the second quarter of 2026, Idaho
Power anticipates requesting approval from the Commission for the ability to issue up to
$1.35 billion in aggregate principal amount of debt securities. The Company also has
access to commercial paper markets, as well as a balance of cash and investments on
its balance sheet.
24. Additionally, Idaho Power has access to capital and credit outside of
existing mechanisms and instruments, such as through term loans, letter of credit, and
other instruments. IDACORP sold an additional 6,434,350 shares of common stock on
various forward sale agreements between November 2024 and May 2025. The
approximate cash value remaining on the forward sale agreements, if settled for
IDACORP shares, is $611 million. The Company intends to finance the South Hills and
Peregrine plants with a combination of available cash and operating cash flow, available
credit facilities and borrowing and debt issuances, and future equity infusions by
IDACORP.
XI. COMMUNICATIONS AND SERVICE OF PLEADINGS
25. Communications and service of pleadings with reference to this Application
should be sent to the following:
APPLICATION - 15

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
dwalkerCcD,idahopower.com ttatumCcDidahopower.com
dockets idaho power.com caschenbrenner(cD_idahopower.com
XII. MODIFIED PROCEDURE
26. 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.
XIII. REQUEST FOR RELIEF
Idaho Power respectfully requests that the Commission issue an order (1) granting
a CPCN for South Hills, a cost-effective natural gas-fueled facility providing up to 222 MW
of nameplate generation to meet an identified capacity deficit in 2029, (2) granting a
CPCN for Peregrine, a cost-effective natural gas-fueled facility providing 430 MW of
nameplate generation to meet an identified capacity deficit in 2030, and (3) confirmation
of the Company's application of accrual ofAFUDC for the South Hills and Peregrine plants
to coincide with initial procurement activities for the natural gas-fueled facilities.
DATED at Boise, Idaho this 10'" day of March 2026.
DONOVAN E. WALKER
Attorney for Idaho Power Company
APPLICATION - 16