20260813Final_Order_No_37130.pdf

Office of the Secretary
Service Date
August 13,2026
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 ) ORDER NO. 37130
PROPOSED UPDATE TO SCHEDULE 87 )
On December 26, 2025, Idaho Power Company ("Company") applied to the Idaho Public
Utilities Commission ("Commission") requesting: (1) approval of the Company's proposed
Schedule 87("Schedule 87"),Intermittent Generation Integration Charges,updated rates,effective
February 1, 2026, for which the Company's 2025 Variable Energy Resource ("VER") Integration
Study was the basis of, and (2) acknowledgement that the Company complied with the
Commission's directives in Order No. 36661 ("Application"). Application at 1.
On January 21, 2026, the Commission issued a Notice of Application, Notice of
Suspension of Proposed Effective Date, and Notice of Intervention Deadline. Order No. 36909.
The Commission granted intervention to Idaho Winds LLC ("Idaho Winds"). Order No. 36943.
On February 26, 2026, the Commission issued a Notice of Modified Procedure, establishing
comment deadlines. Order No. 36947. Commission Staff ("Staff') and Idaho Winds filed
comments to which the Company replied.No other comments were received.
On June 25, 2026, the Commission issued a Final Order approving Schedule 87 with
modifications and ordering the Company to work with Staff on several issues in the next VER
study and to meet with interested parties to discuss Idaho Winds' comments filed in this case.
Order No. 37076. On July 16,2026,Idaho Winds filed a Petition for Reconsideration of Order No.
37076 ("Petition"). On July 23, 2026, the Company filed an answer opposing the Petition
("Answer").
Based on our review of the record, we issue this Final Order denying the Petition.
PETITION
Idaho Winds stated that the integration charges approved by the Commission through
Order No. 37076 would affect the integration charges Idaho Winds would have to pay in the future
as the owner of a 22 megawatt ("MW") qualifying facility ("QF"). Petition at 1. Idaho Winds
argued that the issues it identified with how Schedule 87 charges were calculated from the 2025
VER Integration Study should be addressed at this time.Id. at 2. Further, Idaho Winds stated that
ORDER NO. 37130 1

the Commission did not formally address its argument regarding what integration charges renewal
QFs should pay.Id.
Idaho Winds represented that the impacts of the inaccuracies in how Schedule 87
integration charges were calculated in the 2025 VER Integration Study would have an immediate
impact because it and the Company were in negotiations for a QF renewal contract, and how the
charges were calculated would have an impact on the rates paid to Idaho Winds under the QF
renewal contract with the Company.Id. at 5. Idaho Winds believed that waiting for the next VER
study to address the Company's calculations for integration charges would lead to an unjust and
unreasonable result for Idaho Winds. Id.
Idaho Winds represented that in Order No. 33357 the Commission "established a
distinction between new QF projects and renewing QF projects." Id. at 3. Thus, Idaho Winds
argued that it was:
unjust and unreasonable to use a QF's original online date for purposes of
calculating capacity payments but [to] not use the original online date for
Integration Charges.
Id. Idaho Winds stated a renewing QF should not be required to pay the same integration charges
that new QFs are required to pay.Id. at 3-4. Idaho Winds represented that its argument regarding
the appropriate integration charges was not formally addressed by the Commission in Order No.
37076 and thus made the Commission's decision have an unjust and unreasonable effect on Idaho
Winds. Id. at 4.
ANSWER TO THE PETITION
The Company argued that Order No. 37076 was "supported by substantial, competent
evidence in the record" and that the Petition should be dismissed because it failed to show that
Order No. 37076 was "unreasonable, unlawful, erroneous, or not in conformity with the law," as
required by the Commission's Rule of Procedure 331.01. Answer at 1. The Company asserted that
Idaho Winds failed to raise new arguments and requested the same relief it asked for in its
comments.Id. at 4.
Regarding Idaho Winds' argument that its position on the appropriate integration charges
for renewal QFs was not formally addressed by the Commission, the Company asserted that the
Commission did address Idaho Winds'position by discussing Idaho Winds' concerns and directing
the Company to "'discuss with interested parties...the Company's method of calculating the base
integration charges for renewal QFs...prior to the new VER Study."'Id. at 5 (quoting Order No.
ORDER NO. 37130 2

37076 at 8). The Company went on to detail its process for determining the integration charges
when QF energy sales agreements are renegotiated. Id. at 5. The Company also stated that Order
No. 37076 appropriately addressed Idaho Winds' concerns for double counting integration
charges.Id. at 5-6.
Next, regarding Idaho Winds' argument that it would be impacted by "unjust and
unreasonable rates"if its issues with the calculation for the integration charges were not addressed
now, the Company represented that the existing energy sales agreement ("ESA") between the
Company and Idaho Winds was not set to expire until 2031.Id. at 6. The Company argued that the
decision to "negotiate a replacement ESA" prior to the expiration date of the current agreement
was up to Idaho Winds. Id. The Company represented that Idaho Winds could defer the
negotiations for the replacement ESA until the Company's 2027 or 2029 VER studies, and
associated integration charges, are updated.Id. at 6-7.
COMMISSION FINDINGS AND DECISION
The Commission has the authority to grant or deny reconsideration pursuant to Idaho Code
§ 61-626(2). Reconsideration allows any interested person to bring to the Commission's attention
any question previously determined, and it affords the Commission an opportunity to rectify any
mistakes or omissions. Washington Water Power Co., v. Kootenai Environmental Alliance, 99
Idaho 875, 879, 591 P.2d 122, 126 (1979). The petitioner has 21 days from the date of the final
order in which to ask for reconsideration.Idaho Code § 61-626(1). An answer that disagrees with
the request for reconsideration must be filed within seven days of the petition. IDAPA
31.01.01.331.05.
Under Commission Rule of Procedure 331.01 ("Rule 331
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.
IDAPA 31.01.01.331.01 (emphasis added). Further, "the petition...must state whether the
petitioners...requests reconsideration by evidentiary hearing, written briefs, comments, or
interrogatories." IDAPA 31.01.01.331.03. After a petition for reconsideration is filed, the
Commission must issue a decision within 28 days of the filing of the petition on whether it will
grant or deny the request.Idaho Code § 61-626(2).
ORDER NO. 37130 3

Having reviewed the record, the Petition, and the Answer, the Commission denies the
Petition. The Commission finds that the Petition does not meet the requirements of Idaho Code §
61-626 and Rule 331. Specifically, the Petition only repeats arguments that were addressed in
Order No. 37076 and does not sufficiently explain how Order No. 37076 was unreasonable,
unlawful, erroneous, or not in conformity with the law.
In the Petition,Idaho Winds argues it is unjust and unreasonable for a QF's original online
date to be used to determine capacity payments but not for determining integration charges, and
that the Commission did not formally address this argument/concern in Order No. 37076. Petition
at 3-4. The Commission finds that Idaho Winds' argument regarding integration charges, and the
information supplied in support of that argument, is a repetition of Idaho Winds' disagreement
with the Company's calculation method, and Idaho Winds' preferred alternative method for
integration charges, which was already asserted in Idaho Winds' Comments and addressed by the
Commission in Order No. 37076. Further, the Commission finds Idaho Winds' argument that the
Commission did not formally address its arguments/concerns with integration charge calculations
unpersuasive. Notably we directed:
the Company to discuss with interested parties the VERB included in the
base portfolio in the 2025 VER [Integration] 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[Integration] Study base portfolio prior to the next
VER study.
Order No. 37076 at 7. Merely reiterating an argument that the Commission already decided upon
and asserting that the Commission's failure to adopt a certain position renders the Commission's
decision unjust and unreasonable, and as a matter not formally addressed, does not demonstrate
that a Commission's order was unlawful, unreasonable, erroneous, or not in accordance with the
law.
Idaho Winds also argues that not addressing alleged issues with the integration charges
now will negatively impact Idaho Winds in its negotiations with the Company on the renewal of a
QF ESA between the parties. Petition at 5. However, the Company represents that the existing
ESA between the parties is not set to expire until 2031, giving Idaho Winds the opportunity to
defer the negotiations for a new ESA until after the Company's 2027 or 2029 VER studies.Answer
at 6-7. Thus, it appears that any imminent and direct negative impact of not addressing alleged
issues with the integration charges now stems, at least in part, from Idaho Winds' own approach
to renegotiating the ESA, rather than a result of the Commission's decision and instructions in
ORDER NO. 37130 4

Order No. 37076. An issue arising from a party's actions does not, on its own, establish that a
Commission order was unlawful, unreasonable, erroneous, or not in accordance with the law.
Accordingly, for the above reasons the Commission denies the Petition.
ORDER
IT IS HEREBY ORDERED that the Petition is denied.
THIS IS A FINAL ORDER. Any parry aggrieved by this Order or other final or
interlocutory Orders previously issued in this case may appeal to the Supreme Court of Idaho
within 42 days pursuant to the Public Utilities Law and the Idaho Appellate Rules.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 13th day of
August 2026.
G
EDWARD LODGE, PR IDENT
J R. HAMMOND JR., COMMISSIONER
1
DAYN HA DIE, COMMISSIONER
ATTEST:
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Commission Secretary
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ORDER NO. 37130 5