20260413Opening Comments.pdf

Irion Sanger, ISB No. 12488
Sanger Greene PC
4031 SE Hawthorne Blvd. RECEIVED
Portland, OR 97214 APRIL 13, 2026
Tel: [phone] IDAHO PUBLIC
Fax: [phone] UTILITIES COMMISSION
[e-mail]
Counsel for Idaho Winds LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) Case No. IPC-E-25-36
COMPANY'S 2025 VARIABLE ENERGY )
RESOURCE INTEGRATION STUDY AND IDAHO WINDS LLC'S
PROPOSED UPDATE TO SCHEDULE 87 ) OPENING COMMENTS
I. INTRODUCTION
In accordance with the Idaho Public Utilities Commission's ("Commission")
February 26, 2026 Notice of Modified Procedure, Idaho Winds LLC ("Idaho Winds" or
"IW")provides the following comments on Idaho Power Company's ("Idaho Power" or
"Company") 2025 Variable Energy Resource ("VER") Integration Study("VER Study"
or"Study") and proposed update to Schedule 87. After reviewing the Study, Idaho
Winds has identified multiple flaws in the Study that result in the calculated Integration
Costs being higher than Idaho Power would expect to incur. Therefore, we respectfully
request that the Commission not approve this VER Study until Idaho Power addresses
these issues. We further request that the Commission direct Idaho Power to set Schedule
87 Integration Charges for renewing QFs that reflect the lower cost of integrating earlier
VERs to the system rather than the higher Integration Costs of incremental (new) VERs.
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IDAHO WINDS' OPENING COMMENTS Page I

II. COMMENTS
A. The 2025 VER Integration Cost Study Base Portfolio Is Out of Date
The VERs included in the Base Portfolio of the VER Study are listed in Idaho
Power's 2025 Integrated Resource Plan ("IRP")Appendix C.1 One of those resources is
the 600 MW Jackalope Wind Project, that was expected to come on line in June 2027 for
a 35-year term.2 However, Idaho Power filed a petition to withdraw from that project on
September 19, 2025, in Case IPC-E-25-28.3 This large wind resource (which accounts
for nearly 60% of Idaho Power's total wind nameplate capacity and over 30% of Idaho
Power's total VER nameplate capacity in 2027) is driving up Integration Costs of both
the Base Portfolio and each of the 4 incremental blocks of the Study.
The Commission has previously ruled that, when setting avoided cost rates for
QFs using the incremental cost IRP methodology, Idaho Power should use the AURORA
model from the most recently filed IRP, but the model should be updated to account for
resource changes of high certainty.4 The same requirement should also be applied to the
VER Study. When conducting the Study, the Base Portfolio should be modified to reflect
resource changes of high certainty that have occurred since the issuance of the latest IRP
' Attachment A(Idaho Power Company's Response to Idaho Winds LLC's
Production Requests 3 and 9); 2025 Integrated Resource Plan Appendix C:
Technical Report, Idaho Power Company at 26-30 (June 2025), available at:
hgps:Hdocs.idahol2ower.com/pdfs/AboutUs/PlanningForFuture/2025IRP/2025%2
OIRP%20APpendix%20C.pdf.
2 2025 Integrated Resource Plan Appendix C: Technical Report at 30.
3 In re Petition of Idaho Power to Withdraw Certificate No. 559, Inclusive of the
Build Transfer Agreement and Power Purchase Agreement for the Jackalope
Wind Project Approved by Order No. 36659, Case No. IPC-E-25-28, Order No.
36893 at 1 (Dec. 31, 2025).
4 In re Application of Idaho Power for Approval or Rejection of an Energy Sales
Agreement with Fossil Gulch Wind Park, LLC for the Sale and Purchase of
Electric Energy from the Fossil Gulch Wind Park, Case No. IPC-E-25-31, Order
No. 36956 at 4 (Mar. 5, 2026).
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IDAHO WINDS' OPENING COMMENTS Page 2

but prior to the publication of the Study. By not updating the Base Portfolio to account
for such changes, Idaho Power is calculating Integration Charges based on data that the
Company knows is already out of date. Therefore, in order to calculate Integration
Charges as accurately as possible, the Base Portfolio must be updated with all resource
changes of high certainty known to the Company at the time the VER Study was
published. This would include the removal of the 600 MW Jackalope Wind Project from
the Base Portfolio.
B. Renewal QFs Should Not Pay the Same Integration Charges as New QFs
There are two primary reasons why a renewal QF should be paying Integration
Charges at different rates than a new QF. First, by considering renewing QFs as
incremental (new), most of the QF's energy, and therefore its Integration Cost, is double
counted. By the logic of the Study, a renewal QF paying the same Integration Charges as
a new QF means the renewal QF is being treated as incremental to Idaho Power's Base
Portfolio. However, 75% of that renewal QF's capacity (and energy) is already being
modeled and accounted for in the Base Portfolio of the Study.5 Therefore, by treating the
renewal QF as incremental for purposes of setting Integration Charges, 75% of the QF's
capacity (and energy) is double counted. Since, in general, Integration Costs tend to rise
as the total amount of VERs on the system rises, this double counting results in Idaho
Power getting reimbursed for more Integration Costs than it would actually incur by
executing a renewal contract with the QF.
5 Attachment A(Idaho Power Company's Response to the Production Request 15
of the Commission Staff).
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IDAHO WINDS' OPENING COMMENTS Page 3

Second, the Commission has already established that a renewal QF's capacity
should not be considered incremental in case IPC-E-15-01.6 In Order No. 33357, the
Commission ruled that at the time of renewal, as long as the QF continuously sells power
to the utility, it is entitled to capacity payments based on the utility's capacity deficiency
date established at the signing of its initial contract. The Commission states "[t]his
adjustment recognizes that in ensuing contract periods, the QF is considered part of the
utility's resource stack and will be contributing to reducing the utility's need for
capacity."8 Because a renewal QF is already embedded in the resource stack, it does not
impose the same incremental balancing and variability impacts as a new resource, and
should not be treated as incremental for integration cost purposes. In other words, the
capacity provided by an existing QF should not be considered incremental to the other
resources on the utility's system just because its original contract expires. Rather, if the
QF renews its contract, its original online date is maintained for purposes of determining
how it contributes towards the utility's capacity needs.
If a renewing QF project is not considered incremental in terms of capacity, the
same logic should also apply to Integration Charges. Since a QF's position within the
utility's resource stack is maintained at the time of renewal, the QF should pay
Integration Charges that reflect the utility's lower cost to integrate the first VERB on its
system rather than the higher costs of integrating new, incremental VERB on its system.
This is consistent with the intended purpose of Schedule 87 Integration Charges. When
6 In re Idaho Power Company's Petition to Modify Terms and Conditions of
PURPA Agreements, Case No. IPC-E-15-01, Order No. 33357 at 26 (August 20,
2015).
7 Case No. IPC-E-15-01, Order No. 33357 at 25-26.
8 Case No. IPC-E-15-01, Order No. 33357 at 26.
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IDAHO WINDS' OPENING COMMENTS Page 4

Schedule 87 was created in case IPC-E-13-22, the Commission stated"Staff believes that
applying an increasing burden for each wind project that comes online is reasonable
because the intermittent energy produced creates an increasing burden for the utility.
Staff believes that new projects should be responsible for the full incremental cost of
integration."9 A QF renewing its contract is not a new project, and it does not create an
increasing burden for the utility like a new QF would. Therefore, it would be
inappropriate for a renewing QF to pay the same Integration Charges as a new QF.
C. Calculation of Renewal QF Integration Charges
To most accurately calculate the Integration Charges of a renewal QF, Idaho
Power should calculate Integration Costs by considering the QF to be incremental only to
the VERs on Idaho Power's system that existed prior to the QF's original online date.
This would result in a unique Integration Charge for each QF that reflects Idaho Power's
true cost to integrate that QF's energy based on its original online date and technology
type. However, Idaho Winds recognizes that this might be burdensome without
dramatically altering the methodology of the Study. In that case, IW believes that an
effective compromise would be to establish a single additional Integration Charge rate
class in Schedule 87, specifically for renewing QFs, that reflects the average Integration
Costs of Idaho Power's existing VER portfolio as a whole.
Although it is not explicitly done so in the VER Integration Cost Study, Idaho
Power can easily calculate the Integration Costs of the Base Portfolio using the same
methodology it used to calculate the Integration Costs of each of the four Incremental
9 In re Idaho Power Company's Application to Update its Wind Integration Rates
and Charges, Case No. IPC-E-I3-22, Order No 33150 at 5 (October 10, 2014)
(emphasis added).
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IDAHO WINDS' OPENING COMMENTS Page 5

Blocks.10 The total Integration Costs of the Base Portfolio can be calculated by
subtracting the "Portfolio Cost without Ancillaries" from the "Portfolio Cost with
Ancillaries"for the Base Portfolio." Dividing this difference by the total VER energy
production of the Base Portfolio gives the Integration Cost in terms of dollars per MWh.
This is illustrated by the equation below:12
CBase Portfolio Cost\ / Base Portfolio Cost
Base Portfolio Integration with Ancillaries [$] J (without Ancillaries [$]J
Cost [$/MWh] Base Portfolio 20-yr VER Energy Production [MWh]
The exact production of the VERB in Idaho Power's Base Portfolio is confidential,
however we can estimate it based on the production of the incremental VER"blocks".13
For each year of the 20-year planning horizon, IW calculated the total amount of both
wind and solar VERB in Idaho Power's Base Portfolio. Assuming the wind and solar
projects in Idaho Power's base portfolio produce the same amount of energy per MW per
year as the "blocks" of incremental wind and solar, we can estimate Idaho Power's Base
Portfolio VER energy production for each year of the 20-year planning horizon in order
to find the total expected VER energy of the Base Portfolio, in the absence of project-
specific production data and recognizing this approach as an approximation. The detailed
calculations of Idaho Power's Base Portfolio Integration Costs and estimated energy
production can be found in Attachment B, a spreadsheet.
10 Attachment C at Paragraph 4 (Declaration of Adam Rabin).
11 Attachment C at Paragraph 4.
12 Attachment C at Paragraph 4.
13 Attachment C at Paragraph 4.
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IDAHO WINDS' OPENING COMMENTS Page 6

Based on the data published in the VER Integration Cost Study, the total 20-year
Integration Costs of Idaho Power's Base Portfolio is $63,799,000, and the total estimated
VER production over that period is 102,175,329 MWh.14 From this, the Integration
Costs for VERB in the Base Portfolio is calculated to be $0.62/MWh.15 This rate is 52%
lower than the Integration Costs for new wind and 60% lower than Integration Costs for
new solar at the 100 MW penetration level as calculated in the Study.16 This
significantly lower rate more accurately reflects the true Integration Costs of a renewing
QF.
III. CONCLUSION
Idaho Winds appreciates the opportunity to comment on Idaho Power's 2025
VER Integration Cost Study. The Commission should direct Idaho Power to update the
Base Portfolio used in the Study to account for resource changes of high certainty that
have occurred since the IRP was released. Additionally, the Commission should direct
Idaho Power to set Integration Charges for renewing QFs based on their original online
date and technology type. If it is determined to be unfeasible to set this rate for every QF,
Idaho Power should establish a single additional rate for renewing QFs based on the
average Integration Costs of the Base Portfolio.
14 Attachment B (Base Portfolio Integration Costs); Attachment C at Paragraphs 2a
and 2b.
15 Attachment B; Attachment C at Paragraph 2c.
16 Attachment B; Attachment C at Paragraph 2d.
IPC-E-25-36
IDAHO WINDS' OPENING COMMENTS Page 7

Dated this 13th day of April 2026.
Respectfully submitted,
r; - ZI W,
Irion A. Sanger, ISB No. 12488
Sanger Greene, PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Idaho Winds LLC
IPC-E-25-36
IDAHO WINDS' OPENING COMMENTS Page 8

CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 13th day of April,2026, I caused to be served a
true and correct copy of the foregoing document upon the following individuals in the
manner indicated below:
Electronic Mail Only(See Order No. 35058):
Idaho Public Utilities Commission
Commission Secretary
secretary(c,puc.idaho.gov
Erika Melanson
Deputy Attorney General
Erika.Melanson(cr�puc.idaho.gov
Idaho Power Company
Donovan Walker
Tim Tatum
Riley Maloney
Mary Alice Taylor
dwalker&idahopower.com
docketskidahopower.com
ttatum&idahopower.com
rmaloney(�ic idahopower.com
mtaor(aidahopower.com
Irion A. Sanger
IPC-E-25-36
IDAHO WINDS' OPENING COMMENTS Page 9

Attachment A
Idaho Power Company Reponses to Requests for Production to
Idaho Wind and Commission Staff

REQUEST FOR PRODUCTION NO. 3: Please provide a narrative description of
why wind integration charges increased while solar integration charges decreased from
the 2024 VER Integration Study to the 2025 VER Integration Study.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Integration charges will
change if any of the drivers discussed in the Company's Response to Idaho Winds'
Request for Production No. 2 are changed. When comparing the 2024 VER Integration
Study (which was based on the 2023 Integrated Resource Plan ("IRP") model)to the 2025
VER Integration Study (which is based on the 2025 IRP model), nearly all the driving
inputs changed.
The ability of the system to absorb variable generation was reviewed and revised
between IRPs based on feedback from plant and system operators to more closely match
actual operating capability. This review helped align operator experience with modeling
assumptions and identified that there is less head room in the Company's current system
to absorb VERs than the 2023 IRP model indicated. It also better aligned the ability of
future resources to provide reserves with operator expectations. This adjustment to better
reflect operating realities generally put upward pressure on integration costs for both wind
and solar.
The amount and types of variable generators on the system also changed between
studies consistent with changes between the preferred portfolios in the 2023 IRP and
2025 IRP. Overall, the 2025 IRP selected fewer VERs in the preferred portfolio putting
downward pressure on integration costs for both wind and solar.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO WINDS, LLC'S FIRST SET OF DATA
REQUESTS - 6

The extent that VER generation varies was also analyzed between IRPs and
updated. The values used in the 2023 IRP were created by Energy and Environmental
Economics ("EY), the third-party evaluator Idaho Power contracted with for the 2020 VER
Integration Study. Idaho Power, not having access to E3's proprietary methods, updated
the reserve requirements in the 2025 IRP based on more recent data and with a
transparent method that was vetted with help from the Technical Review Committee in
2024. Analysis with the updated method, which was conducted with more recent data and
included both the diversity and portfolio benefits, showed that reserve requirements for
solar resources needed to be revised down and reserve requirements for wind resources
needed to be revised up. The revisions to the requirements put downward pressure on
integration costs for solar and upward pressure on the integration costs for wind.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO WINDS, LLC'S FIRST SET OF DATA
REQUESTS - 7

REQUEST FOR PRODUCTION NO. 9: Please provide the technology type (e.g.,
hydro, battery energy storage systems ("BESS"), reciprocating engine ("recip")), amount
in MW, and cost of each ancillary resource that Aurora dispatches to provide regulating
reserves for each hour of the year in each of the five portfolios studied in the 2024 VER
Integration Study.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: Please see the
attachment provided in response to this request for the monthly average cost of each
ancillary product and the resources that provide them. While the model resolves at an
hourly level when determining which resources provide reserves and the cost of doing
so, the Company does not output those details due to run time impacts and limited storage
space. Accordingly, the most granular information the Company output for the 2024 VER
Integration Study was at the monthly level. Between IRPs, the Company reviews the
granularity of model outputs and the potential uses for other Company-driven analyses
and may change such level of granularity to minimize storage space and run time impact.
Between the 2023 IRP, which was used for the 2024 VER Integration Study, and the 2025
IRP, which was used for the 2025 VER Integration Study, the model output for ancillary
resources was changed from monthly to annually as monthly data was determined to not
be needed in the near-term for other Company-driven analyses.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO WINDS, LLC'S FIRST SET OF DATA
REQUESTS - 13

REQUEST FOR PRODUCTION NO. 15: Please explain whether wind qualifying
facilities ("QFs") are assumed to be renewed in the Base Portfolio. Also, please quantify
the impacts of this assumption on wind integration charge compared to a scenario where
wind QFs are NOT assumed to be renewed.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Consistent with the
Preferred Portfolio of the 2025 IRP, when a wind QF contract expires, 75 percent of the
project is expected to provide energy on a replacement contract. Idaho Power has not
calculated integration costs without this base 2025 IRP assumption and is therefore
unable to quantify the impact of this assumption.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF - 24

Attachment B
Base Portfolio Integration Costs

Idaho Winds LLC
03 April 2026
IPC 2025 VER Integration Cost Study Analysis
VER Study size 20-yr energy production/MW production/MW/ cost with cost without diff from base Integration Cost
portfolio [MW] production [MWh] [MWh] yr[MWh] ancillaries ancillaries difference portfolio [$/MWh]
base portfolio N/A 102,175,329 N/A N/A $19,806,678,000 $19,742,879,000 $63,799,000 N/A $0.62
incremental solar 100 4,319,419 43,194 2,160 $19,646,864,000 $19,576,261,000 $70,603,000 $6,804,000 $1.58
incremental solar 200 8,638,835 43,194 2,160 $19,494,416,000 $19,402,233,000 $92,183,000 $28,384,000 $3.29
incremental wind 100 5,190,877 51,909 2,595 $19,569,393,000 $19,498,788,000 $70,605,000 $6,806,000 $1.31
incremental wind 200 10,381,756 51,909 2,595 $19,344,360,000 $19,264,738,000 $79,622,000 $15,823,000 $1.52
"energy production of Base Portfolio is calculated on IPC 2025 IRP Base Portfolio VER tab
*all values in blue are taken directly from the IPC 2025 VER Integration Cost Study(see screenshot below)
Portfolio Cost Portfolio Cost Cost Differential Relative
with Ancillaries without Ancillaries to Base Portfolio Incremental Integration Cost
Portfolio ($x 1,000) ($x 1,000) Difference($x 1,000) Energy(MWh) ($/MWh)
Base Portfolio $19,806,678 $19,742,879 N/A N/A
100 MW Solar $19,646,864 $19,576,261 $6,803 4,319,419 1.58
200 MW Solar $19,494,416 $19,402,233 $28,384 8,638,835 3.29
100 MW Wind $19,569,393 $19,498,788 $6,805 5,190,877 1.31
200 MW Wind $19,344,360 $19,264,738 $15,823 10,381,756 1.52
Base Portfolio VER(wind &solar)avg Integration Cost[$/MWh] $0.62 this is the Integration Charge that renewing QFs should be paying
Integration Costs for new(incremental)wind[$/MWh] $1.31
difference in cost from Base Portfolio 52%
Integration Costs for new(incremental)solar[$/MWh] $1.58
difference in cost from Base Portfolio 60%
prepared by:
Adam Rabin, Project Engineer
Idaho Winds LLC
ar(a)powerworks.com
803-292-5788

Idaho Winds LLC
03 April 2026
IPC 2025 IRP Base Portfolio VER Energy Production
Wind Nameplate Capacity[II Solar Nameplate Capacity[MW]
OF Elkhorn Jackalope OF Black Franklin Jackpot Pleasant PVS2 Crimson Blacks Creek total wind total solar total VERB
year wind Wind Wind solar Mesa Solar Solar Solar Valley Solar Solar Orchard Solar Solar [MW] [MW] [MW] wind MWh solar MWh total MWh
2026 620 101 322 40 100 120 200 83.3 721 865.3 1586.3 1,871,311 1,868,869 3,740,180
2027 619 300 327 40 100 120 200 125 66.7 0 1020 978.7 1998.7 2,647,347 2,113,636 4,760,983
2028 617 600 333 40 100 120 200 125 100 320 1217 1338.0 2555.0 3,158,649 2,889,691 6,048,340
2029 604 600 338 40 100 120 200 125 100 320 1204 1343.0 2547.0 3,124,908 2,900,490 6,025,398
2030 596 600 344 40 100 120 200 125 100 320 1196 1349.0 2545.0 3,104,144 2,913,448 6,017,593
2031 539 600 349 40 100 120 200 125 100 320 1139 1354.0 2493.0 2,956,204 2,924,247 5,880,451
2032 524 600 354 40 100 120 200 125 100 320 1124 1359.0 2483.0 2,917,273 2,935,045 5,852,318
2033 437 600 360 40 100 120 200 125 100 320 1037 1365.0 2402.0 2,691,470 2,948,003 5,639,473
2034 426 600 365 40 100 120 200 125 100 320 1026 1370.0 2396.0 2,662,920 2,958,802 5,621,722
2035 361 600 370 40 100 120 200 125 100 320 961 1375.0 2336.0 2,494,216 2,969,601 5,463,817
2036 353 600 365 40 100 120 200 125 100 320 953 1370.0 2323.0 2,473,453 2,958,802 5,432,255
2037 274 600 314 40 100 120 200 125 100 320 874 1319.0 2193.0 2,268,413 2,848,657 5,117,070
2038 265 600 307 40 100 120 200 125 100 320 865 1312.0 2177.0 2,245,054 2,833,539 5,078,593
2039 213 600 279 40 100 120 200 125 100 320 813 1284.0 2097.0 2,110,092 2,773,067 4,883,158
2040 209 600 269 40 100 120 200 125 100 320 809 1274.0 2083.0 2,099,710 2,751,470 4,851,180
2041 170 600 248 40 100 120 200 125 100 320 770 1253.0 2023.0 1,998,488 2,706,116 4,704,604
2042 166 600 246 40 100 120 200 125 100 320 766 1251.0 2017.0 1,988,106 2,701,797 4,689,902
2043 137 600 232 20 100 200 125 100 320 737 1097.0 1834.0 1,912,838 2,369,201 4,282,039
2044 135 600 232 100 200 125 100 320 735 1077.0 1812.0 1,907,647 2,326,007 4,233,654
2045 113 600 232 100 s0 125 100 320 713 927.0 1640.0 1,850,548 2,002,051 3,852,598
20-yr ayg MW 20-yr total MWh
'Base portfolio VERs come from Appendix C of IPC 2025 IRP. See screenshots at bottom of page. 934.0 1,243.1 2,177.1 48,482,791 53,692,538 102,175,329
'energy production/MWlyr is estimated based on the 100 MW blocks of wind and solar
'capacity of PPA projects in years containing the start or end date of the project is prorated based on the number of complete months that project would be online in that year...
...for example,a project expected to come online in June only provides half its nameplate in terms of capacity for that year
contract start
oonVact end M
Qualifying Facilities Forecast(average MW nameplate) Power Purchase Agreement Data
Year Solar Wind Biomass Thermal Cogen Hydro
Project MW On-Line Date Contract End Date
2026 322 620 20 5 18 144
Wind Projects
2027 327 619 17 5 19 145
Elkhorn Wind Project 101 Dec-2007 Dec-2027
2028 333 617 17 5 19 145 Jackalope Wind Project(PPA and Idaho Power-Owned) 600 Expected Jun-2027 35-year PPA term
2029 338 604 16 5 20 145 Total Wind Nameplate Rating 701
2030 344 596 15 5 20 146
Geothermal Projects
2031 349 539 15 5 20 146 Raft River Unit 1 13 Apr-2008 Apr-2033
2032 354 524 15 5 21 147 Neal Hot Springs 22 Nov-2012 Nov-2037
2033 360 437 15 5 21 147 Total Geothermal Nameplate Rating 35
2034 365 426 13 5 22 148 Solar Projects
2035 370 361 12 5 22 148 Black Mesa Solar 40 Jun-2023 Jun-2043
2036 365 353 12 5 23 149 Franklin Solar 100 )un-2024 Jun-2049
2037 314 274 12 5 23 149 Jackpot Solar Facility 120 Dec-2022 Dec-2042
2038 307 265 8 5 23 150 Pleasant Valley Solar 200 Mar-2025 Mar-2045
2039 279 213 4 5 24 150 PV52 Solar 125 Expected May-2026 20-year PPA term
2040 269 209 4 2 24 151 Crimson Orchard Solar(combined project with Crimson Orchard BESS) 100 Expected Apr-2027 20-year PPA term
2041 248 170 3 0 25 151 Blacks Creek Solar 320 Expected Dec-2027 20-year PPA term
2042 246 166 3 0 25 151 Total Solar Nameplate Rating 11005
2043 232 137 3 0 26 152 Total Nameplate Rating(All Non-PURPA Resource Types) 1,741
The above is a summary of the nameplate rating for the projects under contract with Idaho Power as of April 1,2025.In the case of variable-energy resource
2044 232 135 3 0 26 152 projects,nameplate rating of the actual generation units is not an accurate or reasonable estimate of the actual energy these projects will deliver to Idaho Power.
Historical generation information,resource specific industry standard capacity factors,and other known and measurable operating characteristics are
2045 223 113 3 0 26 152 accounted for in determining a reasonable estimate of the energy these projects will produce.
'screenshots from IPC 2025 IRP Appendix C

Attachment C
Declaration of Adam Rabin

DECLARATION OF ADAM RABIN
I, Adam Rabin, declare under the penalty of perjury under the laws of the state of Idaho:
1. My name is Adam Rabin. I am employed by Idaho Winds, LLC as a Project
Engineer. My business address is 5420 West Wicher Road, Glenns Ferry, Idaho, 83623.
2.
a. In the 2025 VER Integration Cost Study, Idaho Power Company's total Base
Portfolio integration costs over the 20-year period covered by the Study are
$63,799,000.
b. In the 2025 VER Integration Cost Study, the estimated energy production of
VERB in Idaho Power Company's Base Portfolio from 2026 to 2045 is
102,175,329 MWh.
c. In the 2025 VER Integration Cost Study, the average integration cost per unit
of energy produced for VERB in the Base Portfolio is estimated to be
$0.62/MWh.
d. In the 2025 VER Integration Cost Study, the estimated average integration
cost of the Base Portfolio is 52% less than the integration cost of incremental
wind at the 100 MW penetration level, and 60% less than the integration cost
of incremental solar at the 100 MW penetration level.
3. My calculations and source documents are attached to the Idaho Winds Opening
Comments as Attachment B.
4. To the best of my knowledge, the Idaho Winds Opening Comments and
attachments are true and accurate.

I hereby declare that the above statement is true to the best of my knowledge and belief,
and that I understand that it is made for use as evidence before the Idaho Public Utilities
Commission and is subject to penalty for perjury.
SIGNED this 1 Oh day of April, 2026.
Signed:
Adam Rabin