20260409Comment_1.pdf

Good afternoon,
Attached, please find the public comments on behalf of Renewable Northwest, for filing in
the above-referenced docket. Please let me know if you have any questions or if you
encounter any issues with the file.
Thank you,
Dustin Prater
Paralegal
Sanger Greene PC
4031 SE Hawthorne Blvd
Portland, OR 97214
503-451-3518 (tel)
503-334-2235 (fax)
[e-mail]
Pronouns: he/him/his

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-26-03
COMPANY'S APPLICATION FOR )
APPROVAL OF THE 2032 ALL-SOURCE ) COMMENTS OF RENEWABLE
REQUEST FOR PROPOSALS TO ) NORTHWEST
MEET CAPACITY RESOURCE NEEDS IN )
AS EARLY AS 2031. ) April 8, 2026
I. INTRODUCTION AND SUMMARY
Renewable Northwest ("RNW") is grateful for the opportunity to submit these comments
to the Idaho Public Utilities Commission ("IPUC" or "Commission") regarding Idaho Power
Company's ("Idaho Power") application for approval of its Draft 2032 Request for Proposals
("RFP").
Idaho Power filed its RFP application with the Commission on February 20, 2026. On
March 9, the Commission issued Order No. 36960, a combined Notice of Application, Notice of
Intervention Deadline, and Notice of Modified Procedure ("Notice"). The Notice established that
Idaho Power's RFP application would be addressed by Modified Procedure under Commission
Rules 201-204, IDAPA 31.01.201-.204.1 Commission Rule 203 provides that "[a]ny person
affected by the moving party's proposal may file a written protest, support or comment Comments
must state and explain the person's position on the proposal." Commission Rule 043(l)provides
that"written comments in modified procedure ... may be made by a natural person pro se,a partner
in a partnership, an employee or officer of a corporation, or a licensed attorney." The Notice
provides that"[p]ersons interested in filing written comments must do so by April 8, 2026."2
1 Notice at 3.
2 Notice at 3.
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 1

RNW is a regional not-for-profit advocacy organization with members that include
renewable energy,battery storage, and transmission developers as well as advocacy organizations
and consumer advocates. RNW has a long history of participating in regulatory proceedings
regarding utility resource procurements, including rulemakings to establish or modify competitive
bidding rules in Oregon and Washington and utility-specific REP proceedings across the region.
RNW and its members have a shared interest in ensuring that utility procurements are fair and
competitive, and RNW's participation in RFP proceedings reflects that interest. These comments
are offered by an employee of RNW in accordance with Commission Rules 043(1) and 203.
Traditionally, when the Commission applied the Oregon Public Utility Commission's
("Oregon Commission") competitive bidding rules, RNW engaged with Idaho Power RFPs at the
Oregon Commission. Now that the Commission has adopted an Idaho-specific approach to
regulating RFPs3 and Idaho Power has proposed divesting its Oregon service territory, RNW
anticipates continuing its RFP advocacy here with the Commission.
In these comments, RNW highlights several elements of the RFP that need to change to
ensure a competitive RFP that results in a least-cost,least-risk portfolio of resources to serve Idaho
Power's captive customers. RNW does not intend for this list to be exclusive and generally
supports the separate comments filed by the Northwest & Intermountain Power Producers
Coalition("NIPPC")as well. In these comments,RNW specifically recommends that Idaho Power
make the following changes voluntarily or that the Commission direct Idaho Power to:
3 In the Matter of Commission Staffs Application for Approval of an Oversight Process for
the Acquisition of Large Supply-Side Electrical Resources, Case No. GNR-E-25-01,
Order No. 36898 (Jan. 2, 2026).
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 2

• Explicitly call for bids with commercial operation dates ("COD") before January 1,
2031 that can compete with bids with later CODS to allow inclusion of resources
eligible for federal tax credits that will benefit Idaho Power and its customers;
• Engage the services of an Independent Evaluator ("IE") to ensure that bids for
company-owned resources (on which Idaho Power can expect to earn a return) can
compete on even terms with third-party resources (on which Idaho Power cannot
receive a return);
• Eliminate its proposed imputed debt adder for third-party bids,which Idaho Power has
previously proposed and had rejected by the Oregon Commission because it is anti-
competitive;
• Clarify the meaning of"commercially proven technology" to ensure that overly strict
interpretation does not preclude emerging technologies such as iron-air battery storage
and enhanced geothermal that are increasingly being deployed at scale and may be
suited to meet Idaho Power's needs; and
• Remove a minimum bid criterion that gives Idaho Power the right to reject a bid if the
bid's COD does not align with the COD reflected in its interconnection studies, a
circumstance that is already adequately addressed in Idaho Power's non-price scoring
criteria.
RNW also highlights a few elements of the RFP that appear to represent best practices not
always observed in utility RFPs, for which RNW offers support. These include the RFP's:
• Acceptance of transmission bids;
• Sharing of transmission resources with third-party bidders; and
• Proposed refresh in the event of changes to law or policy.
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 3

RNW appreciates Idaho Power's and the Commission's consideration of these comments
and the successful acquisition of resources to meet the company's and its customers' needs at the
least cost and least risk, in alignment with the Commission's guiding principles governing RFPs
for large supply-side resources.4
II. COMMENTS
A. Commercial Operation Date
RNW requests that Idaho Power voluntarily revise the RFP to explicitly call for bids with
CODS of December 31, 2030 or earlier or that the Commission direct Idaho Power to do so. This
change would eliminate an unnecessary three-month lacuna that—if unaddressed—could result in
millions if not billions of dollars in additional costs for Idaho Power's customers due to lost federal
tax credits.
The Draft RFP provides that "first delivery" of a resource bid into the RFP must be
"[b]etween April 1 and May 31 of the respective year(2031 and 2032)."5 Meanwhile, federal tax
credits for wind and solar resources are generally available only for resources that come online by
December 31,2030.6 If the three-month difference between December 31,2030 and April 1,2031
inadvertently excludes tax credit-eligible resources from consideration, Idaho Power could be
placing its customers unnecessarily on the hook for millions if not billions of dollars.'
4 Id.
5 Draft RFP at 11, Table 3-1.
6 See IRS Notice 2025-42 at 1-2, 5-12 (Aug. 15, 2025), available at
https://www.irs.goy/pub/irs-drop/n-25-42.pdf(applying "safe harbor"tax credit
eligibility to projects "placed in service"by the end of the fourth year after July 4, 2026).
7 See, e.g.,In re Pacifi Corp 2025 Integrated Resource Plan and Clean Energy Plan,
Oregon Public Utility Commission, Docket No. LC 85, Redacted Comments of
Renewable Northwest at 21 (July 29, 2025) (quantifying cost to PacifiCorp customers of
delaying procurement and losing tax credit eligibility), available at
https:Hedoes.pue.state.or.us/efdoes/HAC/lc85hac338629115.pdf.
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 4

The fix is simple. Idaho Power need only replace the "between April 1 and May 31"
construct with a COD deadline of May 31, 2032. This would allow all economic bids with CODS
before May 31, 2032 to be considered. This deadline construct would be consistent with normal
utility procurement practices.8 There is no good reason to limit resource CODS to a two-month
window in a given calendar year, particularly if doing so could have such extreme costs for Idaho
Power's customers.
B. Independent Evaluator
RNW requests that Idaho Power voluntarily engage an IE to ensure that its procurement is
fair and competitive or that the Commission direct Idaho Power to engage one. Idaho Power has
provided in testimony that, although it does not propose to engage an IE, it is not opposed to using
one. RNW recommends the Commission take Idaho Power up on this offer.
IEs serve a particularly important role in procurement processes where bids for utility-
owned resources are competing against third-party resources. Because an investor-owned utility
stands to earn not just a return of its investment in owned resources but also a return on those
resources—essentially, a profit—the utility may structure or conduct an RFP to prioritize selection
of owned resources over third-party resources on which the utility will not earn a return. Even the
perception that a utility may be tipping the scales can depress participation in an REP and result in
the selection of higher-cost resources to serve customers. By independently reviewing the RFP,
RFP bids, and bid scoring and selection, an IE provides valuable direct oversight and helps to
instill confidence in prospective bidders. The IE can also provide helpful information to the
8 See, e.g., Idaho Power 2028 REP at 11, Table 3-1, available at
hgps://docs.idahopower.com/pdfs/AboutUs/businessToBusiness/2028 IPC AllSource_R
FP.pdf(generally requiring first delivery"[o]n or before April 1, 2028").
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 5

Commission, which will eventually be in the position of determining cost recovery of any
resources procured from the REP.
Here,Idaho Power proposes to accept both utility-owned and third-party bids. Idaho Power
has indicated that it"is not proposing the use of an Independent Evaluator for this solicitation"but
also that it"is not necessarily opposed to Independent Evaluator participation in the RFP selection
process so long as the Company can maintain the proposed timeline to ensure bidders are able to
meet in-service timelines."9 RNW believes the balance suggested in this testimony is reasonable,
and that Idaho Power should retain an IE while adhering to its preferred timeline. The upside for
customers and the commission outweighs the cost of the IE.
C. Imputed Debt
Idaho Power is proposing again to apply an "imputed debt adder" to third-party bids, a
move that has been rejected in the past by the Oregon Commission (and that underscores the
potential value in engaging an IE). RNW respectfully requests the Commission direct Idaho Power
to remove this adder, which is unreasonable and unnecessary.
In 2023,Idaho Power proposed an imputed debt adder as part of its 2026 RFP. Then,RNW
provided in comments to the Oregon Commission that"imputed debt adders not only are typically
disallowed by the Commission but also unnecessarily increase the levelized costs of PPA and BSA
bids."10 RNW explained that "the adder sets up an asymmetrical comparison between utility-
owned and non-utility bids", "does not allow for a fair or transparent comparison between bids[,]
9 Direct Testimony of Eric Hackett at 21.
io In re Idaho Power Company Application for Approval of 2028 All-Source Request for
Proposals To Meet 2028 Capacity Resource Need, Oregon Public Utility Commission,
Docket No. UM 2255, Comments of Renewable Northwest at 2 (May 3, 2023), available
at https:Hedocs.puc.state.or.us/efdoes/HAC/um2255hac9ll2.pdf.
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 6

and unfairly favors utility-owned projects."11 Ultimately, RNW suggested that— consistent with
longstanding Oregon Commission precedent— "debt considerations are best taken in the context
of the utility's cost of capital versus as imputed debt."12 RNW also cited Standard&Poor's 2007
Methodology For Imputing Debt For U.S. Utilities' Power Purchase Agreements as
acknowledging that PPAs heighten risk for a utility" and therefore "apply[ing] risk factors that
reduce debt imputation" and focus instead on cost of capital. 13 The Oregon Commission agreed
with RNW and other parties that opposed the imputed debt adder—including Oregon Commission
Staff and the NIPPC—and directed Idaho Power to remove the imputed debt adder.14
RNW requests that the Idaho Commission do the same. Idaho Power's proposed imputed
debt adder does not accurately reflect the impacts of power purchase agreements on its credit and
serves only to depress selection of third party bids. It is unsupported and anticompetitive, and
therefore unreasonable.
D. Commercially Proven Technology
RNW requests that Idaho Power clarify the meaning of its minimum bid criterion requiring
that any bid be "for a resource with commercially-proven technology" or that the Commission
direct Idaho Power to do so.
Rather than including minimum bid criteria in the body of the RFP, Idaho Power placed
them in a tab—titled"Eligibility"—of an attached Excel workbook comprising Exhibits B, C, and
D of the RFP. Bid Eligibility Factor number 6, located in cell C31, provides that a bid must be
11 Comments of Renewable Northwest at 2.
12 Comments of Renewable Northwest at 2.
13 Comments of Renewable Northwest at 2.
14 In re Idaho Power Company Application for Approval of 2028 All-Source Request for
Proposals To Meet 2028 Capacity Resource Need, Oregon Public Utility Commission,
Docket No. UM 2255, Order No. 23-260 at 5-6 (July 17, 2023), available at
https:Hgpps.puc.state.or.us/orders/2023ords/23-260.pd
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 7

"for a resource with commercially-proven technology." As implied by the references to eligibility,
if a bid does not meet any one of the bid eligibility factors, it is"not eligible"and will be excluded
from the RFP."
At a high level, this provision is reasonable. Part of least-cost, least-risk procurement is
minimizing risk to Idaho Power's customers. Resources that are not commercially proven carry
inherently greater risk than those that are.
However,the term"commercially-proven technology"is also subjective in a way that gives
Idaho Power license to exclude bids effectively on a whim. For example, pumped hydro storage
development in the United States peaked in the 1970s and 1980s and has dwindled to almost
nothing since the 1990s.16 With 30 years lapsed since the last gigawatt-scale investment in pumped
hydro storage, is pumped hydro "commercially-proven"? RNW would say yes; it is unclear what
Idaho Power would say.
This question is doubly important in a time of emerging resources with clear commercial
applications and strong indicators of commercial viability such as iron-air storage and enhanced
geothermal generation. A little over a month ago, Google and Xcel energy partnered to invest in
a 300 MW iron-air storage facility in Minnesota.17 Last year, New Mexico Governor Michelle
Lujan Grisham announced a 150 MW commercial deal between Meta and XGS Energy for an
enhanced geothermal project.18 Pumped hydro, iron-air storage, and enhanced geothermal are all
15 See, e.g., cells. D22 and E22 of the `Eligibility"tab.
16 U.S. Energy Information Administration, "Most pumped storage electricity generators in
the U.S. were built in the 1970s" (October 31, 2019), available at
hgps://www.eia. ovg /todayinenergy/detail.php?id=41833.
17 Xcel Energy, "Xcel Energy to power new Google data center in Minnesota" (Feb. 24,
2026), available at hgps://newsroom.xcelenergy.com/news/xcel-energy-to-power-new-
_goo gle-data-center-in-minnesota.
18 Gov. Michelle Lujan Grisham, "Governor announces XGS Energy, Meta geothermal
partnership—Nation-leading 150 MW geothermal project on its way to New Mexico"
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 8

being developed in the Northwest. Without additional clarity, Idaho Power could exclude these
resources without assessing them simply on the basis that they are not sufficiently"commercially-
proven."
Three possible solutions to this problem are: 1) Simply deleting the minimum bid criterion
for commercially-proven technologies; 2) Clarifying the meaning of "commercially-proven
technology"and ensuring that it includes a range of commercially available technologies that may
meet Idaho Power's needs; or 3) Move the "commercially-proven technology" item from
minimum bid criteria to non-price scoring criteria, so Idaho Power's discretion is limited to scoring
rather than outright exclusion. Any of these would represent an improvement to the RFP.
E. Bid-Interconnection Alignment
RNW recommends either Idaho Power or the Commission address one other minimum bid
criterion: the requirement that a project's interconnection timeline "match[]" its proposed
commercial operation date. Similar to the discussion of"commercially-proven technology"above,
RNW recommends that this requirement be either removed or modified to avoid inadvertent
exclusion of competitive bids.
Bid Eligibility Factor number 9, located in cell C34,requires "[d]ocumentation"including
"GIA status" that "indicates the viability of a Commercial Operation Date (Resource Based
Proposals) or Contract Effective Date (Market Purchase Proposals) that matches the COD
submitted." In this post-FERC Order 2023 era of first-ready, first-served interconnection
processes, interconnection studies may not be a reliable indicator of a project's commercial
(June 12, 2025), available at https://www.govemor.state.nm.us/2025/06/12/govemor-
announces-x sg energy-meta-geothermal-partnership-nation-leading-I50-mw-geothermal-
proj ect-on-its-way-to-new-mexico/.
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 9

operation date. This mismatch can result from a perverse interaction between state regulatory
processes and FERC jurisdictional interconnection processes: A utility IRP indicates a need for a
resource type at a location on the utility's system; developers submit interconnection requests for
projects that match the utility's need;the inclusion of multiple projects in a single area on a utility's
system results in lengthy interconnection timelines; and later attrition from the interconnection
queue leaves competitive projects able to interconnect on a timeline faster than what their
interconnection studies show. Idaho Power's proposed minimum bid criterion requiring a"match"
between interconnection documents and a bid's commercial operation date could exclude these
competitive projects on the basis of an essentially fictional interconnection timeline.
Again, as with "commercially-proven technologies", there are essentially three possible
solutions: 1) Simply deleting the minimum bid criterion for a "match" between interconnection
timelines and commercial operation date; 2) Clarifying that the "match" need not be precise and
Idaho Power will accept a narrative explaining why the bidder believes it will be able to bring its
project online ahead of its interconnection timeline; or 3) Move the "match" requirement from
minimum bid criteria to non-price scoring criteria, so Idaho Power's discretion is limited to scoring
rather than outright exclusion. Again, any of these would represent an improvement to the RFP.
F. Other
Having covered several items RNW has identified as requiring change, these comments
now turn to elements of the RFP that RNW explicitly supports. Because this section is positive in
nature, the explanation for RNW's support in each instance will be brief.
Transmission alternatives: Section 3.3 of the RFP provides that Idaho Power "will also
accept bids for transmission ownership, service, or long-term rights that may meet energy and
capacity needs[.]" In a period of severe transmission constraints in the Northwest, this provision
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 10

sends an important signal that transmission is itself a key resource that can help a utility meet its
needs.
Transmission paths: Exhibit E to the RFP provides a list of transmission paths controlled
by Idaho Power that Idaho Power appears to be making available to bidders. This represents
another positive step for bidders seeking to deliver power to Idaho Power in a transmission-
constrained environment.
Bid refresh: Section 6.5 of the RFP generally requires that bids be held firm and binding,
but adds that "[i]f a substantive change to legislation, law, or similar has a material impact to the
submitted pricing proposal, [Idaho Power] will seek updates from all Bidders, as applicable,
throughout the evaluation process." Because the development and procurement landscape right
now is volatile, RNW appreciates the prospect of a refresh in the not-unlikely event of an
intervening circumstance that might affect bid pricing.
III. CONCLUSION
RNW appreciates Idaho Power's and the Commission's attention to these comments.
RNW recommends that Idaho Power or the Commission implement the changes recommended
above in order to ensure a fair and competitive RFP that results in least-cost, least-risk resources
for Idaho Power and its customers.
Respectfully submitted this 8th day of April, 2026.
Mike Goetz
Regulatory Affairs Director
Renewable Northwest
421 SW 6th Ave., Suite 1400
Portland, OR 97204
Telephone: [phone]
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE I I

CERTIFICATE OF SERVICE
I HEREBY certify that I have on this 8th day of April, 2026, served the foregoing
Comments of Renewable Northwest by electronic mail to the following:
Monica Barrios-Sanchez Irion Sanger
Commission Secretary Sanger Greene, PC
Idaho Public Utilities Commission 4031 SE Hawthorne Blvd.
P.O. Box 83720 Portland, OR 97214
Boise, ID 83720-0074 [e-mail]
[e-mail]
Katie O'Neil
Jeffrey R. Loll Energy Program Manager
Deputy Attorney General Boise City Dept. of Public Works
Idaho Public Utilities Commission 150 N. Capitol Blvd.
P.O. Box 83720 P.O. Box 500
Boise, ID 83720-0074 Boise, ID 83701- 0500
[e-mail] [e-mail]
Donovan Walker Tim Tatum
Idaho Power Company Connie Aschenbrenner
1121 W. Idaho Street Idaho Power Company
PO Box 70 1121 W. Idaho Street
Boise, ID 83707-0070 PO Box 70
[e-mail] Boise, ID 83707-0070
[e-mail] ttatum@.idahopower.com
[e-mail]
Ed Jewell
Deputy City Attorney Eric L. Olsen
Boise City Attorney's Office Echo Hawk& Olson, PLLC
150 N. Capitol Blvd. 505 Pershing Ave., Ste. 100
P.O. Box 500 P.O. Box 6119
Boise, ID 83701- 0500 Pocatello, Idaho 83205
[e-mail] [e-mail]
[e-mail] [e-mail]
Gregory M. Lance Kaufman, Ph. D.
Richardson Adams, PLLC Deborah Glosser, Ph. D.
515 N. 27th Street 2623 NW Bluebell Place
Boise, Idaho 83702 Corvallis, OR 97330
[e-mail] [e-mail]
[e-mail]
By: 44,Vt
Mike Goetz
RENEWABLE NORTHWEST'S COMMENTS
IPC-E-26-03 —PAGE 12