20260702Comments.pdf

qN -HIQAW POWER.
RECEIVED
MEGAN GOICOECHEA ALLEN July 2, 2026
Corporate Counsel IDAHO PUBLIC
mgoicoecheaallen(a_idahopower.com UTILITIES COMMISSION
July 2, 2026
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-26-13
Commission Staff's Application to Update Inputs to the Surrogate Avoided
Resource ("SAR") Method and SAR-Based Avoided Cost Rates
Dear Commission Secretary:
Attached for electronic filing, please find Idaho Power Company's Comments in
the above-entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
4v�r T i U�C�.A QJix�r�l
Megan Goicoechea Allen
MGA:cd
Attachments
1221 W. Idaho St(83702)
P.O.Box 70
Boise, ID 83707

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaallen(a-),idahopower.com
dwalker(a-)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION )
STAFF'S APPLICATION TO UPDATE ) CASE NO. IPC-E-26-13
INPUTS TO THE SURROGATE AVOIDED )
RESOURCE ("SAR") METHOD AND SAR- ) IDAHO POWER COMPANY'S
BASED AVOIDED COST RATES ) COMMENTS
Idaho Power Company ("Idaho Power" or "Company"), in accordance with
Commission Rule of Procedure 203 and the applicable provisions of the Public Utility
Regulatory Policies Act of 1978 ("PURPA"), as well as the Idaho Public Utilities
Commission's ("Commission") Notice of Modified Procedure in this matter, Order No.
37068, hereby respectfully submits the following Comments.
Pursuant to Order No. 32697, Commission Staff ("Staff") annually updates the
surrogate avoided resource ("SAR") avoided cost model with the most recent gas
forecasts provided by the U.S. Energy Information Administration ("EIA") Annual Energy
Outlook. In Order Nos. 32737 and 32802, the Commission clarified that the annual update
IDAHO POWER COMPANY'S COMMENTS - 1

should occur on June 1 or within 30 days of the final release of the EIA Annual Energy
Outlook, whichever is later.
In accordance with the Commission's orders, on May 5, 2026, Staff applied to the
Commission for an order updating Idaho Power's SAR model with the EIA's most recent
natural gas price forecast and approving the resulting SAR-based avoided cost rates. In
addition, Commission Staff requested that the Commission modify the processing
timeline for this annual update to better align with the EIA Annual Energy Outlook
publishing date. More specifically, Staff recommends that the Commission require the
annual update to be initiated within one month of the publishing date, with an effective
date within three months of the publishing date, and that the Commission adopt the same
effective date for all three Idaho regulated utilities.
The Company has reviewed the information in Staff's Application and the SAR
model provided by Staff in the case file, which includes updated gas price forecast inputs
to the SAR model based on the EIA's Annual Energy Outlook. Idaho Power believes the
natural gas forecast utilized by Staff has been correctly updated in the model and agrees
that the calculations for the Company are consistent with the SAR methodology approved
by the Commission. Additionally, the Company supports the new processing timeline for
the annual update proposed by Staff.
Respectfully submitted this 2nd day of July, 2026.
Awr T I I l
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S COMMENTS - 2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2nd day of July 2026, 1 served a true and correct
copy of Idaho Power Company's Comments upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Jeffrey R. Loll U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email - jeff.loll(a�puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Christy Davenport
Legal Administrative Assistant
IDAHO POWER COMPANY'S COMMENTS - 3