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Home My WebLink About20260413Cross-Reply Comments.pdf JAYME B. SULLIVAN BOISE CITY ATTORNEY RECEIVED APRIL 13, 2026 Ed Jewell ISB No. 10446 IDAHO PUBLIC Deputy City Attorney UTILITIES COMMISSION BOISE CITY ATTORNEY'S OFFICE 150 N. Capitol Blvd. P.O. Box 500 Boise, ID 83701-0500 Telephone: (208) 608-7950 Facsimile: (208) 384-4454 Email: BoiseCityAttomeygcityofboise.org Attorney for Intervenor BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR APPROVAL Case No. IPC-E-26-03 OF THE 2032 ALL-SOURCE REQUEST FOR PROPOSALS CITY OF BOISE CITY'S CROSS-REPLY COMMENTS The city of Boise City ("Boise City") submits these cross-reply comments, pursuant to Order No. 36960, on the application submitted by Idaho Power Company ("Company") for approval of the 2032 All-Source Request for Proposals to meet capacity resource needs as early as 2031 and comments thereon. The City, in these cross-reply comments, emphasizes compelling points made by other parties in their comments. The City emphasizes the comments of Northwest Intermountain Power Producers Coalition ("NIPPC"), Idaho Irrigation Pumpers Association ("IIPA"), and Commission Staff regarding the need for an Independent Evaluator ("IE"). The City also supports the comments of NIPPC and Commission Staff requesting the removal of an imputed debt adder. In evaluating a utility-run RFP, the Commission must account for the utility's incentive to own and operate its CITY OF BOISE CITY'S CROSS-REPLY COMMENTS 1 own resources so that it can place those investments into rate base and earn a rate of return on those investments, which may not be the best option for ratepayers. The City further supports NIPPC comments related to price/non-price scoring allocation, benchmark bids, the capturing of expiring tax credit benefits, and technology-based bid ranking. The City also concurs with public comments emphasizing the role that distributed generation and demand side management can play in minimizing capacity deficits and deferring the need for additional capital resources. The City also advocates for risks related to fueled assets be adequately included in the analysis. Fuel price fluctuations for fossil fueled assets due to global supply disruption, market changes, and regulatory changes, should be adequately considered to ensure the actual costs to operate and maintain the resources are considered over a variety of different future scenarios. The corresponding reduced risk from non-fueled resources should also be taken into account. Doing so will help avoid the risk of stranded assets that are not economical to fuel, operate, and maintain due to future scenarios. Relatedly, the models should adequately incorporate future scenarios that reflect climate science and the impacts climate change is having on Idaho Power's service territory, such as less reliable hydropower availability and more cooling days. DATED this 13th day of April 2026. �{ Ed Jewell, Deputy City Attorney CITY OF BOISE CITY'S CROSS-REPLY COMMENTS 2 CERTIFICATE OF SERVICE I hereby certify that I have on this 13th day of April 2026, served the foregoing documents on all parties of record as follows: Monica Barrios-Sanchez ❑ U.S. Mail Commission Secretary ❑ Personal Delivery Idaho Public Utilities Commission ❑ Facsimile 11331 W. Chinden Blvd., Ste. 201-A 0 Electronic Boise,ID 83714 ❑ Other: secretgUApuc.idaho.gov Jeff Loll ❑ U.S. Mail Deputy Attorney General ❑ Personal Delivery Idaho Public Utilities Commission ❑ Facsimile 11331 W. Chinden Blvd., Ste. 201-A 0 Electronic Boise,ID 83714 ❑ Other: jef.loll(kpuc.idaho.gov Donovan Walker ❑ U.S. Mail Lead Counsel ❑ Personal Delivery Idaho Power Company ❑ Facsimile PO Box 70 0 Electronic Boise, ID 83707 ❑ Other: dwalker e,idahopower.com dockets(k idahopower.com Timothy Tatum ❑ U.S. Mail Connie Aschenbrenner ❑ Personal Delivery Idaho Power Company ❑ Facsimile 1221 West Idaho Street(83702) 0 Electronic Boise, ID 83707 ❑ Other: ttatum(kidahopower.com caschenbrenner(kidahopower.com Eric L. Olson ❑ U.S. Mail Echo Hawk&Olson,PLLC ❑ Personal Delivery PO Box 6119 ❑ Facsimile 505 Pershing Avenue, Ste. 100 0 Electronic Pocatello, ID 83205 ❑ Other: elo(kechohawk.com Lance Kaufman,Ph.D. ❑ U.S. Mail Deborah Glosser,Ph.D. ❑ Personal Delivery 2623 NW Bluebell Place ❑ Facsimile Corvallis, OR 97330 0 Electronic lance e,ae isg insi hg t.com ❑ Other: deborah. log sser(kgmail.com CERTIFICATE OF SERVICE 1 Gregory M. Adams ❑ U.S. Mail Richardson Adams,PLLC ❑ Personal Delivery 515 N 27"'Street ❑ Facsimile Boise, ID 83702 0 Electronic g_reggrichardsonadams.com ❑ Other: Spencer Gray ❑ U.S. Mail Executive Director ❑ Personal Delivery NIPPC ❑ Facsimile PO Box 504 0 Electronic Mercer Island,WA 98040 ❑ Other: sgray&nippc.org Irion Sanger ❑ U.S. Mail Sanger Green,PC ❑ Personal Delivery 4031 SE Hawthorne Blvd ❑ Facsimile Portland, OR 97214 0 Electronic irion e,sanger-law.com ❑ Other: Austin Rueschhoff ❑ U.S. Mail Thorvald A.Nelson ❑ Personal Delivery Richard A.Arnett ❑ Facsimile Holland&Hart,LLP 0 Electronic 555 17"'St, Ste 3200 ❑ Other: Denver, CO 80202 darueschhoffkhollandhart.com tnelsonkhollandhart.com awj ensen(khollandhart.com raarnett e,hollandhart.com aclee nhollandhart.com tlfriel(khollandhart.com Michelle Steel, Paralegal CERTIFICATE OF SERVICE 2