20260803Staff Comments.pdf

RECEIVED
August 03, 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 IDAHO POWER )
COMPANY'S APPLICATION FOR AN ) CASE NO. IPC-E-26-17
ORDER APPROVING THE TRANSFER OF )
CERTAIN ASSETS ASSOCIATED WITH )
TRANSMISSION LINE LAND ) COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"),by and through its attorney of record,Kelsea E. Ross, Deputy Attorney General,
submits the following comments.
BACKGROUND
On May 29, 2026, Idaho Power Company ("Company") filed an application
("Application")with the Commission requesting approval to convey approximately 0.659 acres of
land located at 665 W. Amity Road, in Ada County, Idaho ("Land") to ASIG 665 W Amity RD,
LLC ("Buyer"). Application at 1-2.
The Company asserts that in 1946 it acquired from the State of Idaho approximately 5.30
acres of land along Amity Road in Ada County,Idaho("Amity Road Land"). Id. at 1. The purpose
of the"acquisition was to create a transmission line corridor for a future transmission line." Id. at
1-2. The Company explained that although a transmission line does not yet run through the Amity
Road Land, "the Company has installed distribution facilities...." Id. at 2. Since acquiring the
Amity Road Land, various landowners adjacent to the parcel have contacted the Company with
requests to purchase portions of the parcel. Id. Historically, the Company has sold various
STAFF COMMENTS 1 AUGUST 3, 2026

portions of the Amity Road Land to landowners and retained easements on the sold parcels "that
will still allow for placement of a future transmission line...." Id.
The Company represents that under the proposed asset transfer, the Company would
transfer the Land to the Buyer for a purchase price of$100,470, but the Company would reserve
the entire parcel of land as an easement. Id. at 2. The Commission most recently approved a
Company asset transfer similar in nature in Commission Order No. 36461.
STAFF ANALYSIS
In conducting its analysis, Commission Staff ("Staff') reviewed the Company's
Application, its responses to Staff s Production Requests, and additional supporting documents.
Staff focused on the proposed asset transfer's compliance with Idaho Code §§ 61-328, and § 524;
the Fair Market Value ("FMV") of the Land; and the accounting treatment of the proposed asset
transfer. After its review, Staff believes the Company's request is reasonable and is in the interest
of both the Company and its customers.
Idaho Code & 61-328
An electric utility must obtain approval from the Commission before it sells or transfers
ownership of any parcel of land located in Idaho and used in the generation, transmission, or
distribution of electricity in Idaho. Idaho Code § 61-328(1). Further, Idaho Code § 61-328(3)
states that:
Before authorizing the transaction, the public utilities commission shall find: (a)
[t]hat the transaction is consistent with the public interest; (b) [t]hat the cost of and
rates for supplying service will not be increased by reason of such transaction; and
(c) [t]hat the applicant for such acquisition or transfer has the bona fide intent and
financial ability to operate and maintain said property in the public service.
The Company has previously conveyed parcels of land and retained easements on the
parcels that will still allow for placement of a future transmission line by the Company.
Application at 2. In its Application,the Company asserts that the proposed asset transfer meets the
requirements of Idaho Code § 61-328(3). Id. at 3. Staff reviewed the Company's Application,the
Real Estate Purchase and Sale Agreement submitted with its Application ("Agreement"), and its
Staff s responses to Production Requests. Staff notes that the sale would relieve the Company of
ownership and maintenance responsibilities associated with the Land while retaining easement
STAFF COMMENTS 2 AUGUST 3, 2026

rights that would allow it to build a future transmission line on the Land. Staff believes the terms
of the Agreement are consistent with the public interest, consistent with what is required under
Idaho Code § 61-328(3)(a).
Based on Staffs interpretation of Idaho Code § 61-328(3)(b), and its review of the
Application, Staff supports the Company's assertion that the cost of and rates for supplying service
will not be increased by the proposed transaction. As stated above, Staff believes the transfer of
the land would relieve the Company of financial obligations related to the ownership and
maintenance of it. Staff also believes the easement rights retained by the Company would allow
it to utilize the proposed parcel at a future date without a corresponding parcel purchase.
Lastly, Staff reviewed documentation to verify the Buyer's bona fide intent and financial
ability to operate and maintain the Land. The Company represented that the Buyer owns the parcel
adjacent to the Land. Application at 3. The Buyer currently leases the land from the Company to
provide parking. Id. at 2. The Buyer will maintain and continue to provide parking if the sale is
approved. Id. Confidential Response to Staff Production Requests No. 1. Therefore, Staff
believes the Buyer has a bona fide intent and financial ability to operate and maintain the proposed
parcel in the public service in accordance with Idaho Code § 61-328(3)(c).
Idaho Code § 61-524
An electric utility must create and utilize a system of accounts established by the
Commission. Idaho Code § 61-524. Staff reviewed the proposed accounting journal entries in the
Application. Staff believes the proposed asset transfer complies with Idaho Code § 61-524 as the
Company utilizes the Uniform System of Accounts prescribed by FERC as the accounting for the
proposed asset transfer. Application at 17.
Agreement and Fair Market Value
Staff reviewed the Agreement and did not identify any discrepancies between the
information in the Application and the Agreement. Staff also reviewed the FMV calculation of the
proposed asset believes that the FMV sale price of the proposed asset is reasonable and is in the
interest of the Company and its customers.
STAFF COMMENTS 3 AUGUST 3, 2026

Proposed Accounting
The Company provided its proposed accounting journal entries with its Application. Id. at
17. Staff reviewed the proposed accounting treatment and believes it is proper and that the
estimates are reasonable. Application Attachment 2.
Under the Agreement, the Buyer will assume responsibility associated with ownership of
Land while allowing the Company to maintain the use of the Land for an installed distribution
facility and a transmission line corridor through an easement. Id. The total sale price for the Land
is $100,470 as shown in the Application. Id. The Company represented that Land "is a non-
buildable strip of land that has no value to the neighboring property contiguous with the property
to the south." Confidential Response to Staff Production Requests No. 1. The Company will
retain an easement over the entire proposed asset for transmission lines and associated facilities,
fully encumbering the proposed asset, which was quantified as a percentage devaluation of the
FMV of the proposed asset. Id. There will be no separation costs or lost customer revenue
resulting from the proposed asset transfer as there are only installed distribution facilities for a
future transmission line corridor for which the Company will retain an easement for. Application
Attachment 2.
Customer Comments
As required in Idaho Code § 61-328(1), the Commission will hold a telephonic public
hearing on August 4, 2026. As of August 3, 2026, zero (0) public comments have been filed for
this case.
STAFF RECOMMENDATION
Staff recommends the Commission issue an order approving the Company's proposed asset
transfer as detailed in its Application.
Respectfully submitted this 3rd day of August 2026.
Kelsea E. Ross
Deputy Attorney General
Technical Staff. Ray McArthur
I:\Utility\UMISC\COMMENTS\IPC-E-26-17 Comments.docx
STAFF COMMENTS 4 AUGUST 3, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3rd DAY OF AUGUST 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-26-17, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E. WALKER
CONNIE ASCHENBRENNER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707
E-MAIL:
dwalker(a,idahopower.com
caschenbrenner(),idahopower.com
[e-mail]
Re ,
PATRICIA JORDA9, SECRETARY
CERTIFICATE OF SERVICE