20260505Comment_1.pdf

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
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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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