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Home My WebLink About20260413Staff_Cross_Reply_Comments.pdf RECEIVED April 13, 2026 JEFFREY R. LOLL IDAHO PUBLIC DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83702 (208) 334-0357 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 ) CROSS-REPLY 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. ("IIPA") 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 CROSS-REPLY COMMENTS 1 APRIL 13, 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 REP 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, NIPPC, and IIPA filed cross-reply comments on April 8, 2026, and Renewable Northwest also filed public comments on April 8, 2026 (collectively"Comments"). STAFF ANALYSIS Staff reviewed the Comments and does not have any objections to the various recommendations, with three exceptions. Staff recommends that the Commission reject the following three proposals: 1. NIPPC's recommendation to rank bids without regard to resource type; 2. NIPPC's recommendation for the Commission to contract directly with an Independent Evaluator("IE"); and 3. IIPA's recommendation to assign binding reporting obligations to Staff if Staff is assigned to audit the bid evaluations. Application at 2. 2 Id. at 2-3. 3 Id. at 5. 4 Id. 5 Id. at 6. 6 Id. at 6-7. 7 Id. at 7. STAFF CROSS-REPLY COMMENTS 2 APRIL 13, 2026 Staff discusses its reasons for rejecting these proposals below. Reject Ranked Bids Without Regard to Resource Type In its comments, NIPPC "recommends that the Company revise the RFP to the extent necessary to discontinue the practice of ranking bids by resource type for purposes of developing the shortlist."8 NIPPC's concern is that if no other competitors exist in that resource category,the bid will be automatically moved forward, irrespective of price. The next step in the process is for the Company's Aurora model to determine the 20-year net present value ("NPV") for its entire portfolio plus the new resource. NIPPC "is generally concerned with heavy reliance on portfolio modeling in RFPs because it lacks transparency and can be impacted by faulty, or potentially even biased, modeling assumptions."9 In other words, the Aurora cost modeling is where the true comparison of cost- effectiveness occurs between dissimilar resources,and NIPPC is uncomfortable with Aurora's lack of transparency. Instead,NIPPC recommends that the Company adopt a pre-determined algorithm to adjust the pricing of each resource type to normalize for the different resource characteristics.10 Staff believes this is not reasonable. Staff believes the Aurora model is the most detailed, accurate method available to quantify the cost-effectiveness and contribution to reliability of each resource within the Company's system. Furthermore, without a detailed review of the method NIPPC proposes, Staff has no way to determine if its proposal is a reasonable substitute. Staff also notes that even if NIPPC's proposal is accepted, the next step will still be to run all the finalists through the Aurora model. Thus, the supposed lack of Aurora transparency will still exist in the process. Regarding Aurora's transparency, Staff believes that the Aurora inputs, assumptions and results can be made available for analysis. Furthermore, the Company should be using model parameters from the Company's Integrated Resource Plan ("IRP"), which are thoroughly vetted by Staff and other interested parties during and after each IRP cycle. Staff believes the additional complexity to analyze Aurora data is worth the additional accuracy it provides with regard to the cost-effectiveness of each resource. 8 NIPPC Comments at 21. 9 Id. at 22. 10 Id.footnote 44. STAFF CROSS-REPLY COMMENTS 3 APRIL 13, 2026 Therefore, Staff recommends that the Commission reject NIPPC's proposal and instead let the RFP selection process continue to rank bids by each resource type. Reject Commission Contracting Directly with an IE Should the Commission decide that an IE is necessary for this case, NIPPC recommends that "the Independent Evaluator be retained by, and report directly to, the Commission."11 Staff agrees that this recommendation would reduce the conflict of interest between an IE and the Company. However, Staff is concerned that the States's purchasing rules require competitive bidding, which would add unacceptable delay to the timeline. Although Staff does not object to using an IE to provide oversight of the Company's selection process, Staff does not believe the Commission directly contracting the IE is feasible. If the Commission orders an IE to provide oversight, Staff recommends that the Company contract with the IE used in past RFPs, consistent with Staff s original comments in this case. Staff also recommends that the Commission require the Company to file a copy of the contract as a compliance filing to ensure none of the provisions confer any bias to, or create undue conflict of interest with, the Company. Reject Binding Reporting Obligations to Staff In its comments, IIPA recommends that the Commission "require the participation of an independent evaluator, or in the alternative, require Commission Staff to audit bid evaluations on a concurrent, real-time basis with binding reporting obligations...."12 Staff believes it is not feasible to fulfill both the real-time audit obligations and the binding reporting obligations in the timeframe necessary to support the Company's schedule. Based on the Company's proposed timeline, the bid evaluation will occur in June 2026, a month that is typically compressed due to annual Spring filings. Staff reiterates its proposal to not"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."13 If the Commission orders Staff to perform oversight of the RFP, Staff recommends that the Commission reject IIPA's recommendation that Staff have binding reporting obligations. "Id.at 15. 12 IIPA Comments at 1 (emphasis added). 13 Staff Comments at 9. STAFF CROSS-REPLY COMMENTS 4 APRIL 13, 2026 STAFF RECOMMENDATIONS In conclusion, Staff maintains its recommendations included in its initial comments. Staff also does not object to the recommended changes from other parties, with the following three exceptions: 1. Reject NIPPC's recommendation to rank bids without regard to resource type; 2. Reject NIPPC's recommendation for the Commission to directly contract with an IE; and 3. Reject IIPA's recommendation to mandate Staff reports if Staff is assigned to audit the bid evaluations. Respectfully submitted this 13th day of April 2026. Jeffrey R. Loll J Deputy Attorney General Technical Staff. Matt Suess, Steven Verdieck, Kimberly Loskot, Karla Ducharme I:\Utility\UMISC\COMMENTS\IPC-E-26-03 Cross-Reply Comments.docx STAFF CROSS-REPLY COMMENTS 5 APRIL 13, 2026 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF APRIL 2026, SERVED THE FOREGOING CROSS-REPLY 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: dwalker(d),idahopower.com E-MAIL: dockets&idahopower.com ttatum&idahopower.com caschenbrenner(d),idahopower.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. 27th Street Pocatello, ID 83205 Boise, ID 83702 elo(a),echohawk.com greg(a,richardsonadams.com taysha(k 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(d),,sanger-law.com lance&ae isg insi hg t.com deborah. log sser(cgmail.com Spencer Gray Executive Director,NIPPC P.O. Box 504 Mercer Island, WA 98040 sgray�ic,ni]2pc.org STAFF CROSS-REPLY COMMENTS 6 APRIL 13, 2026 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 boisecityattomey( ,,cityofboise.org koneil(&,,cityof6oise.org eiewell&cityofboise.org Intervenor: Micron Austin Rueschhoff Thorvald A. Nelson Richard A. Arnett Holland& Hart, LLP 555 17a' St., Ste. 3200 Denver, CO 80202 darues chhoff khollandhart.com tnelson(d,hollandhart.com raamett(khollandhart.com aclee(d),,hollandhart.com tlfriel&hollandhart.com PATRICIA JORDAA, SECRETARY STAFF CROSS-REPLY COMMENTS 7 APRIL 13, 2026