20260313Application.pdf

4N6 010AW POWER.
LISA LANCE
Corporate Counsel RECEIVED
I lance(aD_idahopower.com
MARCH 13, 2026
IDAHO PUBLIC
March 13, 2026 UTILITIES COMMISSION
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-26-05
In the Matter of the Application of Idaho Power Company for a Determination
of 2025 Demand-Side Management Expenses as Prudently Incurred
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Application and the Direct
Testimony of Quentin Nesbitt in support of the Application in the above-entitled matter. A
Word version of the testimony will also be sent in an email for the convenience of the
Reporter.
In addition, six (6) copies of the Application, Direct Testimony, and the DSM 2025
Annual Report, along with an unbound copy of each, will be hand delivered to the
Commission.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Lisa Lance
LCL:cd
Enclosures
P.O.Box 70(83707)
1221 W.Idaho St.
Boise,ID 83702

LISA C. LANCE (ISB No. 6241)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
IlanceCcDidahopower.com
mgoicoecheaal lenCo�_idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-26-05
DETERMINATION OF 2025 DEMAND-SIDE )
MANAGEMENT EXPENSES AS ) APPLICATION
PRUDENTLY INCURRED. )
Idaho Power Company ("Idaho Power" or "Company"), in accordance with
Commission Rule of Procedure' 52, et. seq., and Order No. 29419,2 submits its Demand-
Side Management 2025 Annual Report ("DSM 2025 Annual Report") and makes
Application to the Idaho Public Utilities Commission ("Commission") for an order
designating Idaho Power's expenditures of$28,936,689 in Idaho Energy Efficiency Rider
("Rider") funds and $8,939,724 of demand response program incentives funded through
base rates and tracked annually through the Power Cost Adjustment ("PCA") mechanism,
Hereinafter cited as RP.
2 In the Matter of the Petition Filed by Idaho Power Company for Modification to Two Prior Orders to
Permit Consolidation of the Company's Conservation and Demand Side Management(DSM) Reporting
Requirement into a Single Consolidated Report, Case No. IPC-E-03-19, Order No. 29419, p. 2 (Jan. 14,
2004).
APPLICATION - 1

for a total of $37,876,413, as prudently incurred demand-side management ("DSM")
expenses.
In support of this Application, Idaho Power offers the Direct Testimony of Quentin
Nesbitt ("Nesbitt Testimony") filed contemporaneously herewith and represents as
follows:
I. INTRODUCTION
1. It is well-established that the Commission considers the promotion of cost
effective energy efficiency and demand-side management an integral part of least-cost
electric service:3 "The Commission has consistently stated that cost-effective DSM
programs are in the public interest and has admonished electric utilities operating in the
state of Idaho to develop and implement DSM programs in order to promote energy
efficiency."4
2. Like the Commission, Idaho Power believes that energy efficiency and
demand response are an important and necessary part of a balanced approach to
meeting system energy needs and endeavors to provide customers with programs and
knowledge through its DSM programs to help them use electricity wisely. The Company's
energy efficiency portfolio includes a broad array of programs available to its customers
in energy efficiency, demand response, and education.
3. Energy efficiency programs are available to all customer segments in Idaho
Power's service area and focus on reducing energy use by identifying homes, buildings,
3 See, e.g. In the Matter of the Investigation of Financial Disincentives to Investment in Energy Efficiency
by Idaho Power Company, Case No. IPC-E-04-15, Order No. 30267, p. 13 (Mar. 12, 2007).
4 In the Matter of the Idaho Power Company's Application for an Order Designating the Energy Efficiency
Rider Funds Spent by the Company During 2008-2009 as Prudently Incurred Expenses, Case No. I PC-E-
10-09, Order No. 32113, p. 8 (Nov. 16, 2010).
APPLICATION - 2

equipment, or components for which an energy-efficient design, replacement, or repair
can achieve energy savings. Some energy efficiency programs include behavioral
components. Savings from energy efficiency programs are measured on a kilowatt-hour
or megawatt hour ("MWh") basis.
4. The goal of Idaho Power's demand response programs is to minimize or
delay the need to build new supply-side peaking resources, and its demand response
portfolio currently has a capacity of more than 8.6 percent of the Company's all-time
system peak load available to respond to a system peak load event during the summer.
In 2025, the Company utilized all or portions of its three demand response programs: A/C
Cool Credit, Flex Peak Program, and Irrigation Peak Rewards. Demand response is
measured both by the actual demand reduction in megawatts ("MW") achieved during
events, as well as the potential demand reduction if all programs were used at full
capacity.
5. The Company strives to offer DSM programs that provide value to its
customers and increase the DSM savings available to the Company. In 2025, Idaho
Power achieved 17.5 average megawatts ("aMW") of incremental energy efficiency
savings, including estimated energy efficiency market transformation savings through
Northwest Energy Efficiency Alliance ("NEEX) initiatives, which represents enough
energy to power approximately 14,000 average homes in Idaho Power's service area for
one year. Nesbitt Testimony at 8-9. From its three demand response programs, Idaho
Power achieved a total non-coincident demand reduction of 161 MW from an available
capacity of 328 MW during the 2025 program season. Nesbitt Testimony at 10-11 .
6. In addition to the education customers get through participation in specific
APPLICATION - 3

incentive programs for energy efficiency, Idaho Power educates customers on energy
efficiency in many other ways including presentations, trainings, workshops, and trade
shows. DSM 2025 Annual Report at 11-12. The Company sponsors significant customer
educational outreach and awareness activities, and focuses marketing efforts on saving
energy—none of which are quantified or claimed as part of Idaho Power's annual DSM
savings, but are likely to result in energy savings that accrue to Idaho Power's electrical
system over time. Nesbitt Testimony at 10.
7. As the Commission previously noted, "DSM benefits depend on constantly
evaluating opportunities and identifying ways to improve available programs."5 To this
end, Idaho Power devotes significant resources to maintain and improve its energy
efficiency and demand response programs and actively works to both improve the cost
effectiveness of existing DSM programs and explore the addition of new DSM offerings
for customers.
8. Idaho Power utilizes DSM funds collected from customers to support the
pursuit of cost-effective energy efficiency and demand response programs, with the
limited exception of certain policy considerations. This goal is achieved by applying a
multi-step process. Prior to the actual implementation of energy efficiency or demand
response programs, Idaho Power performs a preliminary cost-effectiveness analysis to
assess whether a potential program design or measure will be cost-effective from the
perspective of customers as well as the Company. Idaho Power measures cost-
effectiveness under three tests: the Utility Cost Test ("UCT"), the Total Resource Cost
("TRC") test, and the Participant Cost Test ("PCT"). A review of each test allows for an
5 In the Matter of the Application of Idaho Power Company for a Determination of 2020 Demand-Side
Management Expenses as Prudently Incurred, Case No. IPC-E-21-04, Order No. 35270, p. 8 (Dec. 27,
2021).
APPLICATION - 4

economic assessment of the life-cycle costs and benefits of a DSM investment from the
perspective of DSM program participants, Idaho Power, and non-participating customers.
Nesbitt Testimony at 16-18.
II. CONTENTS OF THE DSM 2025 ANNUAL REPORT
9. Idaho Power's DSM 2025 Annual Report, which is included as Attachment
1 to this Application, is submitted in compliance with the reporting requirement set forth
in Commission Order No. 29419 in Case No. IPC-E-03-19. The Company's actions, as
detailed in the DSM 2025 Annual Report, demonstrate the conscientious work Idaho
Power undertook to expend funds wisely to further DSM activities over the course of the
last year.
10. The DSM 2025 Annual Report consists of the main document (with
appendices) and two supplements. The main report provides details for each of the
Company's DSM programs including program descriptions, 2025 performance results,
program activities, expenditures and cost-effectiveness ratios, marketing efforts,
customer satisfaction, and evaluation results if applicable. Supplement 1: Cost-
Effectiveness ("Supplement 1") to the DSM 2025 Annual Report provides detailed cost-
effectiveness data for each program and includes a table that reports expenses by
funding source and cost category. Supplement 2:Evaluation ("Supplement 2")to the DSM
2025 Annual Report includes an evaluation and research summary, the evaluation plan,
Energy Efficiency Advisory Group ("EEAG") meeting notes, links to NEEA evaluations,
copies of Integrated Design Lab reports, research and survey reports, evaluation reports,
and other reports related to DSM activities. Each of these evaluations reflects Idaho
Power's continued commitment to review and evaluate program value and cost
effectiveness on an ongoing basis.
APPLICATION - 5

III. 2025 DSM PROGRAM PERFORMANCE
11. In 2025, Idaho Power offered its customers a wide range of energy
efficiency and demand response programs, participated in market transformation efforts
through NEEA, and offered several educational initiatives and other activities. Table 1 on
page 4 of the DSM 2025 Annual Report contains a list of Idaho Power's DSM programs
by sector, operational type, and location. The table illustrates the broad suite of programs
that Idaho Power offers to its customers in energy efficiency and demand response.
12. As explained in more detail in the Nesbitt Testimony filed
contemporaneously with this Application, Idaho Power's annual energy savings combined
with NEEA estimated annual energy savings resulted in an incremental energy efficiency
savings of 17.5 aMW, which exceeded the economic technical achievable potential
included in Idaho Power's 2023 IRP of 12.8 aMW. Nesbitt Testimony at 8-9.
13. On a system-wide basis, Idaho Power achieved 153,099 MWh of
incremental annual energy efficiency savings in 2025, which includes 125,392 MWh from
Idaho Power's energy efficiency programs and an estimated 27,707 MWh6 of energy
efficiency market transformation savings through NEEA initiatives. Nesbitt Testimony at
7-8. The 2025 savings results consisted of 28,371 MWh from the residential sector,
91,620 MWh from the commercial/industrial sector, and 5,400 MWh from the irrigation
sector. DSM 2025 Annual Report at 6, Table 2.
14. In the 2025 program year, several of the Company's DSM programs
outperformed their savings and participation as compared to the 2024 program year.
6 Because Idaho Power will not receive final 2025 savings from NEEA until the second quarter 2026, the
NEEA-attributable savings is an estimate provided to Idaho Power by NEEA.
APPLICATION - 6

Overall energy efficiency portfolio savings increased by 7,689 MWh. The increase in
savings can largely be attributed to the Commercial and Industrial ("C&I") Retrofits
Program and the Residential Home Energy Reports Program. The Retrofits Program
increased its total savings by 7,513 MWh and the Home Energy Reports Program
increased its total savings by 1,911 MWh. Nesbitt Testimony at 9. Appendix 3 of the DSM
2025 Annual Report contains a complete list of program and sector-level savings.
Additionally, the Company engages in significant educational awareness activities and
marketing efforts that are likely to result in energy savings experienced by customers but
are not quantified or claimed as part of Idaho Power's annual savings.
15. Idaho Power's energy efficiency portfolio remained cost-effective as more
fully explained below, resulting in a 1.70 benefit/cost ratio when evaluated from a UCT
perspective, a 1.37 benefit/cost ratio when evaluated from a TRC test perspective, and
1.78 benefit/cost ratio when evaluated from a PCT perspective. Nesbitt Testimony at 6-
7.
16. In addition, Idaho Power successfully operated all three of its demand
response programs in 2025, and the demand response portfolio currently has a capacity
of more than 8.6 percent of the Company's all-time system peak load available to respond
to a system peak load event during the summer. Idaho Power achieved a total non-
coincident demand reduction of 161 MW from a total available capacity of 328 MW during
the 2025 program season. Nesbitt Testimony at 10-11 . The amount of capacity available
for demand response varies based on weather, time of year, and how programs are used
or managed. The maximum potential reduction capacity (328 MW) is based on an
expected maximum realization rate for participants. DSM 2025 Annual Report at 8.
APPLICATION - 7

IV. 2025 DSM EXPENSES AND ADJUSTMENTS
17. Energy efficiency and demand response funding comes from the Idaho and
Oregon Energy Efficiency Riders and Idaho Power base rates. The Rider funds are
collected directly from customers on their monthly bills; the 2025 Idaho Rider was 2.35
percent of base rate revenues pursuant to Order No. 36042. DSM expenses not funded
through the riders are included in Idaho Power's base rates. Idaho demand response
program incentives funded through base rates are tracked through the annual PCA
mechanism.
18. In 2025, the Company's total system-wide expenditures on DSM-related
activities totaled $43,027,141 . DSM 2025 Annual Report at 9-10, Tables 3 and 4. This
figure includes expenditures for Oregon and other operations and maintenance ("O&M")
expenses that are not before the Commission as part of this prudence request. In this
filing, Idaho Power seeks a determination that a total of $37,876,413 were prudently
incurred in 2025 ($28,936,689 in Rider expenses and $8,939,724 in demand response
program incentives). Nesbitt Testimony at 12-13. A summary of the 2025 program
expenditures by program, customer sector, and funding source for which the Company is
seeking a prudence determination is provided as Exhibit No. 1 to the Nesbitt Testimony.
19. The Company strives to ensure DSM expenses are well-documented and
that controls are in place and adjusted as needed to regulate proper payment of incentives
and other costs. As more fully explained in the Nesbitt Testimony and summarized below,
prior to this filing, the Company's internal review process identified three prior-year and
three current-year accounting adjustments that were necessary to accurately account for
the total 2025 DSM expenses for purposes of the prudence determination in this case.
APPLICATION - 8

Nesbitt Testimony at 13-14. Idaho Power has included each of these adjustments in
Exhibit No. 1 to the Nesbitt Testimony.
20. Prior Year Adjustments. The first prior-year adjustment of $5,383 is related
to expenses associated with the Home Energy Audit program that should have been
charged to the Idaho Rider rather than O&M in 2024. The correction to add the expense
to the Idaho Rider was made in 2025 and therefore $5,383 needs to be subtracted from
the 2025 prudence request because it was already deemed prudent by the Commission
in 2024. The second prior-year adjustment of $5,523 is related to expenses associated
with the Rebate Advantage program that should have been charged to the Idaho Rider,
rather than O&M in 2024. The correction to add the expense to the Idaho Rider was made
in 2025 and therefore $5,523 needs to be subtracted from the 2025 prudence request
because it was already deemed prudent by the Commission in 2024. The third prior-year
adjustment of$2,278 is related to expenses associated with the Irrigation Peak Rewards
program that should have been charged to O&M rather than the Idaho Rider in 2024. The
correction to reduce Idaho Rider expenses was made in 2025, and therefore $2,278
needs to be added back to avoid understating the 2025 prudence request. Nesbitt
Testimony at 14-15.
21. Current Year Adjustments. Three current year-end accounting adjustments
for 2025 were identified through Idaho Power's annual review of DSM expenses and the
corrections were made after the 2025 year-end financial books were closed. The first
current-year adjustment results in a reduction of $244 associated with the Home Energy
Audit program where the expenses were initially charged to the Idaho Rider instead of
the Oregon Rider. The second adjustment results in an addition of $346 associated with
APPLICATION - 9

the Residential New Construction program where the expenses were initially charged to
the Oregon Rider instead of the Idaho Rider. The third adjustment in a reduction of $723
associated with the Residential Energy Efficiency program where the expenses were
initially charged to the Idaho Rider instead of the Oregon Rider. Nesbitt Testimony at 15.
V. DSM PROGRAM COST-EFFECTIVENESS
22. The DSM 2025 Annual Report and accompanying Nesbitt Testimony
demonstrate the Company's diligent efforts to use DSM funds collected from customers
to support the pursuit of cost-effective energy efficiency and demand response programs
and substantiate that Idaho Power's DSM expenses were prudently incurred. As reflected
therein, Idaho Power reviews the cost-effectiveness results for each program and
measure on an annual basis to determine whether a program should continue or be
modified so it remains cost-effective on an ongoing basis.
Energy Efficiency Programs
23. To calculate cost-effectiveness, the DSM 2025 Annual Report calculates
cost-effectiveness using benefit/cost methodologies used in previous DSM Annual
Reports, including the UCT, the TRC test, and the PCT. A review of each test allows for
an economic assessment of the lifecycle costs and benefits of a DSM investment from
the perspective of Idaho Power, DSM program participants, and non-participating
customers. Idaho Power calculates cost-effectiveness from the UCT, TRC test, and PCT
perspectives at the program level except for those programs with no customer costs, in
which case the PCT is not applicable. When an existing program or measure is not cost-
effective, Idaho Power works with EEAG to obtain input before making its determination
on continuing, discontinuing, or modifying an offering. Nesbitt Testimony at 16-17. Cost-
APPLICATION - 10

effective test methodologies are described in more detail in Supplement 1 to the DSM
2025 Annual Report.
24. While the Commission continues to assess the prudence of DSM
investments under "the totality of the circumstances," the Commission also believes that
public utilities may "emphasize the UCT—and that test's focus on Company-controlled
benefits and costs—to argue whether programs were cost-effective."7 Thus, the Company
continues to conduct all three benefit/cost methodologies while using the UCT
perspective as its primary test for evaluating program cost-effectiveness.
25. Supplement 1 to the DSM 2025 Annual Report includes detailed results of
the cost-effectiveness tests by program and by measure, showing that the overall DSM
portfolio achieved benefit/cost ratios greater than 1.0 from the perspective of all three
cost-effectiveness tests in 2025. On a portfolio basis, Idaho Power's energy efficiency
programs were found to be cost-effective, passing the UCT, TRC test, and PCT with ratios
of 1.70, 1.37, and 1.78, respectively. Nesbitt Testimony at 19, Table 3 and Exhibit 2.
26. On an individual program basis, 10 of the 13 energy efficiency programs
offered in Idaho for which the Company calculates cost-effectiveness had benefit/cost
ratios greater than 1.0 under the UCT. Nesbitt Testimony at 21. The results of these
calculations, along with measure assumption details and source determination, can be
found in Supplement 1 to the DSM 2025 Annual Report. Idaho Power's cost-effectiveness
test results for 2025 energy efficiency programs determined that certain programs —
Weatherization Assistance for Qualified Customers ("WAQC"); Weatherization Solutions
In the Matter of the Application of Idaho Power Company for a Determination of 2014 Demand-Side
Management Expenditures as Prudently Incurred, Case No. IPC-E-15-06, Order No. 33365, p. 9-10 (Aug.
28, 2015).
APPLICATION - 11

for Eligible Customers ("Solutions"); and Heating & Cooling Efficiency Program ("H&CE");
— were not cost-effective under the UCT in 2025 as more fully discussed below:
Income Qualified Weatherization
27. Two programs that scored less than 1.0 under the UCT were the Company's
WAQC and Solutions. While these programs are not cost-effective under the UCT, Idaho
Power intends to continue providing funding to local Community Action Partnership
agencies to continue offering these programs to its limited-income customers unless the
Commission directs otherwise. Nesbitt Testimony at 22-24. Idaho Power will also
continue to work with EEAG and weatherization managers to identify opportunities that
might improve the cost-effectiveness of these programs.
H&CE
28. In 2025, the H&CE program achieved a UCT of 0.89 and a TRC of 0.17.
The objective of the H&CE program is to provide customers with energy-efficient options
for space heating/cooling and water heating, offering incentives for the purchase and
proper installation of qualified heating and cooling equipment and services. The main
driver of the H&CE program not being cost-effective in 2025 was $69,035 in
administrative expenses from both a process and impact evaluation, representing about
22 percent of total H&CE program administrative expenses for 2025. Without such
evaluation cost, the program would have a UCT and TRC ratio of 1.02 and 0.18,
respectively, which is an improvement from the UCT perspective when compared to 2024.
29. Based on the Company's forecast analysis for 2026, coupled with the
exclusion of the non-recurring evaluation costs, it expects the program to be cost-
effective. If at any time during 2026 the Company no longer expects the program to be
APPLICATION - 12

cost-effective, it would explore changes to improve the cost-effectiveness and discuss
those changes with EEAG. Nesbitt Testimony at 24-25.
Demand Response
30. For 2025, Idaho Power determined the cost-effectiveness of its demand
response programs based on the methodology approved in Order No. 35336 and more
fully described in the Nesbitt Testimony at 25-27. In 2025, the system-wide cost of
operating the three demand response programs was approximately $10.8 million ($9.1
million of incentives and $1 .7 million of other costs). The amounts attributable to the
Idaho-only jurisdiction were $10.5 million ($8.9 million of incentives and $1.6 million of
other costs). All three of the Company's demand response programs, as well as the
demand response portfolio, had a cost per kilowatt less than the 2025 threshold of$64.03
and were therefore cost-effective. Nesbitt Testimony at 27-28.
VI. DSM PROGRAM EVALUATIONS
31. In addition to the annual cost-effectiveness analysis the Company conducts
for each program, the results of which are included in Supplement 1 to the DSM 2025
Annual Report and summarized above, Idaho Power solicits and contracts with
independent third-party consultants to provide program evaluations. The Company
generally conducts impact evaluations every three years, and conducts process
evaluations as needed for relatively new programs or when a program has significant
changes. Supplement 2 to the DSM 2025 Annual Report provides additional information
regarding how Idaho Power evaluates its programs and the final reports for the
evaluations conducted in 2025.
32. Idaho Power uses the results of these evaluations to improve its DSM
programs, compare Company processes to industry best practices, and benchmark
APPLICATION - 13

reported program savings. In 2025, Idaho Power contracted with several third-party
evaluators to conduct impact and process evaluations as follows:
• Impact and process evaluations on the Heating and Cooling Efficiency, New
Construction, Retrofits, A/C Cool Credit, and Irrigation Peak Rewards programs.
• Impact evaluation on the Home Energy Reports Program.
• Evaluation of deemed savings potential for the Home Energy Reports Program.
• Follow up evaluation to the prior impact evaluation on the Residential New
Construction Program.
33. In addition to these third-party evaluations, Idaho Power completed internal
analyses of WAQC, Solutions, A/C Cool Credit, C&I Flex Peak, and Irrigation Peak
Rewards programs. Nesbitt Testimony at 30.
VII. STAKEHOLDER INPUT
34. Idaho Power relies on input from EEAG to provide a customer and public
interest review of energy efficiency and demand response programs and expenses.
EEAG provides input on enhancing existing DSM programs and on implementing new
DSM programs. Currently, EEAG consists of members representing a cross-section of
customers from the residential, industrial, commercial, and irrigation sectors, as well as
representatives for low-income individuals, environmental organizations, state agencies,
the Commission, and Idaho Power. Nesbitt Testimony at 31 .
35. EEAG generally meets quarterly and, when necessary, additional meetings
are held to address special topics. In 2025, the Company held four EEAG meetings, two
in person with a virtual option and two virtually. The Company believes that member
participation and input remained strong during the 2025 EEAG meetings. Specifically,
APPLICATION - 14

Idaho Power worked with EEAG on developing, designing, and marketing several projects
and solicited guidance on a broad range of issues as more fully discussed in the Nesbitt
Testimony on pages 32-36.
VIII. MODIFIED PROCEDURE
36. Idaho Power believes that a technical 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. Idaho Power has, however, contemporaneously filed the Nesbitt Testimony in
support of this Application. The Company stands ready to present testimony supporting
this Application in a technical hearing if the Commission determines such a hearing is
required.
IX. COMMUNICATIONS AND SERVICE OF PLEADINGS
37. Communications and service of pleadings with reference to this Application
should be sent to the following:
Lisa Lance Riley Maloney
Regulatory Dockets Mary Alice Taylor
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
[e-mail] maloney(@Jdahopower.com
dockets(c)_idahopower.com mtaylor(c)_idahopower.com
X. CONCLUSION
38. As described in greater detail above, in 2025, the Company believes that it
successfully achieved prudent cost-effective energy efficiency savings and provided
useful and cost-effective demand response programs as determined by the IRP planning
APPLICATION - 15

process. As such, Idaho Power respectfully requests that the Commission issue an order:
(1) authorizing that this matter be processed by Modified Procedure and (2) designating
Idaho Power's 2025 DSM expenses of $37,876,413 as prudently incurred.
Respectfully submitted this 13th day of March 2026.
LISA C. LANCE
Attorney for Idaho Power Company
APPLICATION - 16