Reply Comments.tif

DONOVAN WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
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Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2025 VARIABLE ENERGY
RESOURCE INTEGRATION STUDY AND
PROPOSED UPDATE TO SCHEDULE 87
)
) CASE NO. IPC-E-25-36
)
) IDAHO POWER COMPANY'S
) REPLY COMMENTS ________________)
Idaho Power Company ("Idaho Power" or "Company") hereby respectfully submits
the following Reply Comments in response to comments submitted by Idaho Public
Utilities Commission ("Commission") Staff ("Staff') and Idaho Winds LLC ("Idaho Winds")
pursuant to the Commission's Notice of Modified Procedure, Order No. 36947, in the
above-referenced case.
I.INTRODUCTION
On December 26, 2025, in Compliance with Order No. 36661, the Company
submitted its 2025 Variable Energy Resource ("VER") Study and proposed updates to
Schedule 87, Intermittent Generation Integration Charges, ("Schedule 87") rates.
Comments on the Company's filing were submitted by Idaho Winds and Staff on April 13,
2026, and April 16, 2026, respectively.
IDAHO POWER COMPANY'S REPLY COMMENTS -1
IDAHO POWER COMPANY’S REPLY COMMENTS - 2
II. STAFF COMMENTS
Within its comments, Staff recommends the Commission acknowledge that the
Company complied with Order No. 36661, as well as direct Idaho Power to file an update
to Schedule 87 through a compliance filing reflecting:1
 An effective date based on the date of the Commission’s final order in this
case;
 That the tiers of integration charges are based on qualifying facilities’
(“QFs”) incremental nameplate capacity, instead of penetration levels; and
 Integration charges based on a discount rate of 7.41 percent and an
escalation rate of 2 percent.
Additionally, Staff recommends that as part of the Company’s next VER Study, the
Company work with Staff to study or address the following issues:2
 Whether it is reasonable to use weighted integration charges for wind and
solar QFs that cross the 100-megawatt (“MW”) threshold;
 The relationship between reserve shortfalls and capacity inadequacy in
terms of their contributions to the unreliability of a system and whether the
capital and fixed operation and maintenance costs of incremental resources
should be allocated between the purpose of meeting reserve requirements
versus the purpose of meeting load requirements;
 The amount of over and/or under-estimation of integration costs of on-site
generation;
1 Staff Comments at 1-2 (April 16, 2026).
2 Id., at 2.
IDAHO POWER COMPANY’S REPLY COMMENTS - 3
 If and how on-site generation could be represented through a proxy;
 Whether forecasted QFs should be included in the Base Portfolio;
 Whether the Reliability and Capacity Assessment Tool model and the
Aurora model should be calibrated for the amount of reserves;
 Whether there are costs associated with downward reserves that should be
included in integration charges;
 Whether contingency reserves should be treated as integration reserves;
 Why the cost of following reserves is not zero and what impact it has on
integration charges; and
 Whether the calculation method for the 100-200 MW rates is reasonable.
III. IDAHO WINDS COMMENTS
Idaho Winds’ comments recommend that the Commission direct Idaho Power to
update the Base Portfolio used in its VER Study to account for resource changes of high
certainty that have occurred since issuance of the latest Integrated Resource Plan (“IRP”).
Additionally, Idaho Winds requests that the Commission direct Idaho Power to set
integration charges for renewing3 QFs based on their original online date and technology
type or, if determined to be unfeasible for every QF, establish a single rate for renewing
QFs based on the average integration costs of the Base Portfolio.4 Until these issues are
3 Idaho Power notes that Idaho Winds uses different terminology than the Company in discussing a QF
entering into another contract upon the expiration of its existing contract. While Idaho Winds uses the
term “renew,” Idaho Power uses the term “replace” to describe this concept, as the new contract that is
entered into is not a “renewal” of the prior contract, it is a new contract with new applicable rates, terms,
and conditions.
4 Idaho Winds Comments at 7 (April 13, 2026).
IDAHO POWER COMPANY’S REPLY COMMENTS - 4
addressed, Idaho Winds requests that the Commission not approve the Company’s 2025
VER Study.5
IV. COMPANY REPLY
The Company appreciates Staff’s collaboration throughout the development of its
2025 VER Study, as well as Staff’s thorough review and assessment of its filing.
Additionally, the Company appreciates Staff’s recommendation that the Commission
acknowledge the Company’s compliance with Order No. 36661.
The Company believes Staff’s proposed updates to Schedule 87 are reasonable.
The Company also agrees to work with Staff as part of developing its next VER Study on
the items laid out in Staff’s comments.
Idaho Power acknowledges the concerns raised by Idaho Winds but believes some
of the associated VER Study recommendations to be impractical and unnecessary.
Specifically, Idaho Winds’ request that the VER Study’s Base Portfolio be updated to
reflect resource changes of high certainty that have occurred since the issuance of the
latest IRP is not feasible considering this would effectively require the Company to re-run
its time-intensive IRP-related analyses and incorporate such results within the VER
Study, a process that typically spans the course of a year. While Idaho Winds suggests
this update should occur based on Commission directive related to the setting of avoided
cost rates using the incremental cost IRP methodology,6 Idaho Power clarifies that these
are fundamentally different analyses, and each relies on distinct processes with
substantially different computational constraints and run times. Notably, the Company’s
completion of the VER Study and associated analyses, which utilize unmodified IRP
5 Id., at 1.
6 Id., at 2.
IDAHO POWER COMPANY’S REPLY COMMENTS - 5
outputs, currently requires the full six-month timeframe provided by Order No. 36661. As
such, any resource changes that may subsequently occur after the Base Portfolio is
established can only reasonably be addressed when the Company determines integration
costs as part of a future, routine7 VER Study update, the cadence of which is intended to
help maintain relevancy of Schedule 87’s integration charges.
The Company also disagrees with Idaho Winds’ recommendation that the
Commission direct it to set integration charges for renewing QFs based on their original
online date and technology type. As noted above, QF contracts are not “renewed” but
rather replaced with new contracts that have new applicable rates, terms, and conditions.
Therefore, replacement contracts are, in effect, new contracts and should be subject to
the applicable Schedule 87 integration charges at the time they are negotiated. However,
the Company agrees with Idaho Winds that the percentage of replacement QFs
considered within the VER Study’s Base Portfolio has the potential to result in a “double
counting” of integration costs.8 Because no QF projects’ contracts are expected to expire
prior to the next integration charge update,9 there is no immediate impact to remedy.
Accordingly, the Company intends to address the issue of whether forecasted QFs should
be included in the Base Portfolio through its work with Staff ahead of developing its next
VER Study.
7 Order No. 36661 (IPC-E-25-07) requires the Company to file a new VER Study within six months of
filing its most recent IRP.
8 Idaho Winds Comments at 3.
9 The Company is required to file its 2027 VER Study within six months after the filing of its 2027 IRP
which will be filed in June 2027 (IPC-E-25-07, Order No. 36661, p. 4). The next QF project will expire in
December 2028, allowing for resolution of the Commission’s review of the 2027 VER Study and updated
Schedule 87 rates.
IDAHO POWER COMPANY’S REPLY COMMENTS - 6
V. CONCLUSION
The Company appreciates Staff and Idaho Winds’ comments in this matter and
respectfully requests the Commission issue an order (1) acknowledging that the
Company complied with Order No. 36661, (2) directing the Company to file an updated
Schedule 87 in a compliance filing that reflects the items noted in Staff’s comments, and
(3) directing the Company to work with Staff to address the issues noted in their
comments prior to submitting its next VER Study.
DATED at Boise, Idaho this 30th day of April 2026.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S REPLY COMMENTS - 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of April 2026, I 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
Kelsea E. Ross
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
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Idaho Winds, LLC
Irion Sanger
Sanger Greene PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
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Adam Rabin
Idaho Winds, LLC
5420 West Wicher Road
Glenns Ferry, ID 83623
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Stacy Gust
Regulatory Administrative Assistant