20260408Staff Comments.pdf

RECEIVED
April 08, 2026
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
Attorney for the Commission Staff
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 )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney General,
submits the following comments.
BACKGROUND
On February 20, 2026, Idaho Power Company ("Company") applied to the Commission
requesting approval of the Company's draft 2032 All-Source Request for Proposals ("RFP") for
Peak Capacity&Energy Resources ("2032 RFP") ("Application").
On February 25, 2026, the Idaho Irrigation Pumpers Association, Inc. petitioned to
intervene in the case. On February 27, 2026, the Northwest & Intermountain Power Producers
Coalition("NIPPC")petitioned to intervene. Due to the Company's request for a quick decision,
NIPPC contacted the other parties to propose a Modified Procedure schedule that included a cross-
reply comment deadline after a public comment deadline and before a Company reply deadline.
After the schedule was tentatively established,Boise City petitioned to intervene on March
5, 2026. Micron petitioned to intervene on March 23, 2026.
STAFF COMMENTS 1 APRIL 8, 2026

The 2032 RFP is subject to the Commission's Procedure for Soliciting Large-Supply-Side
Resources ("RFP Procedure"), detailed in Order No. 36898.1
The Company states that recent regulatory filings for resource procurement have included
system reliability assessments updated from the 2025 integrated resource plan("IRP"),identifying
an incremental perfect capacity deficit of at least 200 megawatts ("MW")in 2031 and 2032.2 The
2032 RFP seeks bids from all resource types with a commercial operation date between April 1,
2031, and May 31, 2032.3
The Company proposes identifying an initial shortlist of bids based on a screening process
that includes a price and non-price evaluation.4 The Company would then use modeling tools from
its IRP to identify the least-cost, least-risk portfolio from the initial shortlist.5 Next,the Company
would perform a reliability assessment and additional risk analysis of the selected portfolio to
develop the final shortlist prior to a contract negotiation period.6
The Company requests Commission approval of the 2032 RFP by April 24, 2026, to
provide sufficient time for bid submission and evaluation.7
STAFF ANALYSIS
Staff believes that the Company has an ongoing need for new resources and therefore it is
appropriate for the Company to issue a new all-source RFP. Staff agrees that the proposed 2032
RFP is open to all resource types and that the proposed selection process is generally reasonable;
however, Staff believes several selection process details should be modified. Staff recommends
the Commission approve the 2032 RFP solicitation and resource selection process with the
following changes:
1. Disallow an imputed debt cost adder to third-party owned bids;
2. Direct the Company to declare its plan to bifurcate the bids into two different
competitive groups, and to clarify that runner-up bids from the 2031 group will be
carried over to compete again with resources included in the 2032 group; and
'Application at 2.
z Id. at 2-3.
'Id. at 5.
4 Id.
5 Id. at 6.
6 Id. at 6-7.
7 Id. at 7.
STAFF COMMENTS 2 APRIL 8, 2026

3. Direct the Company to accommodate a Staff review of the selection and negotiation
process while it is ongoing.
Details of Staff s justification for its recommendations are discussed below.
The Company Needs Additional Resources
The Company's primary justification for issuing its RFP is based on the 2025 IRP forecast
that the annual peak load will increase from 3,934 MW to 4,949 MW between 2026 and 2031, an
increase of approximately 26 percent.$ This load growth results in "a capacity deficiency
beginning in 2027 and generally growing through the entire 20-year planning period."9 To resolve
the Company's capacity deficiency,the 2025 IRP Preferred Portfolio called for the addition of 450
MW of new gas, 1,345 MW of solar, 700 MW of wind, and 705 MW of battery storage by the year
2032.10 Although this particular resource mix is not binding, the important takeaway is that the
Company must acquire approximately 3,000 MW of new resources by 2032.
To meet the near-term needs,the Company has been negotiating with developers who were
finalists from the 2028 All-Source RFP. These acquisitions are in various stages of approval and
development. As each new resource is negotiated, or new load is added, the Company has been
updating their 2025 IRP deficit analysis." The most recent analysis has "shown an incremental
perfect capacity need of at least 200 MW in 2031 and 2032 with a greater need likely in 2032."12
Staff agrees with the Company's practice of refreshing the analysis and that a capacity deficit of
at least 200 MW exists in 2031 and 2032. Therefore, Staff believes it is reasonable to issue an
RFP to procure additional resources.
The RFP Allows All Feasible Resource Types
Staff believes that the proposed RFP meets the intent of Guiding Principle One of the
Commission's RFP Procedure, which states:
The solicitation should issue a Request for Proposal ("RFP") that maximizes
competition between bidders and is resource-agnostic, soliciting bids from all
feasible resource types (e.g., with respect to technology, fuel type, resource size,
s 2025 IRP,Appendix C at 17.
9 Application at 2.
io 2025 IRP,Appendix C at 43.
Hackett Direct at 4.
12 Id.
STAFF COMMENTS 3 APRIL 8, 2026

ownership arrangements,etc.),and with sufficient lead time that allows all potential
bidders to meet the date when resources are needed. (emphasis added)
Staff reviewed the proposed 2032 RFP and confirmed that it is open to both market-based and
resource-based proposals, all types of resource technologies, and all types of ownership
arrangements.13
However,Guiding Principle One also specifies that the solicitation provide"sufficient lead
time that allows all potential bidders to meet the date when resources are needed." Staff believes
that the Company is making improvements to provide more lead time, but more lead time is still
needed. The previous 2028 RFP was released to bidders on August 16, 2024, with a target early
commercial operation date("COD")of April 1,2028, a time window of approximately 3.6 years.14
This 2032 RFP was released in draft form in February 2026 and has a target early COD of May
31,2031,a time window of approximately 5.3 years.15 For bidders who target the secondary COD
in this solicitation (May 31, 2032), the lead time is approximately 6.3 years.
In concurrent case IPC-E-26-04,Company witness Richins explains how supply-chain lead
times have increased dramatically for gas-powered generation equipment, forcing the Company to
place orders in 2025 for reciprocating engines and simple cycle combustion turbines to be
operational in 2029 and 2030, respectively.16 Richins also adds "there were no combined cycle
combustion turbines available to meet a June 1, 2030, in-service date."17 Accordingly, Staff
believes a six-to-eight-year lead time is necessary to allow the longest lead-time resources to be
fairly considered. Staff suggests that the Company consider a 2034 RFP solicitation within the
current calendar year.
The Selection Process
Staff carefully reviewed the Company's proposed selection process relative to the guiding
principles included in the Commission's RFP Procedure and believes that it meets the intent of
Guiding Principles Two and Three of the Commission's RFP Procedure, with three exceptions.
13 Exhibit No. 1,Sections 3.1,3.2 at 10-12.
"Case No.IPC-E-25-27,Hackett Direct at I I-12.
is Hackett Direct at 8.
i6 Case No.IPC-E-26-04,Richins Direct at 8-9.
17 Id.at 9.
STAFF COMMENTS 4 APRIL 8, 2026

Principle Two states that"the RFP selection process should be designed to select least-cost
least-risk resources that satisfy the system need." Principle Three states that "the RFP and
selection process should ensure competition, transparency, confidentiality, and fairness through
all stages of the procurement process."
In his testimony, Company witness Hackett divided the selection process into three parts:
the RFP announcement plan, the bid submittal process, and the bid evaluation process.18 Staff
believes the RFP announcement plan and the bid submittal process are reasonable and comply
with the Commission's intent. Regarding the bid evaluation process, Staff identified three primary
areas of concern:
1. The inclusion of a cost adder for imputed debt;
2. The lack of clarity about bifurcating bid groups; and
3. The lack of an independent evaluator.
Staff discusses each of its concerns in the sections below.
Imputed Debt
In its draft RFP,the Company proposes to include an imputed debt cost adder to each third-
parry owned asset, which would affect the comparative evaluation of resource bids.19 The
proposed cost estimation method would typically add approximately 17 percent to the cost of third-
party owned assets.20 Regardless of the magnitude of the cost adder, Staff believes that in
principle,the inclusion of this adder is not appropriate in the economic evaluation of resource bids
for the following reasons:
1. A change in the Company's credit rating and cost of debt due to the amount of imputed
debt is uncertain due to many other factors involved in determining the Company's credit
rating.
2. The Company monetarily accounts for imputed debt risk but does not monetarily account
for comparable risks associated with Company-owned resources.
3. Imputed debt is not an actual cost incurred by the utility.
4. Including imputed debt as an adder does not reflect rate-relevant cost differences.
'$Hackett Direct at 8,12,19.
i9 Exhibit No. 1, Section 7.2 at 26.
20 The percent markup depends on the duration of the contract and the assumed debt recovery risk factor. Staff
determined this value by analyzing bid cost worksheets from Case No.IPC-E-25-29.
STAFF COMMENTS 5 APRIL 8, 2026

5. The amount of the adder is estimated and is not known and measurable for ratemaking
purposes.
Staff recommends that the Commission disallow imputed debt adjustments for the
evaluation of least-cost resource alternatives in the RFP. Staff notes that other Idaho utilities have
not included imputed debt cost adders in comparable RFP processes, and therefore inclusion of
such an adder in this case represents a departure from typical practice. As an economic regulator,
the Commission's analysis focuses on determining reasonable, least-cost outcomes and
establishing just and reasonable rates, consistent with its statutory obligation under Idaho Code
Title 61.
Imputed debt, as applied by credit rating agencies such as Moody's Investors Service,
Standard & Poor's Global Ratings, and other agencies, is a financial metric used to evaluate a
utility's credit profile. Credit ratings are generally forward-looking assessments of a company's
ability to meet its financial obligations over time and are used by investors and lenders to evaluate
credit risk. Credit rating agencies generally consider both quantitative factors, such as financial
metrics that measure profitability, leverage, cash flow adequacy, and liquidity, as well as
qualitative factors, such as competitive position, industry dynamics, geographic diversification,
regulatory environment, and management effectiveness. These agencies may treat certain long-
term contractual obligations, including power purchase agreements ("PPAs") and battery storage
agreements (`BSAs"), as debt-like based on their established methodologies. However, these
assessments are forward-looking, are not tied to Commission approval, and are not directly used
to establish rates. As a result, attributing a specific cost impact to imputed debt within the RFP
introduces assumptions that cannot be isolated, quantified, or verified within the evaluation.
Staffs analysis indicates that credit rating outcomes are influenced by multiple factors,
including financial policies, overall business risk, and regulatory environment. Accordingly,
isolating the impact of a specific resource decision on imputed debt introduces additional
uncertainty into the analysis. Imputed debt places emphasis on financial risk associated with
potential rating changes,while not reflecting corresponding risks associated with Company-owned
resources or execution risks related to third-parry resources, such as PPAs or BSAs. The
development risks associated with Company-owned resources may include,but are not limited to,
stranded asset risk,regulatory risk, fuel cost risk(for resources requiring fuel inputs and resources
that are priced on a $/megawatt-hour basis), compliance costs associated with environmental
STAFF COMMENTS 6 APRIL 8, 2026

requirements, construction cost risk, and other project-specific execution risks. These risks are
inherent to Company-owned resource development and are not reflected through a comparable
adjustment in the Company's evaluation, resulting in an inconsistent treatment of risk across
resource types.
Imputed debt is not an actual cost incurred by the utility. Additionally,the application and
magnitude of imputed debt may vary across rating agencies and over time. As a result,
incorporating imputed debt into a least-cost analysis would introduce assumptions that are not
directly measurable or verifiable within the ratemaking framework. As such, imputed debt does
not represent a direct cost that can be compared across resource alternatives in a least-cost
framework.
Rating agency treatment of contractual obligations may occur prior to, or independent of,
Commission review and approval. Therefore, such treatment may not reflect resources that are
ultimately determined to be prudent or used and useful. Including imputed debt in the evaluation
of resource alternatives could affect the comparison of PPAs and BSAs to Company-owned
resources in a manner that does not reflect rate-relevant cost differences. Inclusion of an imputed
debt cost adder may also reduce transparency and consistency in the evaluation of resource bids,
as the adder relies on assumptions that are not applied uniformly across all resource types. Least-
cost analysis is intended to compare costs that are directly relevant to customers, and inclusion of
imputed debt introduces a factor that does not reflect such costs. Accordingly, inclusion of the
adder introduces additional uncertainty into the evaluation that cannot be validated through the
record.
Staff concludes that an imputed debt cost adder is not a reasonable component of least-cost
analysis and is more appropriately considered, if at all, in broader financial or cost-of-capital
discussions. Consistent with Idaho regulatory principles, the Commission's role is to determine
reasonable, prudently incurred, and rate-relevant costs for ratemaking purposes. Accordingly,
Staff recommends that the Commission not allow the inclusion of an imputed debt cost adder in
the evaluation of third-party resource bids.
Lack of Clarity about Bifurcating Bid Groups
Staff believes the 2032 RFP does not explain to bidders that bids will be bifurcated into
two groups which will compete separately. The Company applied this practice in the 2026 and
STAFF COMMENTS 7 APRIL 8, 2026

2028 RFPs and the Company confirmed that it again intends to bifurcate the bids.21 According to
the Company, the first competitive group will include bids with CODS on or before May 31, 2031
("2031 Bid Group").22 The second competitive group will include bids with CODS on or before
May 31,2032 ("2032 Bid Group").23 The Company points out that Table 3.1 and Table 3.2 of the
RFP define the two delivery windows.24 However, Staff believes that these delivery windows only
imply two bidding groups; they do not explicitly explain the bifurcation process to bidders. Staff
recommends that the Commission order the Company to notify potential bidders of an update to
the RFP solicitation that includes a detailed explanation of the bifurcation process in Section 7
(Bid Evaluation,Negotiation and Approval) of the RFP solicitation.
Furthermore, Staff believes there is ambiguity regarding what the Company will do with
unsuccessful bids from the 2031 Bid Group and that it is conceivable that runner-up bids from the
2031 Bid Group may be more cost-effective than the best bids from the 2032 Bid Group. To
ensure the least-cost resources are considered, Staff recommends that runner-up bids from the 2031
Bid Group should be automatically moved for competition in the 2032 Bid Group and that this
change also be explained in Section 7 of the updated RFP solicitation.
Lack of an Independent Evaluator
Historically, the Company has been required to obtain a third-parry independent evaluator
("IE")by the Oregon Public Utility Commission ("OPUC"). Once hired,the IE would review the
bids, cross-check scoring, and compare their results with the Company's. They would also review
the Company's cost calculations, analyze each step of the selection process, and provide detailed
reports of their findings to assure interested parties that the Company is fairly assessing each bid.
However, for this RFP, the Company has filed OPUC Case No. UM 2434, asking the
OPUC to waive the requirement for an IE. The primary justification provided by the Company is
the operational urgency to compress the acquisition schedule.25 A second justification is the
pending agreement for the Company to sell its Oregon assets,thereby ending OPUC jurisdiction.26
This waiver request was filed on February 20, 2026, and is still pending.
21 Company Response to Staff Production Request No. 11.
22 Id.
23 Id.
24 Id.
21 OPUC Case No.UM 2434,Application at 1.
26 Id. at 9.
STAFF COMMENTS 8 APRIL 8, 2026

The Commission's RFP Procedure declares that the Commission may, as part of this
review, require an IE to participate. Staff believes IE oversight of the selection process is a
beneficial practice but is also mindful of the schedule delay that could occur if the Commission
were to require one. If the Commission believes that the cost of a schedule delay by the inclusion
of an IE outweighs the benefits of including one, Staff proposes providing direct oversight of the
process as an alternative. Staff s oversight would be more limited than what an IE usually
provides. Oversight would be limited to reviews scheduled prior to key decision points in the
process, requiring the Company to present proposals explaining its decision-making process, and
for Staff to review the proposals based on the Company's adherence to the Commission's
guidelines and orders and other factors that can affect prudent decisions. Also, Staff is not
proposing to produce a final report typically produced by an IE,unless ordered by the Commission,
although anomalies would be documented for potential inclusion during future prudence reviews
when the Company files resource approvals. The Company has indicated its willingness"to work
with Staff throughout the 2032 RFP evaluation process."27
Assuming the Commission will determine that additional oversight is needed, Staff highly
encourages the Company to include timelines in its reply comments for both alternatives relative
to its RFP schedule to assist the Commission in selecting an option. These timelines include: (1)
a best-case schedule to acquire the services of an IE used in previous RFPs, and (2) a schedule
when Staff would engage with the Company prior to key decision points.
Agreement to a Company-Proposed Change
On March 26, 2026, the Company filed a notice to the parties of a "proposed revision to
the draft 2032 Request for Proposals . . . ." The revision proposes to relax the requirement for
bidders to have requested Network Resource Interconnection Service. Instead, the RFP will only
require that bidders need to submit a generator interconnection request. Staff believes this is
reasonable and supports the change.
STAFF RECOMMENDATION
Staff recommends the Commission approve the draft RFP with the following changes:
1. Disallow an imputed debt cost adder for third-party resource bids;
21 Company Response to Staff Production Request No. 12.
STAFF COMMENTS 9 APRIL 8, 2026

2. Direct the Company to declare its plan to bifurcate the bids into two COD groups, and
to clarify that runner-up bids from the 2031 Bid Group will automatically be forwarded
to compete in the 2032 Bid Group; and
3. Direct the Company to accommodate a Staff review of the selection and negotiation
process while it is ongoing.
Respectfully submitted this 8th day of April 2026.
Jeffrey' . Loll
Deputy Attorney General
Technical Staff. Matt Suess, Steven Verdieck,Kimberly Loskot,Karla Ducharme
I:\Utility\UMISC\COMMENTS\IPC-E-26-03 Comments.docx
STAFF COMMENTS 10 APRIL 8, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8TH DAY OF APRIL 2026, SERVED THE
FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. IPC-E-26-03,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E. WALKER, LEAD COUNSEL TIM TATUM
IPC DOCKETS CONNIE ASCHENBRENNER
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: dwalkergidahopower.com E-MAIL:
docketskidahopower.com ttatumkidahopower.com
caschenbrennergidahop ower.com
Intervenor: Intervenor:
Idaho Irrigation Pumpers Association Northwest Intermountain Power Producers
Coalition
Eric L. Olsen
Echo Hawk& Olsen, PLLC Gregory M. Adams
P.O. Box 6119 Richardson Adams, PLLC
505 Pershing Ave., Ste. 100 515 N. 271h Street
Pocatello, ID 83205 Boise, ID 83702
elogechohawk.com greggrichardsonadams.com
taysha(&echohawk.com
Irion Sanger
Lance Kaufman, Ph.D. Sanger Greene, PC
Deborah Glosser, Ph.D. 4031 SE Hawthorne Blvd.
2623 NW Bluebell Place Portland, OR 97214
Corvallis, OR 97330 irion(ksanger-law.com
lancegae isg insi hg t.com
deborah. log_sser&gmail.com Spencer Gray
Executive Director,NIPPC
P.O. Box 504
Mercer Island, WA 98040
sgrayknippc.org
Intervenor:
Boise City
Ed Jewell Katie O'Neil
Deputy City Attorney Energy Program Manager
Boise City Attorney's Office Boise City Dept. of Public Works
150 N. Capitol Blvd. 150 N. Capitol Blvd.
P.O. Box 500 P.O. Box 500
Boise, ID 83701-0500 Boise, ID 83701-0500
boisecityattomeykcityofboise.org koneilkcityofboise.org
eiewell(acityofboise.org
STAFF COMMENTS 11 APRIL 8, 2026

Intervenor:
Micron
Austin Rueschhoff
Thorvald A. Nelson
Richard A. Arnett
Holland& Hart, LLP
555 17th St., Ste. 3200
Denver, CO 80202
darueschhoff 2hollandhart.com
tnelson(a,hollandhart.com
raamettkhollandhart.com
acleeka hollandhart.com
tlfrielkhollandhart.com
Kink, -ftAVkh4.
Keri J. Aawker, Legal Assistant
STAFF COMMENTS 12 APRIL 8, 2026