20260505Comment_1.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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