20261020Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER LODGE
COMMISSIONER HAMMOND
COMMISSIONER HARDIE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: JAMES CHANDLER,AUDITOR 3
KELSEA E. ROSS,DEPUTY ATTORNEY GENERAL
DATE: OCTOBER 20, 2026
RE: IN THE MATTER OF IDAHO POWER'S APPLICATION FOR AN ORDER
AUTHORIZING UP TO $1,000,000,000 AGGREGATE PRINCIPAL
AMOUNT AT ANY ONE TIME OUTSTANDING OF UNSECURED
BORROWINGS; CASE NO. IPC-E-26-29.
On October 2,2026, Idaho Power Company("Company") applied for authority to issue up
to $1,000,000,000 aggregate principal amount of unsecured borrowings at any one time
(Application"). Application at 1. The Company's current unsecured borrowing authority was
granted by the Commission in Order No. 36004, dated November 17, 2023, issued in Case No.
IPC-E-23-26 and extends through December 31,2030. The Company represents that the proposed
borrowings under the requested authority may consist of: 1) "loans issued by financial and other
institutions and evidenced by unsecured notes or other evidence of indebtedness of the Company;
and 2) "unsecured promissory notes and commercial paper of the Company to be issued by the
"means of public or private placement through one or more commercial paper dealers or agents,
or directly by"the Company. Id. at 2.
The Company states that each line of credit will provide a specific dollar amount to be
available to draw upon for a fee "determined by a percentage of the credit line available, credit
line utilization, compensating balance or combination thereof." Id. Uncommitted credit facilities
may also be utilized on an"as available"basis at negotiated interest rates. Id. "Each note issued
as commercial paper will be either discounted at the rate prevailing at the time of issuance for
commercial paper of comparable quality and maturity or will be interest bearing to be paid at
maturity." Id. at 3. The notes issued as commercial paper will also have a fixed maturity "and
will contain no provision for automatic `roll over"'. Id.
DECISION MEMORANDUM - 1 - OCTOBER 20, 2026

The Company's existing credit agreement "provides committed lines of credit from
participating banks in an aggregate principal amount at any one time totaling $400,000,000, with
an option to increase the borrowing limit to $600,000,000 . . . ." Id. The Company proposes a
new credit agreement with an initial borrowing limit of$500,000,000, with an option to increase
the borrowing limit to $800,000,000. Id.
The Company requests borrowing authority through December 31, 2031, with the ability
to extend the time period for two one-year extension options through December 31, 2033. Id. at
4. The Company states that the proposed increase in unsecured borrowing capacity reflects
increased operating costs since 2023,when the Commission last approved its borrowing authority.
Id. at 3-4.
The Company will provide written notice to the Commission if it elects to increase the
borrowing limit under the proposed new credit agreement above $500,000,000 or exercise either
of the two one-year extensions beyond December 31, 2031. Id. at 5-6. The Company requests
authorization to continue borrowing through December 31, 2033, provided that the Company's
senior secured debt ratings remain investment grade, BBB- or higher by Standard & Poor's and
Baa3 or higher by Moody's Investors' Service. Id. at 6. The required filing fee of$1,000 was
received by the Commission on October 14, 2026.
STAFF DISCUSSION
Staff reviewed the Application and believes that the proposed unsecured borrowings meets
the requirements under Idaho Code § 61-901, as it is "for the acquisition of property;" for "the
construction, completion, extension[,] or improvement of its facilities; for the improvement or
maintenance of its service; for the discharge or lawful refunding of its obligations;"and for general
corporate purposes. Staff also believes that the Application satisfies the filing requirements under
Idaho Code § 61-905 and the Commission's Rules of Procedure 141-150 (IDAPA 31.01.0L141-
150).
Staff believes that the Company's request to increase to the limit and extend the
authorization period is reasonable. The United States Bureau of Labor Statistics ("BLS")
consumer price index for the western region of the United States indicates that prices have
DECISION MEMORANDUM - 2 - OCTOBER 20, 2026

increased by 11.9%since the beginning of 2023.' Staff believes that the BLS data provides support
to the Company's claims of increased operating costs.
The requested authority,if approved,would be continuous and would remain in effect until
December 31, 2033. Application at 1. As a condition of term, the Commission requires the
Company to maintain investment grade ratings of at least BBB- from Standard and Poor's Rating
Services, or a Baa3 or higher senior secured debt rating by Moody's Investors' Service, Inc. The
Company's current senior secured debt ratings are BBB from Standard and Poor's, and Baa2 from
Moody's, which qualify as investment grade. Staff believes that maintaining investment grade
credit ratings provides an appropriate safeguard for the proposed borrowing authority.
However, if the Company's senior secured debt ratings fall below investment grade level
("Downgrade"), Staff recommends that the Commission allow the Company's borrowing
authority to continue for a period of 364 days [from] the date of the Downgrade (`Continued
Authorization Period'), provided that the [Company]:
(1) promptly notifies the Commission in writing of the Downgrade;
and
(2) files a supplemental application with the Commission within
seven (7) days, [or as soon as possible,] after the Downgrade,
requesting a supplemental order. (`Supplemental Order')
authorizing [the Company] to continue to make [b]orrowings as
provided in the [n]ew [o]rder, notwithstanding the Downgrade.
Id. at 6.
Staff recommends that until the Company receives a Supplemental Order,the Commission
require that all borrowings made during the Continued Authorization Period must"mature no later
than the end of the Continued Authorization Period." Id. at 6-7.
The Company requests that its existing borrowing authority under Order No. 36004 remain
effective for 21 days following issuance of the Commission's Order in this case, subject to the
existing $600,000,000 borrowing limit. Id. at 4-5. Furthermore, the Company suggests that the
21-day period could be used as the Commission's"'petition for reconsideration period"'that would
apply to the Commission's Order in this case. Id. at 4. Staff believes that the proposed transition
period is reasonable because it would provide the Company sufficient time to transition from its
existing borrowing arrangements to the newly authorized borrowing authority and allow for a
'U.S.Bureau of Labor Statistics, Consumer Price Index for All Urban Consumers(CPI-U)
hops://data.bls.,gov/timescries/CUUR0400SAO?amp%253bdata_tool=XGtable&output_viewdata&include_.graphs
=true(last visited Oct. 14,2026).
DECISION MEMORANDUM - 3 - OCTOBER 20, 2026

petition for reconsideration period. Therefore, Staff recommends that the Commission approve
the requested 21-day transition period.
Lastly, Staff believes the approval of the Application would not significantly impact the
Company's capital structure or result in changes to customer rates. Furthermore, all funds derived
and used as a result of the borrowings would be subject to a prudence review and Commission
approval in future filings.
STAFF RECOMMENDATION
Staff recommends that the Commission: (1) approve the Company's request to have up to
$1,000,000,000 in unsecured "aggregate principal amount at any one time" of outstanding
borrowings; and (2) approve the borrowing authority through December 31, 2031, with two
optional one-year extensions, provided that the Company notifies the Commission in writing if
either extension is exercised. Staff further recommends that the Commission require the Company
to notify the Commission in writing if its senior secured debt credit ratings fall below investment
grade. Staff recommends that the Commission allow the Company's borrowing authority to
continue for 364 days following a Downgrade, provided that the Company files a supplemental
application within seven (7) days, or as soon as possible, requesting continued borrowing
authority.
COMMISSION DECISION
Does the Commission wish to:
1. approve the Company's request to make up to $1,000,000,000 aggregate principal
amount at any one time of outstanding borrowings?
2. approve the Company's borrowing authority through December 31, 2031, with two
optional one-year extensions,provided that the Company notifies the Commission?
3. approve the Company's request to maintain its existing borrowing authority for 21 days
following issuance of the Commission's Order, subject to the existing $600,000,000
borrowing limit?
4. require the Company to notify the Commission in writing if its senior secured debt
credit ratings fall below investment grade?
5. allow the Company's borrowing authority to continue for 364 days following a credit-
rating Downgrade below investment grade, provided that the Company promptly
DECISION MEMORANDUM - 4 - OCTOBER 20, 2026

notifies the Commission in writing and files a supplemental application within seven
days, or as soon as possible thereafter, requesting continued borrowing authority, with
borrowings during that period maturing no later than the end of the 364-day period
unless otherwise authorized by the Commission?
James Chandler
Auditor 3,
I:\Uti1ity\UDMEM0S\IPC-E-26-29 Decision Memo.docx
DECISION MEMORANDUM - 5 - OCTOBER 20, 2026