20260505Comments_2.pdf

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Denise La Fever 1-0�-CVED
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6706 N Salvia Wau,
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Meridian, Idaho 83646 i -5 AM II: 2 3
[e-mail] <'iC �'t'BLIO
COMM)SSION
907-250-8511
April 29,2026
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8, Suite 201-A
Boise, ID 83714
RE: Opposition to Fixed Cost Adjustment(Case No. IPC-E-26-06)
Dear Commissioners,
I am writing to oppose Idaho Power's Fixed Cost Adjustment(FCA)filing dated March 13,
2026, under Case No. IPC-E-26-06.
While described as a "true-up"mechanism,the FCA results in another increase applied
exclusively to residential and small commercial customers, raising serious concerns
regarding fairness, discrimination, and statutory compliance.
1. Residential Customers Are Singled Out
The FCA applies only to:
® Residential customers
• Small General Service customers
It excludes:
• Large General Service
• Large Power customers
Under Idaho Code§61-315, classifications must be reasonable and non-discriminatory.
The Commission has repeatedly held that rate mechanisms must not unfairly burden
one class of customers, including in Idaho Power Fixed Cost Adjustment Order No. 30722,
where careful balancing of cost recovery and fairness was emphasized.
The current proposal fails that balance.

2. Structural Inequity in Cost Recovery
The FCA guarantees recovery of fixed costs regardless of:
• Usage
• Demand drivers
• System impacts
This violates the principle that cost responsibility should follow cost causation,
reaffirmed in Idaho Power General Rate Case Order No. 34046.
The result is clear:
Residential customers subsidize infrastructure increasingly required by large
industrial users.
3. Compounding Impact from Multiple Increases
Although the FCA increase appears modest(0.65%), it is cumulative:
• Layered on PCA increases
• Following significant 2025 increases
• Combined with higher fixed charges
The Commission has recognized in prior decisions that cumulative impacts must be
considered, particularly for residential customers,to ensure compliance with the public
interest standard under idaho Code s 6 i-50 1.
4. Misalignment with Energy Efficiency Goals
The FCA is intended to support efficiency, yet:
Customers who conserve still pay more
• Financial incentives to reduce usage are weakened
The Commission has historically supported rate designs that encourage conservation, and
structures that dilute those incentives warrant careful reconsideration.
5. Failure to Include Major Cost'Drivers

The FCA excludes major contributors to system costs, including:
Data centers
• Industrial expansion
Large agricultural operations using electric-powered irrigation
In prior orders,the Commission has emphasized that excluding key demand drivers from
cost recovew mechanisms can result. in ineq-Litahle outcomes, undermining both
fairness and efficiency.
Conclusion
I respectfully request that the Commission:
Deny the FCA as filed
• Require participation from all customer classes in fixed cost recovery
• Ensure alignmentwith Idaho Code H 61-315,61-502,and 61-501
Follow established IPUC precedent on fairness, cost causation, and avoidance of
discrimination
A lawful and equitable rate structure must ensure that those who drive system costs bear
responsibility for them.
Respectfully,
Denise La Fever

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Denise La Fever % EI'vED
6706 N Salvia Way -
Meridian, Idaho 83646 Q
[e-mail] ;^0 i'QBLIC
907-250-8511 I ".; i.,Qi<riAAlB$i0
April 29, 2026
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8, Suite 201-A
Boise, ID 83714
RE:Opposition to Power Cost Adjustment(Case No. IPC-E-26-10)
Dear Commissioners,
I am writing to formally oppose Idaho Power's proposed Power Cost Adjustment(PCA)filed
April 15, 2026, under Case No. IPC-E-26-10.
While the PCA is presented as a neutral cost-recovery mechanism,the practical effect is
yet another rate increase on residential customers,following closely on the heels of
prior approved increases that already shifted costs away from large industrial users and
onto hnucahnlrie Under Idaho ('nrlo S F1_5f12� ratoc miict ha jiiet and rgago ahte chic
proposal fails that standard.
1. Pattern of Cost Shifting to Residential Customers
The combined PCA and FCA proposal results in a 3.16%increase for residential
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Large Power(3.69%)—continue to benefit from rate structures that do not fully reflect the
infrastructure demands they create.
This follows a larger 2025 rate increase, establishing a troubling pattern of cost shifting.
The Commission has consistently emphasized in prior decisions that rates must reflect
cost causation and avoid interclass subsidies, including in Idaho Power General Rate
Case Order No. 34046,where the Commission reiterated that cost responsibility should
align with the customers driving system costs.
This proposal departs from that principle.

2. Industrial Demand Is Driving Power Costs
The PCA increase is attributed largely to higher expected power costs, including reduced
hydropower generation. However,this explanation omits a critical factor:
Rapid growth in high-load users, including:
• Hyperscale data centers such as those operated by Meta
• Additional approved data center developments
• Expanding industrial operations
These users create massive, continuous demand, requiring:
• New generation
• Expanded transmission
• Increased market purchases
The Commission has previously recognized the importance of aligning infrastructure costs
with demand drivers, including in Avista Utilities Electric Rate Case Order No. 33106,
emphasizing that failure to properly allocate costs results in inequitable burdens across
customer classes.
3. Forecast Risk Should Not Be Borne by Households
The PCA shifts forecasting risk onto ratepayers.
Residential customers:
• Cannot control market conditions
• Cannot hedge costs
• Cannot materially reduce baseline usage
The Commission has previously cautioned against undue risk transfer to customers
without corresponding control or benefit, including in Idaho Power PCA Order No. 33357,
where careful scrutiny of power cost recovery mechanisms was emphasized to ensure
fairness.
4. Disproportionate Impact Despite"Neutral"Framing

While Idaho Power asserts that it earns no return on PCA collections, the issue is not
profit—it is allocation.
Without proper safeguards,the PCA becomes:
A hidden subsidy for large users
• A regressive burden on households
This conflicts with the Commission°s long-standing position that rate design must avoid
undue discrimination, consistentwith both statutory requirements and prior rulings.
Conclusion
I respectfully request that the rd;;,mission:
• Deny or significantly modify the PCA request
• Require a cost-of-service study tied to demand drivers
• Ensure compliance with Idaho Code N 61-502,61-315,and 61-501
• Align this decision with prior Commission precedent on cost causation and fairness
Idaho families should not bear the financial burden of industrial expansion and energy
market volatility.
Respectfully,
Denise La Fever

Denise Lafever
6706 N salvia Way BOISE ID RPDC 837
Meridian,P,8 a. -4938
30 APR 2026 PM 1 'L
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