20260707Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: ERIKA K. MELANSON
DEPUTY ATTORNEY GENERAL
DATE: JULY 7, 2026
SUBJECT: IN THE MATTER OF THE IDAHO HYDROELECTRIC POWER
PRODUCERS TRUST'S PETITION FOR IDAHO POWER COMPANY TO
REDUCE ITS OPERATION AND MAINTENANCE CHARGES
APPLICABLE TO SCHEDULE 72, GENERATOR INTERCONNECTIONS
TO PURPA QUALIFYING FACILITY SELLERS; CASE NO. IPC-E-26-15.
On May 19, 2026, the Idaho Hydroelectric Power Producers Trust ("IdaHydro" or
"Petitioner")petitioned the Idaho Public Utilities Commission("Commission") requesting to update
Idaho Power Company's ("Company") operation and maintenance ("O&M") charges applicable to
Schedule 72, generator interconnections to Public Utilities Regulatory Act ("PURPA") qualifying
facilities ("QFs") sellers ("Schedule 72") to actual costs ("Petition").
BACKGROUND
On May 8, 2025, the Company submitted an application seeking Commission approval to
revise the O&M charges under Schedule 72, with the revised charges to become effective January 1,
2026. Order No. 36894 at 1. In response, IdaHydro did not dispute the Company's proposed updates
to the inputs or calculations used to determine the Schedule 72 O&M charges. Id. at 5. Instead, it
challenged the underlying methodology that the Commission previously approved for calculating
those charges. Id. IdaHydro contended that the system-average approach relies on what it described
as "phantom costs based on averages." Id. It further asserted that the Company does not separately
record actual O&M expenses attributable to individual QFs,but rather includes those expenses within
broader plant accounting categories. Id. IdaHydro believed that because actual O&M costs are not
tracked at the QF level, there is no reliable means of determining whether the resulting charges
accurately reflect the incremental O&M costs incurred beyond the Company's ordinary utility
operations.Id.
DECISION MEMORANDUM I

The Commission rejected IdaHydro's challenge in that proceeding,finding that Case No. IPC-
E-25-22 was limited to updating the inputs used in the existing O&M charge calculation and was not
intended to revisit the validity of the Commission-approved methodology.Id. at 12. The Commission
explained that any party seeking reconsideration of the system-average methodology could request
that the Commission open a separate proceeding dedicated to that issue. Id. The Commission also
recognized that any alternative methodology, including one based on directly assigning actual O&M
costs, warrants careful examination and consideration of its broader regulatory and operational
impacts before being adopted.Id.
THE PETITION
The Petitioner requests that the Commission:
1. Open a new docket for the full re-examination of the Company's Schedule 72 O&M
methodology, as contemplated in Order No. 36894;
2. Determine that the Company may not continue to justify Schedule 72 O&M charges soley
through a system-average methodology;
3. Require the Company to develop and maintain accounting sufficient to identify direct-
assigned actual O&M costs by facility, together with legitimate shared administrative or
overhead costs associated with interconnection maintenance, and to justify any allocation of
such costs; and
4. Require that any future Schedule 72 O&M charges be tied to actual excess interconnection
costs, consistent with 18 C.F.R. § 292.101 and the principles recognized in Order No. 15746.
STAFF RECOMMENDATION
Commission Staff("Staff') recommends that the Commission issue a Notice of Petition and
Notice of Intervention Deadline establishing a 21-day intervention period. After the intervention
deadline has passed, Staff will confer with parties regarding a schedule for processing the case.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Petition and Notice of Intervention Deadline
establishing a 21-day intervention period?
5�"Eri �/Vl ��--
ca K. Melanson
Deputy Attorney General
I:\Legal\ELECTRIC\IPC-E-26-15_IdaHydro\memos\IPCE2615_dec 1_em.docx
DECISION MEMORANDUM 2