20260415Reply Comments.pdf

-UIQAW POWER,
RECEIVED
DONOVAN WALKER APRIL 15, 2026
Lead Counsel IDAHO PUBLIC
dwalker(a)idaho power.corn UTILITIES COMMISSION
April 15, 2026
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-26-03
Application for Approval of the 2032 All-Source Request for Proposals to
Meet Capacity Resource Needs in as Early as 2031
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Reply Comments in the
above matter.
If you have any questions about any of the aforementioned documents, please do
not hesitate to contact me.
Very truly yours,
Donovan E. Walker
DEW:sg
Enclosures
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker(o-)idahopower.com
Attorney for Idaho Power Company
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 TO MEET ) IDAHO POWER COMPANY'S
CAPACITY RESOURCE NEEDS IN AS ) REPLY COMMENTS
EARLY AS 2031. )
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and,
pursuant to Idaho Public Utilities Commission's ("Commission") Rules of Procedure
("RP") 201-204 and the Notice of Modified Procedure, Order No. 36960, hereby
respectfully submits the following Reply Comments in response to Comments filed on or
before April 8, 2026, by parties to the case, including the Commission Staff ("Staff"),
Northwest & Intermountain Power Producers Coalition ("NIPPC"), and Idaho Irrigation
Pumpers Association, Inc. ("IIPA"). The Company's Reply Comments also address the
public comment filed on April 8, 2026, by Renewable Northwest ("RNW"), who while not
a party to the case, made several substantive recommendations related to the draft RFP.
Finally, the Company's Reply Comments address Cross-Reply Comments ("Cross-
Reply") filed by Staff and the City of Boise City ("Boise City") on April 13, 2026, to the
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

extent those comments were in response to positions already on the record. Collectively,
the Company refers to the abovementioned commentors as Stakeholders.
I. INTRODUCTION
On February 20, 2026, Idaho Power filed for approval of the Company's draft 2032
All-Source Request for Proposals ("RFP") for Peak Capacity & Energy Resources ("2032
RFP"), explaining the proposed 2032 RFP is necessary to position the Company to meet
its obligation to provide safe, reliable service to its customers. The 2032 RFP was
developed in accordance with the Commission's recently adopted Procedures for
Soliciting Large-Supply-Side Resources ("Solicitation Procedures").' To provide sufficient
time for bid submission and evaluation, Idaho Power has requested Commission approval
of the 2032 RFP by April 24, 2026, with issuance of the final RFP on April 27, 2026. The
proposed schedule supports identification of a Final Short List ("FSL") by July 17, 2026,
followed by contract negotiations and subsequent procurement, Commission approval,
and construction activities necessary to place least-cost, least-risk resources in service
as needed.
II. REPLY COMMENTS
The Company appreciates Staff's and other Stakeholders' review of the draft 2032
RFP. Notably, no Stakeholder opposed the Company's proposal to issue an RFP to meet
2031 and 2032 system needs, and Staff's comments reflect a review of the Company's
process for evaluating capacity deficits as new resources or new load are added.
Following that review, Staff found that it "agrees with the Company's practice of refreshing
the analysis and that a capacity deficit of at least 200 megawatts (WW") exists in 2031
Case No. GNR-E-25-01, Order No. 36898 (Jan. 2, 2026).
IDAHO POWER COMPANY'S REPLY COMMENTS -2

and 2032," and "believes it is reasonable to issue an RFP to procure additional
resources." Staff also found that the Company's RFP largely met the intent of the
Commission's Guiding Principles of the Solicitation Procedures, with limited exceptions.
In these Reply Comments, the Company responds to Stakeholders' comments on,
and recommended revisions to, the Company's draft 2032 RFP. As more fully explained
below, and in response to Stakeholder feedback, the Company proposes that the
Commission direct several targeted modifications to the 2032 RFP. To assist the
Commission in its review, the Company's proposed revisions to targeted sections or
exhibits of the 2032 RFP are included in redline format in Attachment 1.
A. Independent Evaluator
In its Application, Idaho Power did not propose the use of an Independent
Evaluator ("IE"), noting that the 2032 RFP selection will be conducted through a fair,
transparent, and confidential evaluation process in accordance with the Commission's
Solicitation Procedures.2 At the same time, Idaho Power acknowledged that while it was
not initially proposing to engage an IE, it was not opposed to the participation of an IE so
long as such participation would not compromise the proposed schedule and bidders'
ability to meet required in service timelines.
Stakeholder Comments
In its comments, Staff recognized the benefits of IE oversight but also highlighted
the potential for schedule delay if an IE is required, ultimately recommending that the
Commission evaluate whether the benefits of including an IE outweigh the risk of delay
at this stage of the solicitation. Staff further proposed that, as an alternative to an IE,
2 Hackett DI Testimony, p. 21.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

Commission Staff could provide direct oversight of the process, which would consist of
reviews at key decision points, during which the Company would present information
explaining its decision making and Staff would assess whether the Company's actions
are consistent with Commission guidance and orders. However, under this alternative
approach, Staff indicated it did not anticipate producing a final report typically prepared
by an IE, unless ordered by the Commission. Additionally, Staff encouraged Idaho Power
to provide timelines in its reply comments to assist the Commission in selecting an option:
(1) engagement of an IE used in prior solicitations, and (2) Staff only oversight.3 Finally,
Staff recommended the Commission direct the Company to accommodate a Staff review
of the selection and negotiation process while it is ongoing.4
Other Stakeholders recommend the use of an IE. I IPA asserted that Staff oversight
is "not equivalent" to an independent evaluator.5 NIPPC recommended that the
Commission require use of the same IE used in Idaho Power's two most recent RFPs
and further suggests that the IE be retained by, and report directly to, the Commission.6
RNW requested that Idaho Power voluntarily engage an IE, or that the Commission direct
Idaho Power to do so, and also acknowledged the Company's position that any such
engagement should preserve the proposed schedule.'
3 Staff Comments, p. 9.
4 Id., p. 10.
e IIPA Comments, p. 4.
s NIPPC Comments, p. 12.
RNW Comments, pp. 5-6.
IDAHO POWER COMPANY'S REPLY COMMENTS -4

In Cross-Reply, Staff opposed NIPPC's recommendation for the Commission to
require an IE be retained by and report directly to the Commission. While Staff
acknowledged NIPPC's recommendation may lead to reduced conflict of interest between
the Company and an IE, Staff noted that the State of Idaho's purchasing rules requires
competitive bidding, which would add unacceptable delay to the timeline.$ Staff also
opposes IIPA's recommendation that, if Staff provides evaluation oversight, it be held to
binding reporting obligations.9 Finally, Staff recommends the Company 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.10 In Cross-Reply, Boise City supports
comments requesting use of an IE.
Idaho Power Response
Idaho Power believes its initial proposal to conduct the RFP without independent
evaluator oversight is reasonable and would support a fair RFP process. However, the
Company understands the Commission's Guiding Principles of the Solicitation
Procedures to provide that the Commission will assess the need and appropriateness of
engaging an IE as part of each RFP. In consideration that the 2032 RFP at issue in this
case is the first RFP subject to the Commission's newly established procurement
guidelines, engaging an IE in this instance may provide beneficial transparency as this
new process develops. Based on Stakeholder feedback, and to address the concerns
raised in comments, the Company offers an alternative approach for the Commission's
8 Staff Cross-Reply Comment p.4.
9 Id.
10 Id.
IDAHO POWER COMPANY'S REPLY COMMENTS - 5

consideration that provides for independent review without introducing schedule impacts.
Notably, while Idaho Power appreciates Staff's willingness to provide independent
oversight in lieu of an IE, the Company believes development of a final closing report
documenting the evaluation and selection process — an outcome that Stakeholders
broadly supported — may provide meaningful transparency in this inaugural Commission
and Stakeholder RFP review. Accordingly, Idaho Power proposes to engage London
Economics International LLC ("LEI"), the same independent evaluator used in the
Company's 2026 and 2028 All Source RFPs, to participate in the 2032 RFP process. To
allow for that participation without impacting the proposed schedule, Idaho Power
proposes that LEI perform the same core functions it provided in prior solicitations,
including participating in the scoring of bids, validating benchmark bid assumptions and
calculations, and preparing a final closing report documenting its review of the evaluation
and selection process, however Idaho Power proposes that LEI provide a single final
report rather than interim reports in addition to the final report. Idaho Power does not
believe the interim reports are necessary as they add time to the process without
commensurate benefit. Limiting LEI's scope related to publishing reports to a single
comprehensive final report ensures that the Commission and Stakeholders receive the
full benefit of independent verification, while avoiding process inefficiencies or needless
schedule delays. Because Idaho Power can engage LEI and maintain the current
timeline, the Company does not believe it is necessary to provide additional detail
requested by Staff reflecting Staff only oversight.
This approach provides IE oversight in this initial RFP case, addresses the
concerns raised by intervenors and RNW regarding independence and verification, and
IDAHO POWER COMPANY'S REPLY COMMENTS - 6

preserves the proposed RFP schedule. Additionally, and consistent with Staff's
recommendation, Idaho Power is supportive of Staff's review of the selection and
negotiation process while it is ongoing — a role like that taken by Oregon Public Utility
Commission ("OPUC") Staff through the 2026 and 2028 processes. Finally, while NIPPC
suggests that the IE be retained by, and report directly to, the Commission, Idaho Power
does not believe this is necessary. The Company has an existing contractual relationship
with LEI and can efficiently engage LEI to provide independent oversight for the 2032
RFP, consistent with prior Commission approved procurements. As requested by Staff,
the Company will provide a copy of the IE contract following execution.
B. Imputed Debt
Idaho Power proposed inclusion of an imputed debt cost adder for third-party bids
as part of the bid evaluation process. The purpose of the imputed debt adjustment is to
reflect the potential financial impacts associated with long-term contractual obligations
(such as power purchase agreements and capital finance lease obligations) that credit
rating agencies may treat as debt-like obligations. Depending on the magnitude of
imputed debt and capital finance lease obligations, the credit metric impacts could lead
to a higher cost of capital, which, if realized, affect customer rates through higher financing
costs.
Stakeholder Positions
Staff, NIPPC, and RNW each recommend that the Commission disallow inclusion
of an imputed debt cost adder in the RFP evaluation. Staff concluded that imputed debt
is not appropriate in the economic evaluation of resource bids due to several reasons,
citing (1) a change in credit ratings and cost of debt due to imputed debt is uncertain
IDAHO POWER COMPANY'S REPLY COMMENTS - 7

because many other factors impact the Company's credit rating, (2) a similar adjustment
isn't proposed for comparable risks associated with Company-owned resources, (3)
imputed debt is not an actual cost incurred, (4) including imputed debt does not reflect
rate-relevant cost differences, and (5) the amount of the adder is not known and
measurable for ratemaking purposes." NIPPC asserted that Idaho Power's proposed use
of imputed debt is an arbitrary feature of the proposed RFP, and noted it was previously
criticized by Staff and rejected by the Oregon Public Utility Commission ("OPUC11),12
concluding the proposed imputed debt adder would strongly bias the RFP in favor of
utility-owned resources without any justification.13 IIPA indicates while it"does not dispute
that credit considerations are legitimate, the record contains no independent financial
analysis comparing the ratepayer cost of imputed debt treatment against the ratepayer
cost of increased rate base from utility ownership.1114 Notably, IIPA does not recommend
that imputed debt considerations be ignored altogether, instead, IIPA requests the
Commission condition its approval on Idaho Power's commitment to present the FSL both
with and without the imputed debt adder applied, as a means to transparency.15 RNW
also requests the Commission direct Idaho Power to eliminate the imputed debt adder,
11 Staff Comments, pp. 5-6.
12 NIPPC Comments, p. 6.
13 Id., p. 12.
14 IIPA Comments, p. 3.
15 Id.
IDAHO POWER COMPANY'S REPLY COMMENTS -8

arguing that it is unreasonable and unnecessary.16 Finally, in Cross-Reply, Boise City
supports Stakeholder comments requesting removal of the imputed debt adder.
Idaho Power Response
Imputed debt is a real, tangible, measurable aspect of long-term contractual
obligations arising from third-party ownership of utility resources, as evidenced by recent
meetings with, and actions by, the credit ratings agencies. Excluding imputed debt entirely
in the evaluation of resource decisions would result in a fundamental disconnect from the
realities of the costs that customers bear in their rates, whether it be interest costs
premised on credit metrics, more expensive equity for that same reason, or a more equity-
heavy capital ratio that results from the utility's need to over-equitize its balance sheet to
maintain credit metrics and avoid costly downgrades from the impact of imputed debt.
Idaho Power is charged with identifying and procuring least-cost, least-risk resources,
and failing to include the real cost of imputed debt is contrary to the least-cost element of
that mandate. NIPPC argues imputed debt is a "one-sided and arbitrary feature of the
RFP;" however, including imputed debt is precisely what makes the resource evaluation
an apples-to-apples comparison, and it results in neutrality, not a bias toward one party
or the other. When evaluating Company-owned resources, the Company's financing
costs during construction, Allowance for Funds Used During Construction ("AFUDC"), as
well as the Company's return component, are incorporated in the Ievelized cost of the
project. Similarly, as part of the review of third-party resources, the debt component, on
an imputed basis, should be evaluated as those projects will lever Idaho Power's balance
sheet for their financing.
16 RNW Comments p. 6.
IDAHO POWER COMPANY'S REPLY COMMENTS - 9

As additional background, Idaho Power competes with other companies in the
capital markets to obtain debt and equity financing necessary to operate its business and
fund capital projects. In seeking capital, one of the major factors banks and lenders
consider is a company's overall financial profile, including the strength of its balance
sheet. While Moody's and Standard & Poor's ("S&P") look at imputed debt differently,
they both evaluate future contractual obligations related to long-term power purchase
agreements ("PPA") and similar arrangements, like financing lease transactions (such as
a battery storage tolling agreement), as they consider future debt and debt-like obligations
of issuers during their ongoing monitoring of credit quality. The third party is ultimately
leveraging Idaho Power's balance sheet to develop and operate its project, with the PPA
or tolling agreement and underlying payment stream as collateral. Imputing debt is a
credit rating agency's way of transferring the project risk from the developer to the utility
because the contractual obligation of the utility is essentially providing cash flow and
credit support to the developer. It is analogous to a debt instrument that Idaho Power
executes, in that Idaho Power's ability to meet its long-term obligations on its
indebtedness is supported by its cash flows. Credit rating agencies account for this
transferred risk as a fixed debt obligation of the utility and impute this risk to the utility's
balance sheet, which affects the utility's financial and credit metrics, credit ratings,
perceived financial strength, and ultimately both the interest rates the utility pays on
indebtedness and the utility's cost of equity — both elements of financing costs.
In comments, Stakeholders rely heavily on reports, comments, and OPUC orders
that were produced or issued throughout 2022 and 2023. However, reliance on those
dated sources ignores the real and recent emphasis rating agencies are placing on these
IDAHO POWER COMPANY'S REPLY COMMENTS - 10

third-party arrangements — many of which the Company entered into after those reports
were issued.17 While the impact of PPAs on Idaho Power's credit metrics is less
measurable, through discussions with rating agencies, Idaho Power understands that
they are qualitatively assessed in final credit rating decisions. On the other hand, for
contracts that result in capital finance lease accounting (e.g., tolling agreements'$),
Generally Accepted Accounting Principles ("GAAP") require companies to impute debt
directly onto the balance sheet, and for Idaho Power, 2025 was the first year this
treatment applied.19 In its March 2026 review of IDACORP's credit rating, S&P considered
25 percent of the finance lease liabilities on Idaho Power's balance sheet as of December
31, 2025, as debt in its credit rating analysis. Because these types of obligations are
recognized on the balance sheet and relied upon by credit rating agencies, they represent
a real, measurable impact that must be considered in the evaluation of such
arrangements. As evidenced by S&P's March 2026 review, entering into additional
contracts that result in capital finance lease accounting will definitively impact IDACORP's
17 The Commission has approved the following PPAs and/or tolling agreements, by online year:
• 2023: 40 MW Solar PPA (IPC-E-22-06)
• 2024: 100 MW Solar PPA (IPC-E-23-05)
• 2025: 200 MW Solar PPA (IPC-E-22-29) and 150 MW BESS Tolling Agreement (IPC-E-23-20)
• 2026: 125 MW Solar PPA (IPC-E-24-01)
• 2027: 320 MW Solar PPA (IPC-E-24-42), 100 MW Solar PPA and 100 MW BESS Tolling
Agreement (IPC-E-25-10), and 80 MW Solar PPA(IPC-E-25-27)
'$ The 150 MW BESS Tolling Agreement approved by the Commission in Case No. IPC-E-23-20 came
online in 2025.
19 See Idaho Power Company Form 10-K for the year ended December 31, 2025, filed February 19, 2026,
at 80 (reporting approximately $217 million of Finance Lease Liabilities associated with the Kuna BESS
project).
IDAHO POWER COMPANY'S REPLY COMMENTS - 11

and Idaho Power's credit metrics.20 To illustrate: S&P's primary financial metric is Funds
from Operations / Debt. A capital finance lease increases the denominator of that
equation without changing the numerator, which reduces the ratio — without exception.
Therefore, each additional capital finance lease will result in further degraded credit
metrics. In contrast, a Company-owned project authorized for recovery would result in an
increase in both the denominator (the debt and equity component of the Company's
financing) and the numerator, which would lead to neutral or improved credit metrics. That
is, Staff's concern that imputing debt "does not monetarily account for comparable risks
associated with Company-owned resources"21 does not arise, as the result of two
otherwise identical projects is that a capital financing lease under GAAP authorized for
collection through rates will negatively impact credit metrics, whereas a Company-owned
project allowed for recovery in rates will not.
At a minimum, PPAs qualitatively harm credit ratings; however, the March 2026
rating review by S&P demonstrates capital finance lease liabilities result in a tangible
negative impact to credit metrics. Accordingly, it is both reasonable and appropriate to
include the impacts of imputed debt when evaluating projects. While Idaho Power had
initially included an imputed debt factor of 50 percent be applied to all third-party bids,
regardless of accounting treatment, in response to Stakeholder comments and in light of
the recent application by S&P, the Company proposes to reduce the imputed debt factor
from 50 percent to 25 percent at this time and apply it only to the projects that would result
20 Consistent with GAAP, expenses associated with the Crimson Orchard 100 MW BESS Tolling
Agreement will be recorded as an additional Finance Lease Liability in the Company's 2027 financial
statements.
21 Staff Comments, p. 5.
IDAHO POWER COMPANY'S REPLY COMMENTS - 12

in capital finance lease accounting. This change in the risk factor reduces the initially
proposed cost of imputed debt by half. For PPAs that do not result in capital finance lease
accounting, Idaho Power proposes to not apply an imputed debt risk factor (reducing the
cost of imputed debt for these PPAs to zero), but may qualitatively consider imputed debt
for such PPAs in the final report. The Company has included redline revisions to the
Levelized Present Value of the Revenue Requirement Scenarios in Exhibit J, consistent
with this proposed modification, in Attachment 1 .
C. Commercial Operation Dates
The 2032 RFP proposes to differentiate bids by commercial operation year for
evaluation specifically to those that can support the then-current needs in 2031 from bids
that cannot. Accordingly, the final shortlist would distinctly include projects in each
applicable year. The 2032 RFP also indicates that the Company is seeking bids proposing
First Delivery before May 31, 2032, and specifically between April 1 and May 31 of each
year (2031 and 2032).
Stakeholder Positions
In its comments, Staff indicated the 2032 RFP should be modified to include a
detailed explanation of the bifurcation process, as it does not believe the 2032 RFP
adequately explains to bidders that bids will be bifurcated into two groups which will
compete separately. Staff characterizes its understanding of its proposed approach by
noting that the "bids will be bifurcated into two groups which will compete separately" and
indicating that the Company "applied this practice in the 2026 and 2028 RFPs" and
"confirmed that it again intends to bifurcate the bids," referencing the Company's
IDAHO POWER COMPANY'S REPLY COMMENTS - 13

response to a production request.22 Additionally, Staff believes there is ambiguity
regarding what the Company will do with unsuccessful bids that could have achieved a
2031 commercial operation date ("COD") as to whether they would be automatically
moved to compete against bids with a 2032 COD.23
NIPPC raises a concern that the proposed 2032 RFP does not clarify whether
Idaho Power would accept bids from projects that must be placed in service prior to 2031
to capture the benefits of expiring tax credits.24 Pointing to Section 3.1 Eligible Proposals,
NIPPC highlights the "the requisite `First Delivery' as `Between April 1 and May 31 of the
respective year (2031 or 2032),' whereas "the Bid Eligibility Checklist merely states: `All
proposals must have a First Delivery date of May 31, 2032 or earlier.1125 NIPPC further
asserts that while a bidder had sought clarification from Idaho Power, the Company's
response was unclear. Similarly, RNW requests that Idaho Power voluntarily revise the
2032 RFP to explicitly call for bids with CODs before May 31, 2032, to be considered.26
In Cross-Reply, Boise City indicated support for NIPPC's comments regarding capturing
the expiration of tax credit benefits.27
22 Id., pp. 7-8.
23 Id., p. 8.
24 NIPPC Comments, pp. 19-20.
25 NIPPC Comments, p. 20.
21 RNW Comments, p. 5.
27 Boise City Comments, p. 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 14

Idaho Power Response
As an initial clarification, the process that was applied in the 2026 RFP and the
one applied in the 2028 RFP differed slightly from one another. The 2026 RFP provided
that Idaho Power "will separate and prioritize bids that can conform to meet a June 1,
2026, commercial operation separately from those that confirm to meet a June 1, 2027,
commercial operation." Whereas the 2028 RFP included similar language and an
additional provision indicating "[t]hose bids that conform to meet a later commercial
operation date will be evaluated subsequent to those that can meet the summer peak
2028." In practice, Idaho Power found the approach taken in the 2028 RFP to involve
additional complexity that made the process less straightforward for bidders when
compared to the simpler and more efficient 2026 process. As a practical matter, the
capacity deficiency in 2031 must be solved first, and in turn 2032 will be solved next.
Accordingly, Idaho Power intends to apply the same process as it did in the 2026
RFP, where the FSL could include both 2031 and 2032 bids. That said, the Company
acknowledges additional clarifying language sought by Staff would be beneficial for
inclusion in the final 2032 RFP. Providing clarifying language will also address Staff's
concern about potential ambiguity around how 2031 identified resources that may not be
competitive in 2031 may be brought forward to address the 2032 need. Idaho Power
proposes to include similar language from the 2026 RFP, with an additional clarification
to highlight that unsuccessful 2031 resources will be considered for 2032 deficiencies.
The proposed redlines to Section 7.1 of the 2032 RFP are reflected in Attachment 1 .
Regarding NIPPC and RNW's recommendations to clear up ambiguity around the
delivery dates or CODs that will be considered, Idaho Power proposes to include clarifying
IDAHO POWER COMPANY'S REPLY COMMENTS - 15

language in the definition of "First Delivery" which will clearly indicate all bids proposing
delivery prior to May 31, 2032, will be considered. For context, Idaho Power had initially
proposed a preferred "first delivery" window in each year between April 1 and May 31 with
the intent of aligning the dates on which new resources begin delivering or are brought
online to a single calendar quarter each year, for compliance purposes. Idaho Power is
required by Federal Energy Regulatory Commission ("FERC") regulations to submit a
market-based-rate authority "change in status" filing when the Company has cumulative
additions generation of 100 MW or more in any calendar quarter.28 This filing requirement
is time intensive, requires contracting with a third-party for specialized analysis, and is
costly. For that reason, to the extent practicable, Idaho Power prefers to align delivery or
commercial operation dates into a single calendar quarter each year, to allow it to
efficiently and in a least-cost manner comply with these FERC regulations, and intends
to negotiate with bidders on the Final Short List to align the delivery dates, to the extent
practicable. To be clear, all eligible bids, including those with earlier delivery dates, will
be evaluated and ranked according to the methodology described in Section 7 of the 2032
RFP to determine the least-cost, least-risk bids that meet the identified needs. The
redlines reflecting necessary changes to Tables 3-1 and 3-2 of the 2032 RFP are
reflected in Attachment 1.
D. Price and Non-Price Scoring Allocation
Idaho Power's bid evaluation framework relies on both price and non-price
assessments that are applied consistently to all bids. Price evaluation is conducted
28 Federal Energy Regulatory Commission Regulations, Change in Status Reporting Requirement, 18
C.F.R. § 35.42 (2025).
IDAHO POWER COMPANY'S REPLY COMMENTS - 16

through a quantitative comparison of levelized revenue requirements, which ranks bids
on a relative cost basis within the same technology, rather than through a point-based
weighting. Separately, non-price factors are evaluated using defined criteria set forth in
the RFP, with scores reflecting project maturity, siting and permitting status,
interconnection readiness, financing, and the bidder's ability to achieve commercial
operation by the required date. Together, these price rankings and non-price scores will
be used to identify a set of higher-ranking, lower-cost proposals that will make up the list
of projects that will advance for further portfolio modeling to determine the least-cost,
least-risk resource mix for customers.
Stakeholder Positions
NIPPC recommends the 2032 RFP utilize the same 75 percent price / 25 percent
non-price allocation that was relied on in Idaho Power's 2026 and 2028 RFPs, suggesting
Idaho Power's proposal replaces a transparent method with one that is opaque and
undefined.21 NIPPC goes on to state that "[i]n principle, the bid scoring process should be
structured in a way to ensure that the selection process is objective, transparent, and
aligned with the utility's goals of acquiring the least-cost and least-risk resources,"30 and
frames Idaho Power's proposal as one that will instead hide the weighting from all parties,
including the Commission. Finally, NIPPC cites to the Solicitation Procedures to highlight
29 NIPPC Comments p. 16.
so Id. pp. 16-17.
IDAHO POWER COMPANY'S REPLY COMMENTS - 17

the RFP "should include scoring factors."31 In Cross-Reply, Boise City indicated support
for NIPPC's comments.32
Idaho Power Response
The Company's proposed evaluation approach represents a modest change from
prior RFPs that assigned fixed point values to both price and non-price factors at the
outset. Under the proposed approach, price is evaluated through relative cost rankings
(i.e., the comparison of Ievelized revenue requirements), while non-price factors are
scored separately up to a maximum of 100 points using defined criteria focused on
whether a project is likely to be developed and delivered as proposed. NIPPC
characterizes this approach as less transparent because it does not assign fixed
numerical weights to both price and non-price factors at the initial screening stage. The
Company disagrees. Under the proposed approach, bidders and the Commission can
clearly see how price is compared on a relative cost basis and how non-price factors are
assessed using objective indicators of project viability.
The purpose of the initial shortlist is not to select projects or determine outcomes,
but to narrow the field to a set of reasonably priced, realistically deliverable projects
suitable for detailed portfolio analysis, and the Company's proposed method will achieve
that result. While the Company acknowledges that applying the prior methodology would
likely produce a similar initial shortlist, the Company does not believe reverting to fixed
weights is necessary. The FSL is developed following comprehensive portfolio modeling
that evaluates operational characteristics and overall system cost and risk, and it is that
31 Id. p. 17.
32 Boise City Comments, p. 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 18

later analysis — not the initial screening mechanics — that drives the ultimate resource
selection. Accordingly, modifying the process by which the initial short list is developed
does not reduce transparency or fairness in the process.
E. Benchmark Bids
The 2032 RFP allows for the submittal of resource-based proposals from Idaho
Power's Internal Bid Team, a team of Company personnel and retained consultants
responsible for developing benchmark bids. To eliminate the potential for bias, Idaho
Power has implemented its Separation of Functions ("SOF") protocol, under which
evaluation of bids received as part of the 2032 RFP is performed by a separate team of
Idaho Power personnel and retained consultants with relevant subject matter expertise
("Evaluation Team").
Stakeholder Positions
NIPPC recommends the Commission require Idaho Power to submit and score
benchmark bids prior to receipt and scoring of third-party bids, citing "best practice" and
asserting that, absent such a requirement, Idaho Power could adjust its benchmark bid
to beat third-party bids — or at a minimum that the requirement would preclude the
appearance that a utility could do s0.33 IIPA similarly supports pre-scoring of benchmark
bids, asserting that the Commission "cannot verify after the fact that the benchmark bid
was evaluated on its own merits" and arguing that this concern is heightened by the
ss NIPPC Comments, p. 18.
IDAHO POWER COMPANY'S REPLY COMMENTS - 19

elimination of the IE that previously provided that verification function.34 In Cross-Reply,
Boise City indicated support for NIPPC's comments.ss
Idaho Power Response
The process Idaho Power has proposed requires that all bids — including
benchmark bids — are submitted and evaluated under the same requirements, evaluation
criteria, and analytical framework. Because all bids advance through the same screening
and portfolio-level evaluation using uniform methodologies, the concern that Idaho Power
can modify a benchmark bid after reviewing third-party submissions is unfounded. That
said, as more fully described above, Idaho Power proposes to engage the services of LEI
to oversee and participate in the bid evaluation process, which addresses any reasonable
concern — actual or perceived — that benchmark bids could be adjusted based on
information from third-party submissions.
F. Technology-Based Bid Ranking
In the 2032 RFP, Idaho Power proposes to rank bids by technology, consistent
with its approach in the 2026 and 2028 RFPs. Under this approach, bids are first
evaluated and ranked relative to other bids within the same technology category,
recognizing that different resource types have distinct cost structures, operating
characteristics, and risk profiles. Technology based ranking allows for an initial screening
of bids on a comparable basis, while allowing resources of different types to later compete
against one another through portfolio level modeling to identify the least cost, least risk
sa IIPA Comments, p. 5.
ss Boise City Comments, p. 2.
IDAHO POWER COMPANY'S REPLY COMMENTS -20

resource mix to meet system needs. This approach is not new and reflects a continuation
of bid evaluation practices previously reviewed and accepted by the Commission.
Stakeholder Positions
For this element, NIPPC recommends a departure from prior practice, noting in
NIPPC's experience ranking bids by resource type is not a norm and that the practice can
lead to anomalous results. NIPPC's concerns appear rooted in the reliance on portfolio
modeling to develop the FSL, indicating that "reducing price bids to a technology neutral
metric for purposes of ranking and advancing bids reduces reliance on portfolio
modeling."36 In Cross-Reply, Staff recommended that the Commission reject NIPPC's
proposal, noting that 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.1137 In Cross-Reply, Boise City indicated support for NIPPC's
comments.38
Idaho Power Response
Idaho Power disagrees with NIPPC's characterization of technology based bid
ranking as anomalous or inappropriate. Ranking bids within technology categories at the
initial screening stage reflects a practical recognition that different resource types have
fundamentally different cost structures, operating characteristics, and risk profiles, which
cannot be meaningfully compared on a single, technology neutral metric in isolation.
Evaluating bids on a like for like basis within technology types allows Idaho Power to
ss NIPPC Comments, p. 22.
37 Staff Cross-Reply Comments p. 3.
38 Boise City Cross-Reply Comments p. 2.
IDAHO POWER COMPANY'S REPLY COMMENTS -21

identify competitively priced and realistically developable projects before advancing bids
for more detailed analysis.
Additionally, and contrary to NIPPC's suggestion, technology-based ranking does
not reduce reliance on portfolio modeling, nor does it pre-determine resource selection
outcomes. Rather, it serves as an initial filter to narrow the universe of bids to those that
are reasonably comparable and viable, while portfolio modeling remains the mechanism
through which different resource types ultimately compete against one another to identify
the least cost, least risk portfolio to meet system needs. This approach has been used in
prior RFPs — including the 2026 and 2028 solicitations — and continues to be appropriate
in this 2032 solicitation.
G. Minimum Bid Criteria
RNW highlights the draft 2032 RFP contains a minimum bid criteria that resources
rely upon "commercially-proven technology," noting at a high level, that while that
provision is reasonable, it could also be subjective in its application. Additionally, RNW
requests clarity around Bid Eligibility Factor number 9, which requires documentation that
generator interconnect status matches the COD submitted, pointing out the existing
language could inadvertently exclude competitive projects based on a "fictional
interconnection timeline."39 In both cases, RNW suggests one of three possible solutions:
(1) remove the criteria entirely, (2) clarify the meaning of the criteria, (3) move the items
from a minimum bid criteria to non-price scoring. In both cases, RNW notes any of these
three would be an improvement to the RFP.
39 RNW Comments p. 9.
IDAHO POWER COMPANY'S REPLY COMMENTS -22

Idaho Power appreciates RNW raising items that could benefit from additional
clarity, and consistent with RNW's recommendation for addressing its concerns, Idaho
Power proposes to clarify the meaning for each of the criteria. With respect to the term
"commercially-proven technology," Idaho Power proposes to revise this item in Exhibit C
to replace the term with "commercially available," which Idaho Power believes will
adequately address RNW's concern. With respect to the concern about documentation
regarding the generator interconnection process and dates, Idaho Power proposes to
replace the word "match" with "support" in Exhibit C, factor 9, and to add a sentence
clarifying documentation may include "a narrative explanation regarding the viability of
the Commercial Operation Date or Contract Effective Date." Redlines reflecting those
changes are presented in Attachment 1.
H. Modification to Draft RFP in Response to Bidder Request
On March 26, 2026, the Company filed a notice in this docket making parties aware
that it had received an inquiry from a bidder requesting clarification pertaining to a
proposed requirement outlined in Section 4.4 of the 2032 RFP, as well as Exhibits B_C_D
and FA. As it was researching the bidder's request, Idaho Power determined the
requirement as drafted was inadvertently overly prescriptive, and as result, identified
revised language that would be necessary to relax the requirement. The purpose of
submitting the notice in the docket was to make all intervening parties aware of a change
that Idaho Power would be proposing and to allow time for comment of the same.
Staff supported the Company's proposed revision. IIPA noted it didn't oppose the
substance of the revision; however, for clarity of the record, it is worth noting IIPA's
misunderstanding of Idaho Power's March 26, 2026, filing. In comments, IIPA took
IDAHO POWER COMPANY'S REPLY COMMENTS -23

exception, noting that Idaho Power "unilaterally" changed the RFP in response to a single
bidder inquiry, without Commission approval, highlighting the benefits of IE oversight."
The plain language contained in the notice submitted in the docket highlighted the
Company was "providing this notice to parties of the proposed changes to the draft 2032
RFP to allow time for parties' review and/or comment." Given Staff's support and no
Stakeholder opposition, the Company proposes the Commission direct it to implement
the proposed change as reflected in Attachment 1.
I. Additional Issues
Stakeholders also raised comments that were not directly related to the draft 2032
RFP. Those have been addressed below.
(1) Consideration for 2034 RFP
In its Comments, Staff evaluated the extent to which the Company's draft 2032
RFP aligns with the Commission's Solicitation Procedures, including the requirement that
solicitations provide sufficient lead time for resources to be developed and in service
when needed. Staff noted that the Company has improved lead time in this solicitation by
increasing it from approximately 3.6 years in the 2028 RFP to between 5.3 and 6.3 years
in the 2032 RFP. Citing the Company's pre-filed testimony regarding supply-chain lead
times for certain technologies, Staff further observed that longer lead times may be
necessary for some resource types and suggested the Company consider a future
solicitation beyond 2032.
The Company appreciates Staff's thoughtful review and analysis and agrees that
careful, ongoing evaluation of long-term system needs is essential. Consistent with that
ao IIPA Comments, p. 4.
IDAHO POWER COMPANY'S REPLY COMMENTS -24

practice, the Company will continue to refresh its planning analyses as new information
becomes available and, as those analyses demonstrate additional resource need, will
consider the appropriate timing of future solicitations to ensure it remains positioned to
procure least-cost, least-risk resources for customers.
(2) Additional Firm Load and Class Cost-of-Service
IIPA references a Commission order from a prior resource approval case,41 where
the Commission declined, in that docket, to address cost causation arguments raised by
IIPA for consideration. Pointing to that order, IIPA asserts that in order to support
meaningful cost-of-service analysis, the Commission should direct Idaho Power to:
"maintain disaggregated capacity modeling throughout the RFP evaluation that isolates
the share of identified capacity need attributable to AFL load versus the existing customer
base, and shall preserve those modeling outputs as part of the RFP record for use in the
pending COS proceeding.1142
Idaho Power understands IIPA's intense interest in understanding and addressing
cost causation, however its request in this case is both unreasonable and unduly
burdensome. Under Idaho law, Idaho Power has an obligation to provide adequate,
efficient, just, and reasonable service on a nondiscriminatory basis to all those that
request it within its service area,43 and the Company does not evaluate the system
capacity position and/or identify needed resources with and without additional firm load
or customer class. While on the surface, IIPA represents its recommendation "does not
41 In the Matter of Idaho Power Company's Application for Approval of a Power Purchase Agreement with
Blacks Creek Energy Center, LLC, Case No. IPC-E-25-27, Order No. 36954 (Mar. 5, 2026).
42 IIPA Comments, p. 6.
43 Idaho Code§ 61-302.
IDAHO POWER COMPANY'S REPLY COMMENTS -25

affect bid evaluation" and "imposes no burden on bidders," implying it is only asking the
Commission to direct Idaho Power to preserve data already available, IIPA's request
plainly read is for Idaho Power to run two separate bid evaluations. This is not only
unreasonable, but also unnecessary. In the same order referenced by IIPA in its
comments, the Commission also found: "[i]t is well-established that the Company has an
obligation to serve both existing and new customers without discrimination" and "[t]he
Company has a system-wide need for capacity, without regard to cost causation.1144 It is
not appropriate in this case to expect or require the Company to evaluate its system need
and resource selections with and without certain segments of customers.
IIPA has intervened in the referenced class cost-of-service docket,45 where they
are afforded the right to issue discovery and take positions on cost allocation through their
intervention in that docket or other or rate making proceedings. It is most appropriate to
ask for the contribution of certain classes of customers relative to the remaining system
during those proceedings — that is, the Company does not need to run and maintain
separate analyses as it identifies viable projects to meet system capacity deficiencies in
order for IIPA to have access to the type of information that is necessary to inform cost
allocation.
(3) Distributed Energy Incentives
In Cross-Reply, Boise City referenced support for a public comment encouraging
the Commission to consider whether redesigned incentives for distributed generation
as Order No. 36954, p. 6.
as The Company filed its Application in IPC-E-26-07 on March 31, 2026, and IIPA filed its Petition to
Intervene the next day, April 1, 2026.
IDAHO POWER COMPANY'S REPLY COMMENTS -26

could cost-effectively supplement the Company's capacity deficiencies.46 Idaho Power
does not agree that consideration of distributed generation is relevant in this proceeding
or necessary to address the issues before the Commission. The Company already
accounts for customer on-site generation resources in its load forecasting and planning
processes, and any incremental contribution from such resources is reflected in the
Company's assessment of system needs.
III. PROPOSED REVISIONS TO 2032 RFP
Because the Company intends to proceed with issuing its 2032 RFP promptly
following receipt of the Commission's order,47 the Company respectfully requests the
Commission provide clear direction in its order as to what changes to its draft 2032 RFP
the Company is directed to make. To assist in that review — and based on the input
received from Stakeholders — the Company has developed several proposed revisions it
believes either fully resolve Stakeholder concerns or, where competing considerations
are present, reasonably balance those considerations. As more fully described above,
the Company did not propose revisions in response to every Stakeholder comment where
existing requirements were appropriate. The Company requests the Commission approve
the RFP with the following revisions, which are presented in Attachment 1 in redline form
for the Commission's review:
41 Boise City Cross-Reply Comments p. 2.
47 In its Application, the Company requests an Order by April 24, 2026, to facilitate issuance of the final
2032 RFP by April 27, 2026.
IDAHO POWER COMPANY'S REPLY COMMENTS -27

• RFP Tables 3-1 and 3-2, Eligible Proposals: Modify description of "First
Delivery" in Tables 3-1 and 3-2 to clarify delivery must occur prior to May
31, 2032.
• RFP Section 4.4, Interconnection Studies and Cost Estimating: Change
language to clarify projects must have submitted a generator interconnect
request.
• RFP Section 7.1, The Evaluation Process: Add language clarifying that
Idaho Power will separate and prioritize bids that can meet 2031 needs
separately from those that meet 2032 needs. Clarify bids that can meet
2031 needs that are not selected for the 2031 FSL will automatically be
considered to meet 2032 needs.
• Exhibit B C D — Bid Entry Form:
o Factor 2: Remove reference to Network Integration Interconnection
Service
o Factor 6: Change "commercially-proven" to "commercially available"
o Factor 9: Change "match" to "support" and add language clarifying
acceptance of narrative explanations regarding the viability of the
COD or contract effective date
• Exhibit FA — Draft Form Agreements for Resources Based Bids: In item 2
of Terms for All Gas-Fired Resources, remove reference to Network
Integration Transmission Service
• Exhibit J, Levelized PVRR Scenarios:
o Remove the imputed debt risk factor from Scenarios 1 and 4 to
remove this factor from the evaluation of PPAs.
o Add Scenario 8 providing an example of a Levelized PVRR for a
Capital Finance Lease, i.e., a battery services agreement, which
includes a 25% risk factor for imputed debt
Additionally, while a change to the language contained in the 2032 RFP is not
needed, Idaho Power also requests the Commission direct it to engage with LEI to provide
IE oversight. Specifically, and to limit unnecessary schedule delays, the Commission
should direct Idaho Power to contract with LEI to participate in the scoring of bids, validate
benchmark bid assumptions and calculations, and prepare a final closing report
documenting its review of the evaluation and selection process.
To the extent the Commission declines to adopt any of the Company's proposed
revisions or recommendations, wishes to adopt with modifications, or seeks to include
IDAHO POWER COMPANY'S REPLY COMMENTS -28

additional requirements, the Company respectfully requests the Commission outline
those directives in its order.
IV. CONCLUSION
Idaho Power respectfully requests that the Commission issue an order by April 24,
2026, approving the Company's 2032 RFP with the revisions identified herein, and
directing the Company to proceed with LEI as an IE to oversee the evaluation process.
Commission approval with clear direction on necessary revisions to the RFP will allow the
Company to issue the final RFP by April 27, 2026, which is necessary to position the
Company to meet its obligation to provide safe, reliable electric service to its customers.
DATED at Boise, Idaho, this 15t" day of April 2026.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS -29

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15t" day of April 2026, 1 served a true and correct
copy of Idaho Power Company's Reply Comments upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Jeffrey Loll U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email
PO Box 83720 Jeff.loll _puc.idaho.gov
Boise, ID 83720-0074
Idaho Irrigation Pumpers Association, Hand Delivered
Inc. U.S. Mail
Eric L. Olsen Overnight Mail
Echo Hawk & Olsen, PLLC FAX
505 Pershing Ave., Ste. 100 FTP Site
Pocatello, Idaho 83205 X Email
elo(a�echohawk.com
taysha _echohawk.com
Lance Kaufman, Ph.D. Hand Delivered
Deborah Glosser, Ph.D. U.S. Mail
2623 NW Bluebell Place Overnight Mail
Corvallis, OR 97330 FAX
FTP Site
X Email
lance _aegisinsight.com
[e-mail]
Northwest Intermountain Power Hand Delivered
Producers Coalition U.S. Mail
Gregory M. Adams Overnight Mail
Richardson Adams, PLLC FAX
515 N. 27t" Street FTP Site
Boise, Idaho 83702 X Email
greg richardsonadams.com
IDAHO POWER COMPANY'S REPLY COMMENTS - 30

Irion Sanger Hand Delivered
Sanger Greene, PC U.S. Mail
4031 SE Hawthorne Blvd. Overnight Mail
Portland, OR 97214 FAX
FTP Site
X Email
irion _sanger-Iaw.com
Spencer Gray Hand Delivered
Executive Director U.S. Mail
P.O. Box 504 Overnight Mail
Mercer Island, WA 98040 FAX
FTP Site
X Email
sgray(a-).nippc.org
CITY OF BOISE CITY Hand Delivered
Ed Jewell U.S. Mail
Boise City Attorney's Office Overnight Mail
150 N. Capitol Blvd. FAX
Boise, ID 83701 FTP Site
X Email
ejewell cityofboise.org
boisecityattorney(abcityofboise.org
Katie O'Neil Hand Delivered
Energy Program Manager U.S. Mail
Boise City Department of Public Works Overnight Mail
150 N. Capitol Blvd. FAX
Boise, Idaho 83701 FTP Site
X Email
[e-mail]
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Richard A. Arnett FAX
Holland & Hart LLP FTP Site
555 17t" Street, Suite 3200 X Email
Denver, CO 80202 darueschhoff(a)hol land hart.com
tnelson hollandhart.com
raarnettCa)-hol land hart.com
aclee _hollandhart.com
tlfriel(a-)hollandhart.com
IDAHO POWER COMPANY'S FINAL COMMENTS - 31

Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S FINAL COMMENTS - 32

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-26-03
IDAHO POWER COMPANY
ATTACHMENT 1

RFP Tables 3.1 and 3.2, Eligible Proposals: Modify description of"First Delivery" in Tables 3.1 and 3.2 to clarify
delivery must occur prior to May 31, 2032.
Table 3-1. Resource Based Proposal Scope Summary
Scope Item Description
Ownership and Asset Purchase Agreements (which may include Build-Transfer Agreements
Agreement Types (BTA)) — Asset acquisition of the proposed facility and related assets,
where the Seller assumes development and construction risk.
Power Purchase Agreements (PPA) — Power purchase for energy, capacity,
and all environmental attributes from a facility.
Battery Storage Agreements (BSA) — Purchase of capacity and the
charging/discharging of energy from battery facilities.
Any hybrid proposals that include multiple resource technologies co-located
using the same point of interconnection will also require operational
agreements that establish protocols related to scheduling and dispatch
(for example solar+ battery energy storage system (BESS)).
Term IPC is not prescribing a specific term requirement but prefers terms consistent
with the life of the asset.
First Delivery to Prior to May 31, 2032. IPC will evaluate all bids that provide delivery by that
Idaho Power date. IPC prefers commercial operation dates (or,for existing resources, date of
commencement of delivery to IPC) b8etween April 1 and May 31 of the
respective year(2031 and 2032) and,to the extent practicable, will negotiate
with bidders to align the delivery date within that window..-.
Resource Status Existing (which can deliver incremental capacity that is not otherwise already
contracted with IPC) or proposed new late-stage development.
Dispatch Rights For dispatchable generation (e.g., storage and gas-fired generation), IPC will
have the right to dispatch the facility across the full range of the proposed
capacity(0-100%), contingent on the capabilities of the generator(e.g.,
minimum dispatch level, ramp rates)
Interconnection IPC Transmission System or Non-IPC Transmission Systems with all necessary
transmission rights to the IPC BA area
Delivery Point Within the boundary of the BA, or outside with all necessary transmission
rights to the BA
Other If the facility generates environmental attributes, bids must include all
environmental attributes, including Renewable Energy Certificates (REC), if any.
Bidders will be responsible for ensuring RECs are bundled, and that they are
established through Western Renewable Energy Generation Information
System (WREGIS).
Proposed pricing for Asset Purchases shall include Operating and Maintenance
(O&M), Long-Term Services Agreement (LTSA), and warranty costs for the
proposed term.
Page 11

Table 3-2. Market Purchase Proposals
Scope Item Description
Contract Structure Agreement for purchase of firm energy and capacity(prefer WSPP Agreement
Schedule C or equivalent) meeting WRAP eligibility requirements for qualifying
contracts. Agreement may take the form of a confirmation under a mutually
agreeable master agreement (e.g., WSPP or other), or a mutually agreeable
standalone agreement.
Term 3 years or more preferred.
Delivery Months Either or both summer (June—September) or winter(November—February)
preferred. IPC will consider other proposals.
First Delivery Prior to May 31, 2032. IPC will evaluate all bids that provide delivery by that
date. IPC prefers first delivery dates between April 1 and May 31 of the
respective year(2031 and 2032) and, to the extent practicable, will negotiate
with bidders to align the delivery date within that window.getweeR ApFi A
May 31 ef the respective year (2031 and_2()92).
Pricing Index-based preferred, but IPC will consider other proposals. Pricing should not
include costs of regulatory structures not applicable in Idaho or Oregon and
should be based on a product with sinking in Idaho or Oregon.
Product Capacity with callable energy. Prefer flexibility to shape energy deliveries and
quantities into specific days or hours. IPC will consider other proposals.
Interconnection IPC Transmission System, or Non-IPC Transmission Systems with all necessary
transmission rights to an eligible Point of Delivery
Delivery Point Delivery to an eligible Point of Delivery as listed in Exhibit E—Transmission
Paths and Delivery Points.
3.2. ALTERNATIVE PROPOSALS
IPC may also accept other proposal types that meet the intent and electrical functionality criteria
outlined in this RFP. Bidders who submit a proposal not specifically identified in this RFP must fully
describe how their bid can meet the general desires and intent of the RFP. Proposal types that are not
eligible include but are not limited to; energy or capacity that is not electrical (e.g.,thermal energy
storage without conversion to electric energy); renewable energy credits without the associated
energy(Unbundled RECs); and financial instruments used to mitigate variable cost exposure without
associated energy or capacity(Financial Firming).
3.3. TRANSMISSION ALTERNATIVES
As part of IPC's IRP processes, in addition to supply-and demand-side resources, IPC is directed to give
equal and balanced treatment to transmission resources.Therefore, IPC will also accept bids for
transmission ownership, service, or long-term rights that may meet energy and capacity needs
identified above.
Page 12

RFP Section 4.4, Interconnection Studies and Cost Estimating: Change language to clarify projects must
have submitted a generator interconnect request.
The interconnection facility types are specified below.
Interconnection Facilities
• Interconnection Customer's Interconnection Facilities (ICIF) are all facilities and equipment
(including the generation tie line) located between the resource and the Point of Change of
Ownership. Bidder must submit resource-specific cost estimates of ICIF as part of its bid and
consider the cost of ICIF in its pricing.
• Transmission Provider Interconnection Facilities (TPIF) connect the Interconnection
Customer's Interconnection Facilities to the Transmission Provider transmission system and
facilitate the metering, relaying and communications, etc.TPIF are all facilities owned,
controlled, or operated by the Transmission Provider from the Point of Change of Ownership
to the Point of Interconnection.These are facilities that the Transmission Provider will own,
and the Bidder will fund.The Bidder must submit resource-specific cost estimates of TPIF as
part of its bid and consider the cost of TPIF in its pricing. In the absence of an estimate, IPC will
develop an estimate based on available information. If an interconnection study has been
performed by the Transmission Provider that includes an estimate of TPIF,then the costs from
that study should be used.
Network Upgrades
• Station Network Upgrades (SNU) are either new switchyards or additions to existing
switchyards or substations built to interconnect the generator to the IPC transmission or
distribution system. SNUs become a component of the integrated IPC transmission or
distribution system and are incorporated into IPC tariffs. Bidders are required to provide cost
estimates of SNUs.
• Delivery Network Upgrades (DNU) are upgrades to IPC's transmission or distribution network
that will be required for individual resources and groups of resources. DNUs become a
component of the integrated IPC transmission or distribution system and are incorporated
into IPC tariffs. Bidders are required to provide cost estimates of DNUs.
Based on information available from the GI request and/or studies and estimates performed by the
Transmission Provider(s), separate and apart from the Evaluation Team (if available),the Evaluation
Team will determine bid-specific SNUs and DNUs and associated reimbursable costs to include in the
evaluation of a bid. The Evaluation Team's development of bid-specific SNUs/DNUs does not take the
place of the IPC Open Access Transmission Tariff(OATT) GI and transmission studies and does not
remove the Bidder's obligation to submit GI or transmission requests to the Transmission Provider(s).
With respect to transmission service, for resources that will be owned in full or in part by IPC or for
which IPC will have an executed contract for the purchase of the generation, IPC anticipates it will
designate the resource or executed contract as Network Resources of IPC under the OATT upon
commercial operation of the resource or first delivery date under the contract. Projects that are
seeking to interconnect to IPC's system must have submitted a GI request Nletvgerrk ReSe Fee
Page 15

RFP Section 7.1,The Evaluation Process:Add language clarifying that Idaho Power will separate and
prioritize bids that can meet 2031 needs separately from those that meet 2032 needs. Clarify bids that
can meet 2031 needs that are not selected for the 2031 FSL will automatically be considered to meet
2032 needs.
Commerce's Denied Persons List, Unverified List or Entity List, or other export/import control lists; or
(b) for any purpose prohibited by Trade Control and Sanctions Laws.
Notwithstanding any consent of IPC given pursuant to Section 3.23.1, under no circumstances shall
Bidder use any Chinese manufactured unmanned aerial vehicles (drones), including but not limited to
those manufactured by Shenzhen DJI Sciences and Technologies Ltd. or Autel Robotics, in the
performance of this Agreement.
6.9. SMALL BUSINESS AND SMALL DISADVANTAGED BUSINESS
PROGRAM
IPC is committed to the implementation of a Small and Disadvantaged Business Program. It is the
intent of IPC that small business concerns and small businesses owned and controlled by socially and
economically disadvantaged individuals have the opportunity to participate in the performance of
contracts awarded by IPC. Consequently, IPC requests that Bidders indicate their eligibility as a small
business based upon the regulations in Title 13, Code of Federal Regulations, Part 121. If in doubt,
Bidders should consult the Small Business Administration Office in their area.
6.10. INSURANCE
Bidder is directed to the Exhibit F—Draft Form Agreements for Resource Based Proposals for details
concerning insurance requirements that must be met.
6.11. FINANCIAL AND CREDIT INFORMATION
Bidder must provide a written response and associated documents in response to the Counterparty
Financial Questionnaire. Details are further described in Exhibit H—Counterparty Financial
Questionnaire of this RFP.
6.12. CLARIFICATION OF BIDS
While evaluating a bid, IPC may request clarification or additional information from the Bidder about
any item in its bid. Such requests will be sent via the Portal or via email by IPC and the Bidder must
provide a response back, respectively,to IPC within five (5) business days, or IPC may deem the Bidder
to be non-responsive and either suspend or terminate further evaluation of its bid. Bidders are
encouraged to provide an alternate point of contact to ensure a timely response to clarification
requests.
6.13. ADDENDA TO RFP
Any additional responses required from Bidders as a result of an addendum to this RFP shall become
part of each bid. Bidders must acknowledge receipt of and list all addenda where indicated in the BEF.
7. Bid Evaluation, Negotiation and Approval
7.1. THE EVALUATION PROCESS
The bid evaluation and selection process are designed to identify the combination and size of
proposed resources that will maximize customer benefits and will satisfy projected resource capacity
and energy needs while maintaining reliability.The portfolio optimization models used to identify the
Page 23

proposed resources are the same that IPC uses to evaluate proxy resources in the 2025 IRP (and
subsequent IRPs). IRP portfolio optimization process details can be found in IPC's 2025 IRP Sections 9
and 10.
IPC will separate and prioritize bids that can meet 2031 needs separately from those that meet 2032
needs. Bids that can meet 2031 needs, but that are not selected for the Final Shortlist to meet 2031
needs specifically,will automatically be considered in the evaluation of bids to meet 2032 needs.
The Selection Plan, or bid evaluation process, is described below.
7.2. PHASE 1 - INITIAL SHORTLIST
Phase 1 of the bid evaluation process includes the screening, evaluation, and ranking of the bids,
including the IPC Internal Bids,to identify a subset that can be advanced for further evaluation (the
Initial Shortlist).This includes: 1) bid eligibility screening to ensure conformance with the Minimum
Requirements; 2) price and non-price evaluation to score and rank bids; and 3) identification of the
bids for inclusion in the Initial Shortlist. The bids will be categorized by the commercial operation
date.
IPC will rely on the Information provided within the Bid Package to screen, evaluate, and rank bids.
During this phase of the bid evaluation process, IPC does not anticipate asking for, nor accepting,
updated pricing or updates to any other bid components (with the exception of updates identified in
Section 6.5). However, IPC may contact Bidders to confirm and clarify information presented in each
bid if necessary.
Additionally, if at any time during Phase 1, a Bidder determines its submitted bid is no longer valid,the
Bidder should notify IPC immediately and the bid will be withdrawn from further consideration.
Conformance to Minimum Requirements
Bids will initially be screened against the Minimum Requirements using Exhibit C—Bid Eligibility
Checklist. Bidders of non-conforming bids will be notified and the bid will be removed from
consideration.
Price and Non-Price Scoring, Ranking, and Initial Shortlist
Resource Based Proposals Non-Price Score (up to 100 points)
The non-price evaluation rubric for Resource Based Proposals is included in Exhibit D— Non-Price
Scoring Sheet. IPC's non-price scoring model evaluates whether bids are thorough and
comprehensive,whether the proposed resource is viable, and whether the Bidder is likely to achieve
commercial operation by the proposed date. Bidders must provide documentation, representation,
warranties, and other information as necessary to sufficiently assure IPC that any proposed project
will complete construction and achieve full commercial operation by the defined commercial
operation date.The non-price rubric is designed to be objective, intuitive, and self-scoring. Bidders are
required to score themselves by answering each of the non-price questions and providing supporting
documentation.The non-price questions are utilized to score and rank bids based on, among other
factors,the completeness of the Bid Package and adherence to the bid requirements,the ability to
contract with the project,the maturity of the project including site control, permitting,generator
interconnection
Page 24

Exhibit B C D—Bid Entry Form:
o Factor 2:Remove reference to Network Integration Interconnection Service
o Factor 6:Change"commercially-proven"to"commercially available"
o Factor 9:Change"match"to"support"and add language clarifying acceptance of narrative explanations regarding the viability of
the COD or contract effective date yes
No
Bid Eligibility Factor
Bid Eligibility Submittal Completeness-Bidder completed each of
NO. the following items accurately and in a manner consistent with the
RFP requirements.
Resource Based Proposal-Bid is submitted on or before the submittal deadline and all applicable forms have been completed and
submitted.
Bid narrative in accordance with the Bid Format and Requirements(Exhibit N)
[Eligibility],[Resource Based Non-Pricing],and the applicable[3rd Party Owned Pricing]and[IPC Asset Purchase Pricing]tabs
1 Redlines/Issues List to Draft Form Agreements/Term Sheets(Exhibit F)
Counterparty Financial Questionnaire(Exhibit H)
Draft Form Letter of Credit(Exhibit 1)
Forecasted Hourly Renewable Output,if applicable(Exhibit K)
Cyber Security Questionnaire(Exhibit L)
Gas-Fired Resources-Fuel Questionnaire,if applicable(Exhibit M)
Resource Based Proposal-The Bidder is in
2 the IPC Generator Interconnection Queue and will be delivered to a Point of Delivery on IPC's transmission system OR if the Facility will be
interconnected to a third-party transmission system,Bidder has provided documentation that demonstrates it has submitted applicable
transmission service requests to the relevant Transmission Provider to establish transmission rights to deliver to IPC point of delivery.
3 Resource Based Proposal-The Bid has established Site Control for the Facility.
Resource Based Proposal-Bidder has provided a Development Schedule identifying the timeline and schedule including contract execution,
4 full notice to proceed,and major engineer,procure,and construct milestones to ensure delivery at the proposed commercial operation
date. The Development Schedule shall include,in addition to the timeline and major milestones,a description of risks,their influence on the
project's critical path,and any mitigation strategies.
5 Resource Based Proposal(dispatchable generation only)-Bid includes IPC's ability to commit,decommit,and dynamically schedule(e.g.,
automatic generation control("AGC"))the Facility.
6 Resource Based Proposal-The Bid is for a resource with commercially-available pfeveiq technology.
7 All Proposals must have a First Delivery date of May 31,2032 or earlier.
8 Evidence of wire transfer provided prior to bid deadline in the correct amount for the correct number of bids.
Documentation submitted indicates the viability of a Commercial Operation Date(Resource Based Proposals)or Contract Effective Date
(Market Purchase Proposals)that matehes supports the COD submitted.
Documentation may include,as applicable,GIA status and timely interconnection capability;federal,state,and local permitting
requirements and decisions;land-use and site control requirements and decisions;construction plans and schedules;procurement
documentation;financing capability and sources;and other relevant documentation necessary to demonstrate timely viability of the project.
9 Documentation may also include a narrative explanation regarding the viability of the Commercial Operation Date or Contract Effective
Date.
Bidder must provide details of public and community outreach(tactics,audience,goals,etc.)at a local level to identify the viability of a
project's success. Idaho Power may utilize local knowledge and experience to gauge relative outreach when scoring.
Idaho Power will also consider(and bidder must identify)pending,actual,or threatened administrative,legal,legislative,procedural,and
other actions(federal,state,or local)that could impact timely viability.
Market Purchase Proposal-Bid is submitted on or before the submittal deadline and all applicable forms have been completed and
submitted.
10 Bid narrative in accordance with the Bid Format and Requirements(Exhibit N)
[Market Purchase Non-Pricing]and[Market Purchase Pricing]tabs
Counterparty,Financial Questionnaire(Exhibit H)
11 Market Purchase Proposal-Bid of firm energy and capacity(prefer WSPP Agreement Schedule C or equivalent)meeting Western Resource
Adequacy Program(WRAP)resource specificity,transmission and other requirements.
12 Market Purchase Proposal-The minimum WRAP Qualified Capacity Contribution requirement is met.

Exhibit F.4—Draft Form Agreements for Resources Based Bids: In item 2 of Terms for All Gas-Fired Resources,remove reference to
Network Integration Transmission Service
Terms for All Gas-Fired Resources
Term Description of Term
1 Facility Capacity: Facility provides for flexible generation with [ MW] of net capacity
(measured at the Electric Interconnection Point (as defined in item 2 below))
under Summer Conditions ("Summer Rated Capacity").
2 Electric The "Electric Interconnection Point" will be a point where the Facility will be
Interconnection interconnected to the host utility, as specified by Bidder in the applicable Bid.
and The Electric Interconnection Point must be consistent with Bidder's generator
Transmission interconnection application.
Bidder will be responsible for (and will bear the full costs and risks of) the
arrangement, procurement, and receipt of the interconnection, deliverability,
and transmission facilities and service required for the Facility and for Full
Deliverability (as defined below) of the Facility to Buyer's load. This includes,
but is not limited to, the arrangement, procurement, payment for construction,
installation, and readiness for energization, operation, and maintenance of
any required electric interconnection facilities and any system interconnection
and transmission upgrades.
The Buyer will be required to pursue and procure Retwerk reseUFGe
interconnection service ("NRIS") that equals or exceeds the Guaranteed
Capacity, and full deliverability of at least the Guaranteed Capacity from the
Facility to Buyer's load on a firm network resource basis for the life of the
Facility, (collectively, "Full Deliverability"), where applicable.
Terms Specific to Build-Transfer Agreements
Term Description of Term
1 Buyer's Closing Seller has in place (i) the full capability to transport fuel to, and receive delivery
Conditions of fuel at, the fuel interconnection point(s), and (ii) all agreements and all
approvals and other authorizations necessary for transport of fuel to, and
receipt of delivery of fuel at, the fuel interconnection point(s), and available for
immediate use by the Facility from and after Closing
2 Facility The Definitive Agreement will provide for tests of the performance of the
Performance Facility, including the individual generating units, to be conducted, at Seller's
Testing: expense, prior to Closing. The tests will cover (i) Guaranteed Base Capacity
and Guaranteed Duct-Firing Capacity (if included as part of the Facility), (ii)
Guaranteed Base Heat Rate and Guaranteed Duct-Fired Heat Rate (if duct

Exhibit J, Levelized PVRR Scenarios:
o Remove the imputed debt risk factor from Scenarios 1 and 4 to remove this factor from the evaluation of PPAs.
o Add Scenario 8 providing an example of a Levelized PVRR for a Capital Finance Lease,i.e.,a battery services agreement,
which includes a 25%risk factor for imputed debt
Idaho Power 2032 All Source RFP
Exhibit J-Levelized PVRR Scenarios
Idaho Power 2032 All Source RFP-Exhibit J-Levelized Present Value of the Revenue Requirement Scenarios
Proposed Initial Scenario Proposed Initial Scenario Proposed New
Scenario 1 1 deleted Scenario 4 4 deleted Scenario 8
Scenario 1 geegafw4 Scenario 2 Scenario 3 Scenario 4 Seeaacis4 Scenario 5 Scenario 6 Scenario 7 Scenario 8'
Simple Cycle
PPA Iw/2% PPA(wj 294 BTA(20 year Self Build(20 PPA Iw/2% P BTA(35 year Self Build(35 Combustion Capital Finance
esc. esc-4 life) year life) esc. e-4 life) year life Turbine Lease(BSA)
1 $6,570,000 $8 79,809 $12,027,498 $12,027,498 $9,855,000 $12,762,388 $16,189,525 $16,189,525 $19,336,483 $8,331,833
2 $6,701,400 ' ",", 3 $10,935,086 $10,935,086 $10,052,100 °i,43-1,',"' $14,846,663 $14,846,663 $18,688,236 $8,308,356
3 $6,835,428 $8487 284 $10,790,549 $10,790,549 $10,253,142 °1, 23,296 $14,544,453 $14,544,453 $18,280,308 $8,283,552
4 $6,972,137 co o 747 $10,600,542 $10,600,542 $10,458,205 $",302,604 $14,261,137 $14,261,137 $17,884,986 8 257 347
5 7111 579 $8,688,382 $10,383,371 $10,383,371 $10,667,369 °1�-480,517 $13,832,147 $13,832,147 $17,501,489 $8,229,661
6 $7,253,811 $9 7er-795,93�^ 3 $9,868,615 $9,868,615 $10,880,716 c"667 036 $13,330,741 $13,330,741 $17,129,099 $8,200,410
7 $7,398,887 °8 3KA29 $9,929,320 $9,929,320 $11,098,331 °�''"' $12,829,826 $12,829,826 $16,767,155 $8,169,507
8 $7,546,865 $9,973-679 $9,671,873 $9,671,873 $11,320,297 °i4 04,294 $13,299,992 $13,299,992 $16,415,051 $8,136,858
9 $7,697,802 °�-063,74 $9,414,743 $9,414,743 $11,546,703 $14,174,321 $12,967,063 $12,967,063 $16,072,231 $8,102,365
10 $7,851,758 ,'^ 49683^O°' $9,157,938 $9,157,938 $11,777,637 $14,34 ,43 $12,732,852 $12,732,852 $15,738,185 $8,065,922
11 $8,008,793 $9�""' $8,901,469 $8,901,469 $12,013,190 °'4,05,204 $12,499,195 $12,499,195 $15,412,447 $8,027,421
12 $8,168,969 $9°io'908 $8,645,344 $8,645,344 $12,253,454 c1"665'o^ $12,266,107 $12,266,107 $15,094,589 $7,986,744
13 $8,332,349 $9'38; "' $8,389,574 $8,389,574 $12,498,523 $14,820,904 $12,033,606 $12,033,606 $14,784,222 $7,943,769
14 $8,498,996 $9 454,645 $8,134,171 $8,134,171 $12,748,493 $ Ate7,°" $11,801,710 $11,801,710 $14,480,991 $7,898,366
15 $8,668,975 $9�J-J18,646 $7 879 144 $7,879,144 $13,003,463 e,`�-117,4 7 $11,570,435 $11,570,435 $14,184,573 $7,850,398
16 $8,842,355 $9°moo`^^ 7 $7,624,505 $7,624,505 $13,263,532 $ 6,'�- 119 $11,339,802 $11,339,802 $13,894,673 $7,799,719
17 $9,019,202 $9"pT628,99A^^" $7,370,266 $7,370,266 $13,528,803 °"�^,97 $11,109,827 $11,109,827 $13,611,027 $7,746,177
18 $9,199,586 $9,674479 $7,116,438 $7,116,438 $13,799,379 cis'S1-o486 $10,880,533 $10,880,533 $13,333,394 $7,689,610
19 $9,383,578 $9,7m,^"^ $6,863,034 $6,863,034 $14,075,367 °1, 34,1^' $10,651,938 $10,651,938 $13,061,557 $7,629,847
20 $9,571,249 $9,74=-'°58 $6,610,066 $6,610,066 $14,356,874 $16,743,62^ $10,424,063 $10,424,063 $12,795,324 $7,566,707
21 $14,644,012 °15, 43,362 $10,196,930 $10,196,930 $10,866,349
22 $14,936,892 $ °`932 O58 $9,970,561 $9,970,561 $11,868,624
23 $15,235,630 $16, 11,09" $9,744,979 $9,744,979 $11,649,015
24 $15,540,342 °ic 77'993 $9,520,207 $9,520,207 $11,432,120
25 $15,851,149 $16 129,82v^°^°'^ $9,296,270 $9,296,270 $11,218,009
26 $9,073,191 $9,073,191 $11,006,754
27 $8,850,998 $8,850,998 $10,798,429
28 $8,629,716 $8,629,716 $10,593,111
29 $8,409,372 $8,409,372 $10,390,876
30 $8,189,994 $8,189,994 $10,191,806
31 $7,971,612 $7,971,612
32 $7,754,254 $7,754,254
33 $7,537,952 $7,537,952
34 $7,322,737 $7,322,737
35 $7,108,641 $7,108,641
Total $159,633,720 $49as44-,297 $180,313,545 $180,313,545 $315,658,604 4 $382,989,029 $382,989,029 $424,481,111 $160,224,570
MW 50 30 50 50 75 73 7S 75 100 50
MWhs 131,400 , w 197,100 ,w 197,100 197,100 175,200
PV(with Discount Delay) $85,199,474 a99 31, `^ $106,460,694 $106,460,684 $145,246,091 $" 902 098 $170,102,326 $170,102,326 $204,953,080 $90,136,140
Levelized Payment $7,905,234 '^'�'455 $9,877,955 $9,877,955 $12,217,635 $ A 678°°' $12,823,766 $12,823,766 $16,152,935 $8,363,282
Levelized$/kw-month 513.18 $19.42 $16.46 $16.46 13.58 $16.31 $14.25 $14.25 $13.46 13.94
Levelized$/MWh $60.16 $70.42 $61.99 $74.47 $65.06 $65.06
Number of Years 20 20 20 20 25 2-5 35 35 30 20
Product Type Solar sew BESS BESS Solar 6elar Solar Solar Gas BESS
Escalation 2.00%
Discount Rate 6.78%
Discount Delay 0.50
Foot Notes:
1.Includes a 25%risk factor for imputed debt.