20260716Staff Comments.pdf

RECEIVED
July 16, 2026
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-26-12
APPROVAL OF THE THIRD AMENDMENT )
TO THE POWER PURCHASE AGREEMENT )
BETWEEN IDAHO POWER COMPANY AND ) COMMENTS OF THE
USG OREGON, LLC ) COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"),by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney General,
submits the following comments.
BACKGROUND
On April 15, 2026, Idaho Power Company ("Company") applied to the Commission
requesting approval of the Third Amendment ("Amendment") to the Power Purchase Agreement
("PPA") between the Company and USG Oregon, LLC ("Seller") for the Neal Hot Springs
geothermal project ("Application").
The Company's proposed Amendment includes pricing for years 2037 through February
28, 2038, which is the ending date of the 25-year contract term. Application at 1. The prices for
2037 and 2038 are calculated by using the average of the annual escalation rates of years 2034
through 2036. Application at 3.
STAFF COMMENTS I JULY 16, 2026

STAFF ANALYSIS
The Company did not include the pricing for years 2037 and 2038 within the current 25-
year PPA and proposed in this case to include the pricing for these years by using the average of
the annual escalation rates of years 2034 through 2036. To determine if the proposal is reasonable,
Staff reviewed the parties' pricing framework that set the prices in the original PPA, which were
approved through Order No. 31087 in Case No. IPC-E-09-34. Through its review, Staff believes
the proposed rates are aligned with the parties' original pricing structure and recommends that the
Commission approve the Amendment.
In Case No. IPC-E-09-34, when the original PPA was submitted and approved by the
Commission through Order No. 31087, Staff noticed that the rates in the PPA were only available
from January 2012 through December 2036. Staff Production Request No. 19 (Case No. IPC-E-
09-34). Staff inquired whether the PPA would still expire in 2036 if the project came online later
than 2012,which would lead to a contract term of less than 25 years. Id. The Company responded
that"[t]he contract term is 25 years and the price schedule will be extended at the same escalation
rate as the escalation from 2035 to 2036." Response to Staff Production Request No. 19 (Case
No. IPC-E-09-34). The Company indicated that"[t]he failure to show this extension on the table
was an oversight by both parties." Id. However, the pricing for years 2037 and 2038 was never
subsequently provided through amendments to the original contract.
In the current case, the Company states that the parties "did not have other documentation
indicating the pricing to be used in 2037 and 2038." Application at 3. However, Staff believes
the Response to Staff Production Request No. 19 in Case No. IPC-E-09-34 indicated that the
parties' original pricing for 2037 and 2038 would have been calculated based on the same
escalation rate between 2035 and 2036. Under this method, the escalation rate is 0.99% as
reflected in Table No. 1 below.
Table No. 1: Annual Escalation Rates
Base Pricing Escalation per year
2034 140.92 0.99%
2035 142.31 0.99%
2036 143.73 0.99%
2037 145.15 0.99%
2038 146.59 0.99%
STAFF COMMENTS 2 JULY 16, 2026

Since the proposed pricing for 2037 and 2038 is based on the average of the annual
escalation rates of years 2034 through 2036 and reflects the same 0.99% escalation rate as the
originally intended escalation rate in Case No. IPC-E-09-34, Staff believes that the proposed
pricing aligns with the same pricing structure used in the original PPA that was approved through
Order No. 31087. Therefore, Staff recommends that the Commission approve the Company's
proposed Amendment.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Amendment to the PPA between the
Company and the Seller.
Respectfully submitted this 16th day of July 2026.
0,-, 'A-
Jeffrey R. Loll
Deputy Attorney General
Technical Staff. Yao Yin
I:\Utility\UMISC\COMMENTS\IPC-E-26-12 Comments.docx
STAFF COMMENTS 3 JULY 16, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF JULY 2026, SERVED
THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. IPC-
E-26-12, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E. WALKER CAMILLE CHRISTEN
REGULATORY DOCKETS IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707 E-MAIL:
E-MAIL: cchristengidahopower.com
dwalker(a,idahopower.com
dockets(a)idahopower.com
G"�ifilG� e7oC�i
PATRICIA JORD A , SECRETARY
CERTIFICATE OF SERVICE