Compliance Filing.tif

IDAHO POWER COMPANY’S COMPLIANCE FILING - 1
DONOVAN E. WALKER (ISB No. 5921)
LISA C. LANCE (ISB No. 6241)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
FOSSIL GULCH WIND PARK, LLC FOR
THE SALE AND PURCHASE OF ELECTRIC
ENERGY FROM THE FOSSIL GULCH
WIND PARK.

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CASE NO. IPC-E-25-31

IDAHO POWER COMPANY’S
COMPLIANCE FILING

Idaho Power Company (“Idaho Power” or “Company”) hereby respectfully submits
to the Idaho Public Utilities Commission (“Commission”) the accompanying Compliance
Filing in compliance with Final Order No. 36956 in the above-captioned case.
I. INTRODUCTION AND BACKGROUND
On September 30, 2025, Idaho Power filed an Application requesting approval of
an Energy Sales Agreement (“ESA” or “Agreement”) and Interim Agreement with Fossil
IDAHO POWER COMPANY’S COMPLIANCE FILING - 2
Gulch Wind Park, LLC (“Seller”) for the purchase of electric energy from the Fossil Gulch
Wind Park (“Project” or “Facility”) located in Twin Falls County, Idaho.
On March 5, 2026, the Commission issued Final Order No. 36956 approving the
ESA and the associated Interim Agreement, subject to the Company submitting a
compliance filing containing an updated ESA that incorporates the following specific
modifications directed by the Commission:
1. Recalculate the avoided cost of energy and the avoided cost of capacity
using the AURORA model from the Company’s 2025 Integrated Resource
Plan (“IRP”), based on the Facility’s updated generation profile and
reflecting resource changes of high certainty as of September 26, 2025;
2. Reestablish the Maximum Capacity Amount by either limiting it to 10
megawatts (“MW”) or adopting a bifurcated rate structure;
3. Correct the calculation description in Article 6.4.4, update the definition of
Surplus Energy, remove the modification language included in Appendix B,
and correct the error in Appendix E.
This Compliance Filing and the First Amendment to the ESA, submitted herewith
as Attachment 1, address each of these directives.
II. RECALCULATION OF AVOIDED COST OF ENERGY AND CAPACITY
Consistent with Order No. 36956, Idaho Power has recalculated the avoided cost
of energy and avoided cost of capacity using the AURORA model from the Company’s
2025 IRP. The recalculations are based on the Facility’s updated generation profile and
reflect resource changes of high certainty as of September 26, 2025, the date the parties
IDAHO POWER COMPANY’S COMPLIANCE FILING - 3
executed the ESA. These revised avoided cost inputs are incorporated into the ESA via
the First Amendment submitted alongside this Compliance Filing.
III. MAXIMUM CAPACITY AMOUNT AND BIFURCATED RATE STRUCTURE
Pursuant to Order No. 36956, the Company and Seller have elected to adopt a
bifurcated rate structure, rather than reduce the Maximum Capacity Amount to 10 MW.
The bifurcated rate structure reflected in the updated ESA compensates generation up to
10 MW at a rate that includes the avoided cost of energy, the avoided cost of capacity,
and applicable wind integration charges. Generation attributable to the additional 0.5 MW
above the 10 MW threshold is compensated at a separate rate that includes the avoided
cost of energy and applicable wind integration charges, without the avoided cost of
capacity component.
The bifurcated rate is applied on an hourly basis. For each billable hour, the
Company totals the Facility’s delivered energy. The portion of total hourly delivered
energy up to 10 MW is paid at the full avoided cost of energy, avoided cost of capacity,
and wind integration charge. Any hourly delivered energy in excess of 10 MW is paid at
the bifurcated rate, which excludes the avoided cost of capacity. This structure ensures
any energy delivered above 10 MW does not receive capacity compensation prior to the
applicable capacity deficiency date (June 2027), consistent with the Staff’s
recommendation and the Commission’s directive in Order No. 36956. Effective June 1,
2027, the Facility will receive a rate that includes the avoided cost of energy, avoided cost
of capacity, and wind integration charge for all generation.

IDAHO POWER COMPANY’S COMPLIANCE FILING - 4
IV. CONTRACTUAL CORRECTIONS REQUIRED BY ORDER NO. 36956
In addition to the revisions described above, the First Amendment submitted with
this Compliance Filing incorporates the contractual modifications directed by the
Commission in Order No. 36956. Article 6.4.4 has been revised to clarify that shortfall
damages are calculated based on 85 percent of the Calculated Net Energy Amount. The
definition of Surplus Energy has been updated by removing Item 1. The modification
language included in Appendix B has been removed, and Appendix E has been corrected
by replacing the reference to “item d” with “item 4.”
V. REQUEST FOR RELIEF
The Company respectfully requests that the Commission approve the Amended
Energy Sales Agreement, submitted in compliance with the Commission’s directives in
Final Order No. 36956.

Respectfully submitted this 4th day of May 2026.

LISA C. LANCE
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S COMPLIANCE FILING - 5
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 4th day of May 2026, I served a true and correct
copy of the within and foregoing Idaho Power Company’s Compliance Filing upon the
following named parties by the method indicated below, and addressed to the following:

IPUC COMMISSION STAFF
Adam Triplett
Deputy Attorneys General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074

Hand Delivered
_ U.S. Mail
Overnight Mail
FAX
X Email – [e-mail]

________________________________
Stacy Gust,
Regulatory Administrative Assistant

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-25-31

IDAHO POWER COMPANY

ATTACHMENT 1
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 1 of 9
FIRST AMENDMENT
TO THE
ENERGY SALES AGREEMENT
BETWEEN
IDAHO POWER COMPANY
AND
FOSSIL GULCH WIND PARK, LLC

This First Amendment of the Energy Sales Agreement (“ESA” or “Agreement”) is entered
into on this ____ day of ________ 2026, by and between Idaho Power Company, an Idaho
corporation (“Idaho Power”, “Company”, or “Buyer”), and Fossil Gulch Wind Park, LLC
(“Seller”), (individually a “Party” and collectively the “Parties”).
WHEREAS, Parties entered into an ESA under the Public Utilities Regulatory Policies
Act of 1978 (“PURPA”) on September 26, 2025, for the purchase and sale of generation produced
by the Fossil Gulch Wind Park (“Facility”) with an Initial Term of two (2) years from the
Scheduled Operation Date, which was approved by the Idaho Public Utilities Commission’s
(“IPUC”) on March 5, 2026, in Order No. 36956 subject to Idaho Power submitting a compliance
filing containing an updated ESA that incorporates the modifications described in Order No.
36956; and
WHEREAS, Order No. 36956 directed that: (1) the avoided cost of energy and capacity
be recalculated using the AURORA model from the Company’s 2025 IRP, including resource
changes of high certainty as of September 26, 2025, and based upon the Facility’s updated
generation profile; (2) in establishing the Maximum Capacity Amount, the Company and Seller
have the option to either set the amount at the original 10 MW or adopt the bifurcated rate design
described by Staff; (3) the calculation description in Article 6.4.4 be corrected making shortfall
damages based on 85% of the Calculated Net Energy Amount; (4) the definition of Surplus Energy
be updated by removing Item 1 of the definition; (5) the modification language included in
Appendix B be removed; and (6) an error in Appendix E be corrected by replacing “item d” with
“item 4.”
WHEREAS, the Parties have agreed to revise the ESA to incorporate the modifications
directed by Order No. 36956.
NOW, THEREFORE, in consideration of the foregoing, and for other good and valuable
consideration, the receipt and adequacy of which are hereby acknowledged, and intended to be
legally bound, the Parties hereto agree as follows:
1. Incorporation of Recitals. The above-stated recitals are incorporated into and made a
part of this First Amendment by this reference to the same extent as if these recitals were set forth
in full at this point.
2. Amendment. The agreement is hereby amended and revised as follows (deletions in
strikethrough, additions in underline, all in red text):
Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
29th April
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 2 of 9
A. Recalculation of Avoided Cost of Energy and Capacity, Updated Generation
Profile, and Election to use Bifurcated Rates.

The avoided cost of energy and capacity have been recalculated using the 2025
Integrated Resource Plan (“IRP”) inputs into the AURORA model, instead of the 2023 IRP
inputs, including all resource changes of high certainty as of September 26, 2025, and based
on the Facility’s updated generation profile as determined by the Seller. Additionally, the
Seller elected a Maximum Capacity Amount of 10.5 MW and the adoption of a bifurcated
rate that includes the avoided cost of energy and capacity and wind integration charges for
hourly generation up to 10 megawatt hours (MWh), and a second rate of avoided cost of
energy and wind integration charges without avoided cost of capacity for any hourly
generation above 10 MWhs, until the first capacity deficit date of June 2027. These
changes are hereby incorporated into the ESA by the Amended Table 1 in Article 6.2 and
the Amended Appendix G as set forth below:
Table 1
Initial Year Monthly Net Energy Amounts
Month kWh
January 2,124,689 2,163,501
February 2,642,414 2,253,280
March 2,894,202 2,428,546
April 2,796,527 2,600,583
May 2,014,372 2,218,964
June 1,552,145 1,883,951
July 1,178,857 1,344,186
August 1,411,821 1,368,982
September 1,483,324 1,518,647
October 1,840,740 1,807,793
November 1,771,591 2,093,483
December 2,361,486 1,992,641

Appendix G “Monthly Purchase Prices” should be deleted in its entirety and replaced with
the following Appendix G Amended Monthly Purchase Prices and Appendix G Amended
Bifurcated Monthly Purchase Prices:
Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 3 of 9
APPENDIX G
Monthly Purchase Prices

Month-Year
Base Energy Heavy Load
Purchase Price Components

Base Energy Light Load
Purchase Price Components

Integration
Charge

Energy
Price
Component
Capacity
Price
Component
Energy Price
Component
Capacity
Price
Component
(Mills/kWh) (Mills/kWh) (Mills/kWh) (Mills/kWh) (Mills/kWh)
Oct-25 $31.30 $7.56 $27.77 $7.56 $0.95
Nov-25 $37.55 $7.56 $36.14 $7.56 $0.95
Dec-25 $62.20 $7.56 $57.60 $7.56 $0.95
Jan-26 $35.88 $7.75 $33.18 $7.75 $0.98
Feb-26 $45.21 $7.75 $33.99 $7.75 $0.98
Mar-26 $16.99 $7.75 $13.15 $7.75 $0.98
Apr-26 $10.00 $7.75 $14.56 $7.75 $0.98
May-26 $17.79 $7.75 $13.67 $7.75 $0.98
Jun-26 $37.60 $7.75 $24.56 $7.75 $0.98
Jul-26 $58.47 $7.75 $45.37 $7.75 $0.98
Aug-26 $58.27 $7.75 $46.65 $7.75 $0.98
Sep-26 $47.46 $7.75 $41.15 $7.75 $0.98
Oct-26 $39.34 $7.75 $33.51 $7.75 $0.98
Nov-26 $46.67 $7.75 $39.42 $7.75 $0.98
Dec-26 $56.25 $7.75 $51.66 $7.75 $0.98
Jan-27 $39.29 $7.96 $44.22 $7.96 $1.00
Feb-27 $35.16 $7.96 $43.21 $7.96 $1.00
Mar-27 $17.20 $7.96 $23.24 $7.96 $1.00
Apr-27 $7.87 $7.96 $9.89 $7.96 $1.00
May-27 $8.84 $7.96 $13.74 $7.96 $1.00
Jun-27 $22.60 $7.96 $16.05 $7.96 $1.00
Jul-27 $42.95 $7.96 $44.18 $7.96 $1.00
Aug-27 $43.30 $7.96 $44.49 $7.96 $1.00
Sep-27 $39.01 $7.96 $37.97 $7.96 $1.00
Oct-27 $28.04 $7.96 $32.53 $7.96 $1.00
Nov-27 $40.97 $7.96 $45.49 $7.96 $1.00
Dec-27 $57.07 $7.96 $54.65 $7.96 $1.00
Jan-28 $35.50 $8.13 $42.37 $8.13 $1.03
Feb-28 $27.86 $8.13 $24.69 $8.13 $1.03
Mar-28 $7.43 $8.13 $11.88 $8.13 $1.03

Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 4 of 9
APPENDIX G
Amended Monthly Purchase Prices
(For Hourly Generation Up To 10 MW)

Month-Year
Base Energy Heavy Load
Purchase Price Components

Base Energy Light Load
Purchase Price Components

Integration
Charge

Energy
Price
Component
Capacity
Price
Component
Energy Price
Component
Capacity
Price
Component
(Mills/kWh) (Mills/kWh) (Mills/kWh) (Mills/kWh) (Mills/kWh)
Oct-25 N/A N/A N/A N/A N/A
Nov-25 N/A N/A N/A N/A N/A
Dec-25 N/A N/A N/A N/A N/A
Jan-26 N/A N/A N/A N/A N/A
Feb-26 N/A N/A N/A N/A N/A
Mar-26 N/A N/A N/A N/A N/A
Apr-26 $5.80 $9.16 $5.94 $9.16 $0.98
May-26 $8.96 $9.16 $12.06 $9.16 $0.98
Jun-26 $27.07 $9.16 $26.21 $9.16 $0.98
Jul-26 $37.60 $9.16 $35.73 $9.16 $0.98
Aug-26 $36.21 $9.16 $35.65 $9.16 $0.98
Sep-26 $32.94 $9.16 $33.40 $9.16 $0.98
Oct-26 $32.16 $9.16 $33.42 $9.16 $0.98
Nov-26 $38.96 $9.16 $37.99 $9.16 $0.98
Dec-26 $42.84 $9.16 $40.58 $9.16 $0.98
Jan-27 $38.36 $9.38 $38.02 $9.38 $1.00
Feb-27 $48.94 $9.38 $49.30 $9.38 $1.00
Mar-27 $13.04 $9.38 $15.25 $9.38 $1.00
Apr-27 $9.50 $9.38 $7.37 $9.38 $1.00
May-27 $10.45 $9.38 $16.72 $9.38 $1.00
Jun-27 $20.28 $9.38 $23.83 $9.38 $1.00
Jul-27 $35.90 $9.38 $34.81 $9.38 $1.00
Aug-27 $38.07 $9.38 $37.13 $9.38 $1.00
Sep-27 $39.74 $9.38 $42.38 $9.38 $1.00
Oct-27 $33.22 $9.38 $34.44 $9.38 $1.00
Nov-27 $43.31 $9.38 $41.99 $9.38 $1.00
Dec-27 $49.10 $9.38 $46.64 $9.38 $1.00
Jan-28 $43.22 $9.57 $44.21 $9.57 $1.03
Feb-28 $33.71 $9.57 $36.09 $9.57 $1.03
Mar-28 $19.66 $9.57 $27.07 $9.57 $1.03

Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 5 of 9
• Pricing before April 2026 is Not Applicable (N/A).
APPENDIX G
Amended Bifurcated Monthly Purchase Prices
(For Hourly Generation Above 10 MW up to 10.5 MW)

Month-Year
Base Energy Heavy Load
Purchase Price Components

Base Energy Light Load
Purchase Price Components

Integration
Charge

Energy
Price
Component
Capacity
Price
Component
Energy Price
Component
Capacity
Price
Component
(Mills/kWh) (Mills/kWh) (Mills/kWh) (Mills/kWh) (Mills/kWh)
Oct-25 N/A N/A N/A N/A N/A
Nov-25 N/A N/A N/A N/A N/A
Dec-25 N/A N/A N/A N/A N/A
Jan-26 N/A N/A N/A N/A N/A
Feb-26 N/A N/A N/A N/A N/A
Mar-26 N/A N/A N/A N/A N/A
Apr-26 $5.80 N/A $5.94 N/A $0.98
May-26 $8.96 N/A $12.06 N/A $0.98
Jun-26 $27.07 N/A $26.21 N/A $0.98
Jul-26 $37.60 N/A $35.73 N/A $0.98
Aug-26 $36.21 N/A $35.65 N/A $0.98
Sep-26 $32.94 N/A $33.40 N/A $0.98
Oct-26 $32.16 N/A $33.42 N/A $0.98
Nov-26 $38.96 N/A $37.99 N/A $0.98
Dec-26 $42.84 N/A $40.58 N/A $0.98
Jan-27 $38.36 N/A $38.02 N/A $1.00
Feb-27 $48.94 N/A $49.30 N/A $1.00
Mar-27 $13.04 N/A $15.25 N/A $1.00
Apr-27 $9.50 N/A $7.37 N/A $1.00
May-27 $10.45 N/A $16.72 N/A $1.00
Jun-27 $20.28 $9.38 $23.83 $9.38 $1.00
Jul-27 $35.90 $9.38 $34.81 $9.38 $1.00
Aug-27 $38.07 $9.38 $37.13 $9.38 $1.00
Sep-27 $39.74 $9.38 $42.38 $9.38 $1.00
Oct-27 $33.22 $9.38 $34.44 $9.38 $1.00
Nov-27 $43.31 $9.38 $41.99 $9.38 $1.00
Dec-27 $49.10 $9.38 $46.64 $9.38 $1.00
Jan-28 $43.22 $9.57 $44.21 $9.57 $1.03
Feb-28 $33.71 $9.57 $36.09 $9.57 $1.03
Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 6 of 9

Month-Year
Base Energy Heavy Load
Purchase Price Components

Base Energy Light Load
Purchase Price Components

Integration
Charge

Energy
Price
Component
Capacity
Price
Component
Energy Price
Component
Capacity
Price
Component
(Mills/kWh) (Mills/kWh) (Mills/kWh) (Mills/kWh) (Mills/kWh)
Mar-28 $19.66 $9.57 $27.07 $9.57 $1.03

• Pricing before April 2026 and Capacity Price before June 2027 is Not Applicable (N/A).

B. The Calculation Description in Article 6.4.4 is hereby amended as follows:

If the current month’s Mechanical Availability is less than the Mechanical Availability
Guarantee, damages shall be equal to:

((85 percent of the The month’s Calculated Net Energy Amount) minus the
month’s actual Net Energy deliveries) multiplied by the Availability Shortfall
Price.

C. The definition of Surplus Energy in Article 1.42 is hereby amended as follows:

(1) All Net Energy produced by the Seller’s Facility and delivered by the Facility to the
Idaho Power electrical system that exceeds the Nameplate Capacity of the Facility.
Deliveries above the Facility’s Nameplate Capacity solely for the purpose of
accommodating hourly scheduling in whole MWs by a third-party transmission
provider shall not be considered Surplus Energy as described within this paragraph
1.42 item 1 or (2) All Net Energy produced by the Seller’s Facility and delivered by
the Facility to the Idaho Power electrical system prior to the Operation Date.

D. Appendix B, Article B-1, is hereby amended to remove the modification language
as follows:

The Seller’s Facility is described as: Seven (7) – 1.5 MW 77 SLE GE Wind Turbines.

Facility Nameplate Capacity: 10.5 MW

Individual Generator Power Factor: Leading 0.9, Lagging 0.9

Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 7 of 9
Qualifying Facility Category (Small Power Production or Cogeneration): Small Power
Production

Primary Energy Source (Hydro, Wind, Solar, Biomass, Waste, Geothermal): Wind

Fueled or Non-Fueled Rate (Generator primarily fueled with fossil or non-fossil fuel):
Non-Fueled

Any modifications to the Facility, including but not limited to the generator or turbine, that 1)
increases or decreases the Facility Nameplate Capacity, or 2) changes the Qualifying Facility
Category, or 3) changes the Primary Energy Source or 4) changes to the generator fuel and
subsequently the Fueled Rate or Non-Fueled Rate, will require a review of the Agreement terms,
conditions and pricing. Idaho Power, at its sole determination, may adjust the pricing or
terminate the Agreement. If the Agreement is terminated because of said modifications, the
Seller will be responsible for any Termination Damages.

E. Appendix E Wind Energy Production Forecasting Item 2 is hereby amended as
follows:
2) During the first Contract Year, as the value of the one-tenth percent (0.1%) cap of
the Facilities total energy payments will not be known until the first Contract Year
is complete, Idaho Power will deduct the Facility’s calculated share of the Wind
Energy Production Forecasting costs specified in item d 4 each month during the
first Contract Year and subsequently refund any overpayment (payments that
exceed the cap) in equal monthly amounts over the ensuing Contract Year.
3. Commission Approval. The obligations of the Parties under this First Amendment are
subject to the IPUC’s approval of this First Amendment, and such approval being upheld on
appeal, if any, by a court of competent jurisdiction. The Parties will submit this First Amendment
to the IPUC and request approval or rejection in its entirety.
4. Effect of Amendment. Except as expressly amended by this First Amendment, the
Agreement, as amended, shall remain in full force and effect.
5. Capitalized Terms. All capitalized terms used in this First Amendment and not defined
herein shall have the same meaning as used in the Agreement, as amended.
6. Scope of Amendment. This First Amendment shall be binding upon and inure to the
benefit of the Parties hereto, and their respective heirs, executors, administrators, successors, and
assigns, who are obligated to take any action which may be necessary or proper to carry out the
purpose and intent thereof.
7. Authority. Each Party represents and warrants that (i) it is validly existing and in good
standing in the state in which it is organized, (ii) it is the proper party to amend the Agreement,
and (iii) it has the requisite authority to execute this First Amendment.
Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 8 of 9
8. Counterparts. This First Amendment may be executed in any number of counterparts,
each of which shall be deemed an original and all of which taken together shall constitute a single
instrument.
Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
Energy Sales Agreement
Project: 20251001 Fossil Gulch Wind Park
First Amendment - Page 9 of 9
IN WITNESS WHEREOF, the Parties hereto have caused this First Amendment to be duly
executed as of the date above written.

FOSSIL GULCH WIND PARK, LLC

By: _________________________________

Name: Olivier Duguet

Title: CEO

Date: ________________________________

IDAHO POWER COMPANY

By: _________________________________

Name: Ryan Adelman

Title: Vice President of Power Supply

Date: ________________________________

Docusign Envelope ID: 14048CFF-6024-805B-82C4-D0450CE2DFED
4/29/2026 4/29/2026