20260716Petition for Reconsideration.pdf

Irion Sanger, ISB No. 12488
Sanger Greene PC RECEIVED
4031 SE Hawthorne Blvd. JULY 16, 2026
Portland, OR 97214 IDAHO PUBLIC
Tel: [phone] UTILITIES COMMISSION
Fax: [phone]
[e-mail]
Counsel for Idaho Winds LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER Case No. IPC-E-25-36
COMPANY'S 2025 VARIABLE ENERGY
RESOURCE INTEGRATION STUDY AND IDAHO WINDS LLC'S PETITION
PROPOSED UPDATE TO SCHEDULE 87 FOR RECONSIDERATION
I. INTRODUCTION
Pursuant to Idaho Code § 61-626, Idaho Winds LLC ("Idaho Winds")respectfully
petitions the Commission to reconsider Order No. 37076 approving Idaho Power
Company's ("Idaho Power") Schedule 87 with modifications, but only to the effective
date, wording, discount rate, and escalation rate. As the owner of the 22 MW qualifying
facility("QF") Sawtooth Wind Project("Sawtooth"), the Schedule 87 Integration
Charges approved by the Commission in this case will directly affect the Integration
Charges in the future paid by Idaho Winds to Idaho Power. Order No. 37076 states that
Idaho Winds' concerns articulated in comments in this proceeding should be addressed in
Idaho Power's next Variable Energy Resource Integration Study ("VER Study").1 Errors
1 In re Idaho Power Company's 2025 Variable Energy Resource Integration Study
and Proposed Update to Schedule 87, Case No. IPC-E-25-36, Order No. 37076 at
7 (June 25, 2026).
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with how Schedule 87 Integration Charges have been derived in the 2025 VER Study
should be addressed now rather than waiting for the next VER Study two years from
now. Additionally, Idaho Winds' argument that renewal QFs should pay Integration
Charges based on their original online date has not been formally addressed by the
Commission.
II. PETITION
An interested party may petition for reconsideration within 21 days of a final
order.2 Petitions for reconsideration must specify (a)why the order or any issue decided
in it is unreasonable,unlawful, erroneous or not in conformity with the law, and(b)the
nature and quantity of evidence or argument the petitioner will offer if reconsideration is
granted.3 All charges made by a public utility must be just and reasonable.4 In a docket
using modified procedure and absent a hearing, the Commission may issue an order
based on the written submissions in the docket.5
A. Renewal QF vs New QF Integration Charges Has Not Been Settled
Under the current Schedule 87, for purposes of calculating Integration Charges,
Sawtooth is considered incremental to 316.25 MW of QF solar projects with online dates
after November 2011, 301 MW of QF wind projects with online dates after November
2011, 460 MW of PPA solar projects with online dates after November 2011, 525 MW of
PPA solar projects which have not yet come online, and a 600 MW PPA wind project
2 Idaho Code § 61-626(1).
3 IDAPA 31.01.01, Rule 331-01.
4 Idaho Code § 61-301.
5 IDAPA 31.01.01, Rule 204.
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which Idaho Power has since withdrawn from (Jackalope Wind Project).6 In total,
Sawtooth is considered as incremental to 2,202.25 MW of wind and solar resources
which came online (or are scheduled to come online) after Sawtooth achieved
commercial operations in November 2011.
Idaho Power has argued that"QF contracts are not `renewed' but rather replaced
with new contracts that have new applicable rates, terms, and conditions" as evidence to
support the position that a renewing QF should pay the same Integration Charges as a
new QF. However, as pointed out in Idaho Winds' Opening Comments, the Commission
has already established a distinction between new QF projects and renewing QF projects.
In Order No. 33357, the Commission ruled that at the time of renewal, as long as the QF
continuously sells power to the utility, it is entitled to capacity payments based on the
utility's capacity deficiency date established at the signing of its initial contract.$ This
clearly establishes a distinction between a new QF project and a renewing one.
It is unjust and unreasonable to use a QF's original online date for purposes of
calculating capacity payments but not use the original online date for Integration
Charges. If a QF's original online date is used for calculating the capacity benefit that
the project provides to the utility, then the same should hold true when calculating the
utility's cost to integrate that capacity. Therefore, a renewing QF should not be
6 2025 Integrated Resource Plan Appendix C: Technical Report, Idaho Power
Company at 27-30 (June 2025), available at
http s://does.idahopower.com/pdfs/AboutUs/PlanninaForFuture/2025IRP/2025%2
OIRP%20Appendix%20C.pdf.
7 Idaho Power's Reply Comments, Case No. IPC-E-25-36 at 5 (Apr. 30, 2026).
8 In re Idaho Power Company's Petition to Modify Terms and Conditions of
PURPA Power Purchase Agreements, Case No. IPC-E-15-01, Order No. 33357 at
25-26 (Aug. 20, 2015).
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considered incremental to resources with online dates after its own, and the Integration
Charges it pays should not be the same as those of a new QF. This argument was not
formally addressed or ruled upon in Order No. 37076 leading to unjust and unreasonable
rates for renewing QFs.
Based on Idaho Winds' calculations, the average Integration Costs for VERB in
the Base Portfolio of the 2025 VER Study should be $0.62/MWh, 52% lower than Idaho
Power's Integration Costs for new wind resources in the 0-100 MW capacity penetration
level.9 Based on the annual energy production for Sawtooth, this difference would result
in Sawtooth overpaying for its Integration Costs in the first year of its renewal contract
by $43,896. Over 10 years, Sawtooth would overpay for its Integration Costs by an
estimated $487,902, a significant negative cost impact that is unjust and unreasonable.
B. Known Issues with the VER Study Should Be Addressed Now
In their comments, Commission Staff("Staff') state that they believe inclusion of
forecasted QFs in the Base Portfolio of the VER Study "will result in inaccurate
integration charges for QFs."10 Idaho Winds identified a similar issue regarding the
assumed 75%renewal rate of existing QFs in our opening comments.11 In their reply
comments, Idaho Power agreed with Idaho Winds that the inclusion of a renewal rate of
75% of existing QFs in the Base Portfolio inaccurately calculates the integration costs of
a renewal QF,but they stated that"[b]ecause no QF projects' contracts are expected to
9 Idaho Winds' Opening Comments at 7.
10 Commission Staff Comments at 8.
11 Idaho Winds' Opening Comments at 3.
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expire prior to the next integration charge update, there is no immediate impact to
remedy."12
However, Idaho Winds is currently in negotiations with Idaho Power for a QF
renewal contract. Idaho Winds has submitted a Schedule 73 Qualifying Facility Energy
Sales Agreement ("ESA") Application and received a Public Utility Regulatory Policies
Act Indicative Pricing Proposal ("Proposal") from Idaho Power, most recently on
December 10, 2025. The Proposal contains Schedule 87 Integration Charges, which are
subject to change based on the outcome of this case. Therefore, any inaccuracies in how
Schedule 87 Integration Charges are calculated now will have a direct impact on the rates
paid to Idaho Winds in the next ESA for Sawtooth. Fixing these issues two years from
now will not remedy this impact.
Yet, Order No. 37076 only directs Idaho Power to "discuss with interested parties
the VERB included in the base portfolio in the 2025 VER Study, the Company's method
of calculating the base integration charges for renewal QFs, and the issue of including
forecasted QFs in the 2025 VER Study base portfolio prior to the next VER study."13
Waiting for the next VER Study two years from now will lead to unjust and unreasonable
rates because the integration charges will be higher than warranted by the record in this
docket. As a result, the known issues with the methodology of calculating Integration
Charges should be addressed now.
12 Idaho Power Company's Reply Comments at 5.
13 Order No. 37076 at 7.
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III. CONCLUSION
Idaho Winds respectfully requests that the Commission reconsider Order No.
37076 directing Idaho Power to work with Staff and interested parties to address issues
identified in the 2025 VER Study. Rather, the Commission should address these issues
now so that Schedule 87 Integration Charges can be accurately set, and just and
reasonable. Idaho Winds also requests that the Commission issue an order stating that
renewal QFs should not be required to pay the same Integration Charges as new QFs and
approve Idaho Winds' proposed methodology for setting the integration charge for
renewing QFs based on the precedent set in Order 33357 regarding capacity payments
for renewal QFs.
Dated this 16th day of July 2026.
Respectfully submitted,
Irion A. Sanger, ISB No. 12488
Sanger Greene PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Idaho Winds LLC
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CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 16th day of July, 2026, I caused to be served a
true and correct copy of the foregoing document upon the following individuals in the
manner indicated below:
Electronic Mail Only(See Order No. 35058):
Idaho Public Utilities Commission
Commission Secretary
secretary�a,puc.Idaho.gov
Erika Melanson
Deputy Attorney General
Erika.Melanson(&,puc.Idaho.gov
Idaho Power Company
Donovan Walker
Tim Tatum
Riley Maloney
Mary Alice Taylor
dwalkerkidahopower.com
dockets(&,idahopower.com
ttatum(k idahopower.com
rmaloney( ,,idahopower.com
mtaylorkidahopower.com
Irion A. Sanger
IPC-E-25-36
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