20260519Staff Comments.pdf

RECEIVED
May 19, 2026
KELSEA E. ROSS IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO STATE BAR NO. 12050
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-26-10
AUTHORITY TO IMPLEMENT POWER )
COST ADJUSTMENT ("PCA") RATES FOR )
ELECTRIC SERVICE FROM JUNE 1,2026, ) COMMENTS OF THE
THROUGH MAY 31, 2027 ) COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its attorney of record, Kelsea Ross, Deputy Attorney General,
submits the following comments.
BACKGROUND
On April 15, 2026, Idaho Power Company ("Company") applied to the Commission
requesting an order approving an update to Schedule 55 ("Application") based on: (1) the
quantification of the 2026-2027 Power Cost Adjustment ("PCA"); (2) the PCA Balancing
Adjustment; and (3) the Idaho jurisdictional Boardman Balancing Account over-collection, to
become effective June 1, 2026 for the period of June 1, 2026, through May 31, 2027. Application
at 17. The Company states that if approved, the Application will result in a revenue increase of
approximately $51.3 million, or a 3.0 percent increase from its current billed revenue. Errata to
Application and Brady Direct at 2.
The PCA mechanism permits the Company to increase or decrease its PCA rates to reflect
the Company's annual "power supply costs." Due to its diverse generation portfolio, the
STAFF COMMENTS 1 MAY 19, 2026

Company's actual cost of providing electricity varies from year to year depending on changes in
such things as the river streamflow,the amount of purchased power, fuel costs,the market price of
power, and other factors. The annual PCA surcharge or credit is combined with the Company's
"base rates"to produce a customer's overall energy rate.
The PCA quantifies and tracks annual differences between actual Net Power Supply
Expenses("NPSE")and the normalized or"base level"of NPSE recovered in the Company's base
rates, resulting in a credit or surcharge that is updated annually on June 1. The PCA mechanism
uses a 12-month test period from April through March ("PCA Year") and includes a forecast
component and a Balancing Adjustment. The forecast component represents the difference
between the Company's NPSE forecast from the March Operating Plan and base level NPSE
recovered in the Company's base rates. The Balancing Adjustment includes a backward-looking
tracking of differences between the prior PCA Year's forecast and actual NPSE incurred by the
Company and also tracks the collection of the prior year's Balancing Adjustment.
Except for Public Utility Regulatory Policies Act of 1978 ("PURPA") expenses and
demand response incentive payments, the PCA allows the Company to pass through to customers
95 percent of the annual differences in actual NPSE as compared with base level NPSE, whether
positive or negative. With respect to PURPA expenses and demand response incentive payments
and actual annual expenses deviate from base level NPSE, the Company is allowed to pass 100
percent of the difference for recovery or credit through the PCA. The PCA is also the rate
mechanism used by the Company to provide customer benefits resulting from the revenue sharing
mechanism, approved by the Commission in Order No. 34071.
The Company represents that if approved,the proposed 2026-2027 PCA rates would collect
$86.5 million in total PCA collection. Errata to Application and Brady Direct at 13.
The Company represents that Table 2 in its Application shows the separation of the $51.3
million revenue increase that would occur if the 2026-2027 PCA rates were approved into each
component included in the Company's proposed rates. Errata to Application and Brady Direct at
4.
STAFF ANALYSIS
The Company's proposed update to Schedule 55 reflects an approximate increase of$51.3
million, or 3.0 percent, in billed revenue, effective June 1, 2026,through May 31, 2027. Errata to
STAFF COMMENTS 2 MAY 19, 2026

Application and Brady Direct at 2. Based on its review of the Application, audit of sample
transactions, examination of the testimony and workpapers of Company witness Jessica G. Brady,
and a review of the Company responses to Staff s Audit and Production Requests, Staff
recommends the Commission approve the Company's Application and proposed Schedule 55, as
filed, effective June 1, 2026.
Staff examined the Company's sales and expenses for the historical 2025-2026 PCA Year
and its forecasting methods, projected revenues, and expenses for the upcoming 2026-2027 PCA
Year. Staff also verified that the Company's filing and methods complied with prior, relevant,
Commission Orders. Staff believes that:
1. The Company's forecast for the upcoming PCA Year (2026-2027) of electricity sales,
loads, fuel consumption, fuel costs, and purchased power costs are reasonable;
2. The Company should keep the Commission apprised of differences between forecasted
and actual NPSE during the 2026-2027 PCA Year and make an off-cycle filing to adjust
the forecast rate if differences are significant;
3. The approval of the Company's proposed Boardman Balancing Account treatment,
resulting in a $3.3 million credit to customers, is reasonable;
4. The Company's balancing adjustment for the last PCA Year is accurate and the actual
NPSE is prudent; and
5. The Commission should accept late-filed customer comments.
Components of Proposed PCA Increase
The components of the $51.3 million increase in the PCA are shown in Table No. 1 below.
Table No. 1: Revenue Impact by PCA Rate Component,Idaho Basis
Table 1 Revenue Impact by Component
Line
No. Rate Component 2025-2026 PCA 2026-2027 PCA Difference
1 PCA Forecast $ 88,931,875 $ 165,106,470 $ 76,174,596
2 PCA Balancing Adjustment $ (53,722,317) $ (78,581,629) $ (24,859,313)
3 PCATotal $ 35,209,558 $ 86,524,841 $ 51,315,283
4 Revenue Sharing $ 0 $ 0 $ 0
5 Total Revenue Impact $ 35,209,558 $ 86,524,841 $ 51,315,283
STAFF COMMENTS 3 MAY 19, 2026

The Company's NPSE varies each year depending on several factors, which may include
changes in river streamflow, the amount of purchased power, fuel costs, and the market energy
price of power, among others. The PCA trues up annually for differences between actual NPSE
and the NPSE collected through base rates. Application at 9. With the PCA, the Company's
customers are paying their actual NPSE, adjusted for Company/customer sharing. Id. at 9-10.
The Company's power supply costs and surplus sales are subject to a 95 percent/5 percent
sharing band, with the Company responsible for 5 percent of the excess NPSE compared to the
NPSE revenue the Company collected through base rates. Brady Direct at 4. The Commission
approved this sharing band to provide a financial incentive for the Company to make careful
resource acquisition and operating decisions to reduce costs. Order No. 30715. If actual costs are
less than revenue collected,the Company keeps 5 percent of that difference. If costs are more than
revenue collected, customers pay 95 percent of the excess costs, and the Company absorbs 5
percent.
In the Company's most recent general rate case, Case No. IPC-E-25-16, the power supply
expense amounts embedded in base rates changed as a result of Commission Order No. 36892,
effective January 1, 2026. Staff verified that the Company used the correct power supply expense
embedded in base rates for April 2025 through December 2025 and used the updated approved
base rate power supply amounts for January 2026 through March 2026 in its balancing adjustment.
Forecast Analysis
Staff reviewed the Company's 2026-2027 PCA forecast component. Staff believes the
Company's forecast component is reasonable, but notes that the complexity of calculating it is
growing, which makes it more difficult to correlate the causes and impacts of significant changes.
The PCA forecast component is the difference between the Company's NPSE forecast
from the 2026 March Operating Plan and the base level NPSE recovered in base rates, after
adjusting for the 95 percent/5 percent sharing agreement. Application at 10. The NPSE forecast
is produced by the Company's Aurora dispatch simulation model, which accounts for a complex
array of variables including forward market energy prices, hydro generation, fuel prices, existing
hedge transactions, and costs associated with PURPA and non-PURPA contracts.
For the upcoming PCA Year, the forecasted NPSE is expected to exceed the base NPSE by
approximately $181 million at the system level. Brady Direct Table 2 at 8. The major drivers of
STAFF COMMENTS 4 MAY 19, 2026

this cost difference are increased gas-based generation ($89 million above baseline), increased
steam-based generation ($33 million above baseline) and reduced sales of surplus power ($49
million below baseline). Id. Two factors are driving these cost increases. Brady Direct at 6-7.
First, based on Staff's calculations of the difference between the amounts in Table 4 of Company
Witness Brady's testimony ("Table 4") and baseline NPSE from Case No. IPC-E-25-16,
forecasted hydro generation is down approximately 1,849,000 megawatt-hours ("MWh") from
baseline, so this non-fuel cost generation must be replaced by more costly forms of generation.
Second,based on Staff's calculations of the difference between the amounts in Table 4 and baseline
NPSE from Case No.IPC-E-25-16,the overall system load has increased approximately 1,264,000
MWh from the baseline NPSE, meaning the additional load must be supplied by the least-cost
available resource. Taken together, Staff believes these two factors amount to approximately
3,113,000 MWh that must be obtained above the baseline. Staff believes the need for this
incremental energy explains most of the $181 million cost differential between the Company's
forecast expense and the expense embedded in base rates. Staff believes the remainder of the cost
differential is a result of increased average cost per MWh of energy,but the average unit costs are
reasonable and consistent with recent historical data.
Staff also examined the Company's sales forecasts to ensure that the costs for additional
generation from new load are matched by a commensurate increase in forecasted sales. Staff
observed that the system-level sales are forecasted to be 16,727,802 MWh. Brady Direct at 13.
Compared to 2025-2026 actual system-level sales of 15,983,688 MWh, Staff calculated an
increase of approximately 744,000 MWh. Brady Direct Exhibit No.2 Cell 0110. Staff determined
this increase is approximately 522,000 MWh less than the 1,264,000 MWh overall increase in
generated energy.
In a meeting with Staff on the "missing" sales, the Company represented that the system-
level generation includes energy that is self-consumed by Clean Energy Your Way ("CEYW")
customers. Staff believes the Company's explanation is reasonable; however, Staff notes that the
CEYW contracts have significantly complicated the PCA forecast component. The CEYW
generation is included in the overall NPSE, so the CEYW self-consumption must be removed from
the sales. For any marginal cost energy that is sold to CEYW companies, both the sales revenue
and the MWh sold are accounted separately and corresponding adjustments are made to the PCA
STAFF COMMENTS 5 MAY 19, 2026

forecast component. For subsequent PCA cases, Staff requests that the Company provide a
worksheet designed to calculate and reconcile all these adjustments.
Finally, Staff notes that the forecast rate allows the Company to collect the deferral balance
during the 2026-2027 PCA year and any differences between the collection of the forecast and
base-to-actual deferral will be trued-up in next year's PCA. However,if actual NPSE significantly
deviates from forecasted NPSE, Staff recommends that the Commission order the Company to
submit an off-cycle filing to mitigate large swings in the deferral balancing account and help keep
customer rates stable.
Balancing Adjustment
The Balancing Account incorporates additional components into the PCA as shown in
Table No. 2 below.
Table No. 2: Balancing Account Summary
Amount
Beginning Balance $ (52,045,994)
2025-2026 Incremental Deferral $ 21.539.038
2025-2026 Forecast Revenues Collections $ (64,632,008)
2025-2026 Prior Balance Revenues Collected $ 23.162.501
Boardman Balancing Adjustment $ (3,279,207)
Current Month Interest $ (3.321.133)
2025-2026 Ending Deferral Balance $ (78.576,803)
Incremental Deferral Balance
The incremental deferred balance of$21.5 million includes two expenses: (1) the expense
difference between actual NPSE, from April 1, 2025, to March 31, 2026, and NPSE recovered
through base rates; and (2) other PCA expenses. Table No. 3, below, summarizes the two
components of the incremental deferral balance and shows the amounts allocated to Idaho
customers after the jurisdictional allocation and the 95 percent/5 percent sharing band are applied.
Staff's review of the incremental deferred balance included: (1) an audit of the deferral
components; (2) an analysis of the methods and the basis used to calculate the cost deferrals and
account balances; (3) an examination of the actual NPSE, including the Company's energy risk
management policies and actions; and (4) an analysis to determine if the Company prudently
STAFF COMMENTS 6 MAY 19, 2026

dispatched resources, purchased power, and sold power in the wholesale market. Based on its
review, Staff is confident that the Company's proposed deferral is accurate and that it conforms to
past Commission orders.
Table No. 3: PCA Incremental Deferral Balance Summary
Amount
NPSE $ 61,545,970
Other PCA Expenses $ (40,006,932)
Total Incremental Deferral Balance $ 21,539,038
Actual Net Power Supply Expense
Staff believes the Company's actual NPSE of approximately $557 million for the 2025 to
2026 PCA Year is reasonable. Staff calculated the actual NPSE ,was $7 million,or 1 percent, less
than the forecast of$564 million (Brady Direct Table 5 at Line No. 9).
Although the actual NPSE ended up remarkably close to the forecast NPSE, Staff noted
that some of the subordinate Federal Energy Regulatory Commission("FERC") Electric Uniform
System of Accounts ("FERC Accounts") deviated significantly from the Company's forecast.
Most notably, Staff calculated that the Company missed its hydro-generation forecast, FERC
Account No. 536,by almost one million MWh,which is a 13 percent shortfall. Brady Direct Table
6. Since, hydro-power is zero fuel-cost generation, reduced hydro-generation was replaced by
more costly energy sources. However, Staff calculated that the Company's actual annual load was
approximately 466,000 MWh less than forecasted, so much of the hydro-generation shortfall was
effectively offset. Id. Staff investigated the reasons for the significant reduction in hydro-
generation and believes the Company's explanation that an extremely warm spring melted the
above-average snowpack too quickly is reasonable. Response to Staff Production Request No. 3
Staff reviewed the other Company FERC Accounts and divided the annual expenses in
each account by the annual MWh generated to calculate the average annual cost per MWh. Based
on its calculation, Staff determined the Company achieved an average calculated cost that was less
than the forecast, with one exception being less than 2 percent over the forecasted amount. Staff
believes the result of actual costs being lower than forecasted amounts is evidence of the
Company's good faith efforts to minimize expenses.
STAFF COMMENTS 7 MAY 19, 2026

Overall, Staff believes the actual NPSE results are reasonable and recommends the
Commission accept them as filed.
Other PCA Expenses
Other PCA expenses are the difference between forecast expenses from the prior PCA Year
and the amounts embedded in base rates. These components include: (1) Idaho Jurisdictional
Qualifying Facility("QF"),PURPA Expense Deferral, and Export Credit Rate ("ECR") expenses;
(2) Idaho Revenue Adjustment from the Sales Based Adjustment ("SBA") Rate; (3) Demand
Response ("DR") Incentive Payments; (4) renewable energy credit ("REC") revenues; and (5)
Point-to-Point, ("PTP")Wheeling Revenue.
1. QF/PURPA/ECR Expense Deferral. PURPA, QF, and ECR expenses are not subject to
the 95 percent sharing band but are subject to jurisdictional allocation between the Company's
Idaho and Oregon customers. Brady Direct at 4. Additionally, as established in Order No. 36048,
the Commission approved the Company's proposal to implement an Export Credit Rate, subject
to 100 percent recovery through the PCA as a NPSE, effective January 1, 2024. For the PCA
deferral year, the Company calculated that QF, PURPA, and ECR expenses were $12.9 million
above the amount recovered in base rates. Brady Direct Exhibit No. 2 Line No. 43. Staff reviewed
the QF, PURPA, and ECR expenses and agrees with the Company's calculation of a$12.9 million
increase to the deferral balance.
2. SBA Rate. The SBA is used to determine the over- or under-recovery of actual NPSE
due to sales that are higher or lower than the sales used to determine base rates (subject to 95
percent customer sharing). The SBA is the difference in actual and base rate sales multiplied by
the SBA rate. The SBA Rate is $27.82/MWh as set in Order No. 36042. The Company calculated
a decrease of$7.9 million due to actual sales being higher than the normalized sales embedded in
base rates. Brady Direct Exhibit No. 2 Line No. 53. Staff determined that the correct SBA Rate
was used for each month's calculation and agrees with the Company's calculation of a$7.9 million
decrease to the deferral balance.
STAFF COMMENTS 8 MAY 19, 2026

3. DR Incentive Payments. The Company's DR incentive payments are not subject to the
sharing band and are wholly allocated to Idaho.Brady Direct at 4. The Company calculated a$1.0
million DR Incentive decrease due to the actual DR Incentive payments being less than those
recovered in base rates. Brady Direct Exhibit No. 2 Line No. 60. The prudency of DR incentive
payments will be determined in the Company's annual Demand-Side Management prudency filing
currently before the Commission(Case No. IPC-E-26-05). Any DR disallowance in that case will
be reflected in next year's PCA deferral balance. Staff reviewed the DR incentive expenses and
agrees with the Company's calculation of a $1.0 million decrease to the deferral balance.
4. REC Revenues. In Order No. 30818, the Commission required the Company to sell all
RECs it receives for renewable generation to benefit its customers. REC sales are not included in
base rates, and all sales are returned to customers through the 95 percent sharing band. The
Company calculated a $44.5 million decrease due to the sales of RECs. Brady Direct Exhibit No.
2 Line No. 68. Staff reviewed the Company's REC transactions and agrees with the Company's
calculation of a $44.5 million decrease to the deferral balance.
5. PTP wheeling Revenue. In Order No. 36042, the Commission established a baseline
amount of wheeling revenue to be recovered through customer base rates. In Order No. 36502,
the Commission approved the Company's request to track the Idaho annual PTP wheeling revenue
in the PCA and true-up the difference between the revenue amount set in base rates and the revenue
amount accrued over the PCA period. The revenue is calculated when the Company moves power
through its transmission system for third parties, following the guidelines of the Company's Open
Access Transmission Tariff established by the FERC. Staff reviewed the Company's wheeling
revenue and agrees with the Company's calculation of a $0.6 million increase to the deferral
balance.
All components described above result in a Company calculated $40.0 million decrease to
the deferral balance for Other PCA Expenses, as shown in Table No. 3. Based on its analysis, Staff
agrees with the Company's calculation of the $40.0 million decrease to the deferral balance.
STAFF COMMENTS 9 MAY 19, 2026

Collections of the 2025-2026 Forecast
The Company calculated $64.6 million in revenue collected from its 2025-2026 PCA
forecast adjustment. Brady Direct Exhibit No. 2 Line No. 98. Monthly forecast balance
collections are calculated by multiplying the MWh sales applicable to the PCA by the forecast rate
for that particular month of the PCA. Staff has reviewed the components of the Company's
calculation and agrees with the $64.6 million decrease to the deferral balance.
Collections of the 2025-2026 Deferral Balance
The Company calculated $23.2 million in revenue collected from its 2025-2026 PCA
balancing adjustment. Brady Direct Exhibit No. 2 Line No. 99. Monthly deferral balance
collections are calculated by multiplying MWh sales applicable to the PCA by the balancing
adjustment rate for that particular month of the PCA. Staff has reviewed the components of the
Company's calculation and agrees with the Company's calculation of a $23.2 million increase to
the deferral balance.
Boardman Balancing Adjustment
The Company calculated a $3.3 million credit to be returned to customers as a one-time
giveback to be included in the PCA Balancing Adjustment related to the Boardman Balancing
Account. Application at 11. The decommissioning of the Boardman Power Plant resulted in a
Boardman Balancing Account established in Order No. 32457, which tracks expenses and
revenues related to decommissioning. Order No. 32549 authorized the Company to collect
revenues for the Boardman Balancing Account through customer rates and required annual
compliance filings each year detailing the overall balance components: decommissioning costs,
materials and supplies write-offs, remaining forecasts, and customer collections.
Order No. 34885 resulted in the Boardman levelized revenue requirement being removed
from customer rates, though the Boardman Balancing Account remained to track continuing
decommissioning costs and other revenue. The Company submitted its latest compliance filing
for the Boardman Balancing Account in Case No. IPC-E-12-09 on December 22, 2025, which
provided a summary of the final calculated Boardman Balancing Account balance of$3.3 million
in over-collections, including its final decommissioning cost in March 2025 and a gain on an Asset
Purchase Agreement. Table No. 4 below shows a summary of the total balance the Company
STAFF COMMENTS 10 MAY 19, 2026

requests to return to customers in this case. Since the Company ceased Boardman collections
through customer rates in 2020,rates do not need to change as a result of the Boardman Balancing
Account return to customers. Staff has reviewed all compliance filings in Case No. IPC-E-12-09
and agrees with the Company's calculation of a $3.3 million over-collection. Staff believes the
Company has complied with all Commission Orders related to the Boardman Balancing Account.
Furthermore, Staff recommends the Commission approve returning the Boardman Balancing
Account balance to customers in this case, as it reduces the overall PCA increase to customers.
Table No. 4: Idaho Jurisdictional Boardman Balancing Account
1 Decom miss ioningCosts $ 3,108,402
2 Materials and Supplies Write-off $ 920,138
3 Total Decommissioning Expenditures $ 4,028,540
4 Collection of Costs $ (5,116,957)
5 Load Variance True-Up $ (3,950)
6 Asset Purchase Agreement Proceeds $ (2,186,840)
7 Under(Over)Collection $ (3,279,207)
Interest
The deferral balance accrues interest monthly using a Commission-approved method as set
forth in Order No. 33307. The Company calculated an interest balance of$3.3 million, as shown
in Table No.2 above. Staff agrees with the monthly balance amounts and believes that the interest
rates used to calculate each month's balance were accurate. Staff agrees with the Company's
calculation of a $3.3 million decrease to the deferral balance.
Revenue Sharing and Rate Calculation
The Company is required to share revenues with customers if the Company exceeds an
established Idaho jurisdictional year-end earned Return on Equity("ROE"),as established in Order
No. 30978. The sharing threshold was most recently established in Order No. 36042 and was set
at 9.6 percent. In 2025, the Company calculated that its ROE was below 9.6 percent, resulting in
no revenue sharing benefit to customers. Application at 13. Staff reviewed the revenue sharing
inputs and calculations and agrees with the Company's determination.
STAFF COMMENTS 11 MAY 19, 2026

PCA Rate Calculations
Staff's review of all rate components included verification that rates were calculated
accurately and that the Company's methods comply with Commission Orders. Staff confirmed
that the revenue requirement was allocated across classes on an equal cents per kWh basis, which
ensures that customers share the PCA revenue requirement based on the amount of energy
consumed.
Overall Impact of Filings Effective June 1, 2025
On March 13, 2026,the Company filed its annual Fixed Cost Adjustment("FCA")in Case
No. IPC-E-26-06. The Company's 2026 FCA filing proposes a $5.1 million increase in current
billed revenue, or a 0.65 percent increase for Idaho Residential and a 0.65 percent increase for
Small General Service customers, effective June 1, 2026,through May 31, 2027.Application at 7
in Case No. IPC-E-26-06.
If the PCA and FCA applications are approved as filed, Staff calculated that the combined
impact is an overall increase in current billed revenue of $56.4 million, or 3.30 percent. The
Company has proposed implementing the PCA and FCA rates effective June 1, 2026. Staff's
calculation of the impact by revenue class is reflected in the following table.
Table No. 5: Percentage Increase from Current Billed Rates by Proposed Change
Small Large
General General
Residential Service Service Large Power Irrigation
PCA 2.50% 2.06% 3.49wb 3.68ai 2.95%
FCA 0.65% 0.65% N/A N/A N/A
Total Combined Impact 3.15% 2.71% 3.49ab 3.68% 2.95%
Customer Notice and Press Release
The Company's press release and customer notice were included with its Application. Staff
reviewed the documents and determined that both meet the requirements of Rule 125 of the
Commission's Rules of Procedure. Rule 125, (IDAPA 31.01.01.125). The customer notice was
included with billing statements mailed to customers from April 22 through May 22, 2026.
Customers whose bills are scheduled to be mailed after May 18, were also sent a postcard that
STAFF COMMENTS 12 MAY 19, 2026

included the customer notice information. For customers enrolled with paperless billing, an email
was sent during the same period that included a link to the digital version of the customer notice.
The Commission set a public comment deadline of May 19, 2026. As of May 19,2026, 12
customer comments have been filed, and all are opposed to the Company's proposal. Customers
in the later part of the billing cycle may not have received their notices or had adequate time to
submit comments before the comment deadline. Staff believes customers should have the
opportunity to file comments and have those comments considered by the Commission. Staff
recommends that the Commission consider late-filed customer comments.
STAFF RECOMMENDATION
Staff recommends the Commission approve the Company's Application and proposed
Schedule 55, as filed, effective June 1, 2026. Staff also recommends the Commission:
1. Find the Company's forecast for the upcoming PCA Year (2026-2027) of electricity
sales, loads, fuel consumption, fuel costs, and purchased power costs reasonable;
2. Direct the Company to keep the Commission apprised of differences between
forecasted and actual NPSE during the 2026-2027 PCA Year and make an off-cycle
filing to adjust the forecast rate if differences are significant;
3. Approve the Company's proposed Boardman Balancing Account treatment, resulting
in a $3.3 million credit to customers;
4. Find the Company's balancing adjustment for the last PCA Year accurate and the actual
NPSE prudent; and
5. Accept late-filed customer comments.
Respectfully submitted this 19th day of May 2026.
Kelsea Ross
Deputy Attorney General
Technical Staff. Steven Verdieck, James Chandler, Matt Suess, Curtis Thaden
I:\Utility\UMISC\COMMENTS\IPC-E-26-10 Comments.docx
STAFF COMMENTS 13 MAY 19, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF MAY 2026, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. IPC-
E-26-10, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA C. LANCE TIMOTHY E. TATUM
REGULATORY DOCKETS JESSI BRADY
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707 BOISE ID 83707-0070
E-MAIL: E-MAIL:
[e-mail] [e-mail]
[e-mail] [e-mail]
[e-mail] jbrady(&,,idahopower.com
PATRICIA JORDAII, SECRETARY
CERTIFICATE OF SERVICE