20260831Reply Comments.pdf

010AW POWER.
LISA C. LANCE RECEIVED
Corporate Council August 31, 2026
Ilance(a)idahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
August 31, 2026
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
RE: Case No. IPC-E-26-22
Pico Energy, LLC Project
Idaho Power Company's Application for Approval of the First Amendment to
the Energy Sales Agreement Between Idaho Power and Pico Energy, LLC
Dear Commission Secretary:
Attached for electronic filing, please find Idaho Power Company's Reply
Comments in the above-entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
Arl- C__'/Z,��
Lisa C. Lance
LCL:cd
Enclosures

LISA C. LANCE (ISB No. 6241)
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]
Ilance(a-Mdahopower.com
dwalkerCa-)_idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-26-22
APPROVAL OF THE FIRST AMENDMENT )
TO THE ENERGY SALES AGREEMENT ) IDAHO POWER COMPANY'S
BETWEEN IDAHO POWER AND PICO ) REPLY COMMENTS
ENERGY, LLC. )
COMES NOW, Idaho Power Company ("Idaho Power" or "Company") in
accordance with Commission Rule of Procedure 203 and applicable provisions of the
Public Utility Regulatory Policies Act of 1978, as well as the Idaho Public Utilities
Commission's ("Commission") Notice of Modified Procedure in this matter, Order No.
37115, hereby respectfully submits the following Reply Comments in response to
Comments filed by Commission Staff ("Staff") on August 24, 2026, in the above
referenced case.
I. INTRODUCTION
On July 6, 2026, the Company applied to the Commission for an order approving
the First Amendment to the Energy Sales Agreement ("ESA") between Idaho Power and
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

Pico Energy, LLC ("Amendment")for the Pico Energy cogeneration facility ("Facility"). The
Amendment modified certain provisions of the ESA to reflect a reduction in the Facility's
nameplate capacity and incorporated Commission-approved language pertaining to
modification of the Facility.
II. STAFF COMMENTS
Within its comments, Staff recommends the Commission approve the Amendment
on the condition that Idaho Power submits a compliance filing correcting certain language
shown as being deleted from the original ESA. Specifically, Staff recommends that the
Company correct typographical errors in the language shown as deleted from Appendices
B-1 and B-4.
III. COMPANY REPLY
The Company acknowledges the inadvertent typographical errors contained in the
Amendment's depiction of the language being deleted from the original ESA. Staff's
summary of the transcription errors in the deleted language is correct; however, these
errors are merely presentational in nature and pertain only to content included to aid in
the review of the Amendment. Moreover, the new changes are accurately reflected in the
Amendment, as acknowledged by Staff.' To be clear, the ESA, as amended by the
Amendment, is correct. Accordingly, the Company does not think it is necessary or
administratively efficient for it to submit a compliance filing correcting presentational
language as the errors are not material and do not affect the actual amended version of
the ESA.
Staff's Comments at 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2

IV. CONCLUSION
Idaho Power appreciates Staff's review of its Application in the matter. However,
the errors found by Staff are immaterial to the implementation of the amended ESA, as
noted above. Therefore, the Company respectfully requests that the Commission issue
an order approving, as filed, the First Amendment to the ESA between Idaho Power and
Pico Energy, LLC.
Respectfully submitted this 31St day of August 2026.
LISA C. LANCE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 31St day of August 2026, 1 served a true and
correct copy of Idaho Power Company's Reply Comments upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Kelsea E. Ross U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FTP Site
11331 W. Chinden Blvd., Bldg No. 8, X Email kelsea.ross6a�Puc.idaho.gov
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
Courtesy Copy Sent To:
Montauk Renewables, Inc., John Ciroli: jciroli _montaukrenewables.com
C%",--
Christy Davenport
Legal Administrative Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 4