20150925IRS Accounting Method Change.pdf

STM
An TDACORP Company
LISA D. NORDSTROM
Lead Counsel
t. ''
September 23,2015
Ms. Jean D. Jewell
Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, lD 83720-0074
RE: ldaho Power Company
lnternal Revenue Service Form 3115, Application for Change in Accounting Method
Dear Ms. Jewell:
On September 11 , 2015, IDACORP, lnc., on behalf of its subsidiary ldaho Power Company
("ldaho Powe/'), filed Form3115, Application for Change in Accounting Method, with the lnternal
Revenue Service ('lRS') along with its federal income tax return for 2014. Pursuant to IRS Rev.
Proc.2011-14, as modified by Rev. Proc.2015-33, ldaho Power is providing a copy of two Form
3115s to the ldaho Public Utilities Commission ("Commission") within 30 days of its submittal to the
IRS.
The purpose of the first Form 3115 is for ldaho Power to make a late partial disposition
election. Specifically, this Form 3115 is related to certain dispositions of portions of electrical
generation assets placed in service after December 31, 1986, and prior to January 1,2014.
The purpose of the second Form 3115 is for ldaho Power to notify the IRS of a change in
treatment of dispositions. Specifically, this Form 3115 is related to the gain or loss calculated upon
the disposition or partial disposition of IRC S1245 property or depreciable land improvements.
The filing of this election has no impact to the financial statements of IDACORP, Inc. or
ldaho Power. The submission is protective in nature and is unrelated to any change in accounting
for Generally Accepted Accounting Principles purposes. Similarly, there are no ratemaking
implications as a result of the change. Accordingly, as this filing is for informational purposes only,
no action is required of the Commission nor is action being requested by ldaho Power.
lf you have any questions, please contact Courtney Waites, Senior Regulatory Analyst, at
[phone].
Very truly yours,
fr.;!z[*u"*,--'
LDN/KKt
Enclosures
cc dencl: Gene Marchioro
Randy Lobb
Terri Carlock
Lisa D. Nordstrom
Em 31 15
(Rev Otrqtd 2009)
O.Bar$hail d fre Fr@Eury
REv. PnOc. 2011-11 PURSUAT{TTO SEC 15.02(11(.Xla) OF 8EV. Pf,OC m1}li AS MODIHID BY REV,
Application for Change in Accounting Method OMB No
f{amB cil llGr (narns d parent corporaion rf a consolidaled group) iscc inslrLdions)
|DACORP, [{C.
number (See instructions)
hrsincss adivity codc numbcr (see insfuu€lions)
Numb€r. slreet. and room or suite no lf a P O box. se€ thc insfudions gJr'-al-{lt:!g-e--bSC'J'S_{UUlqo_mryJ)_.-._oil6nu1
P axlE oa
City or tofln, slate, and ZIP code d 6nlac1 pcrson (se€ inslructions)
&tt07 JANE ROTIRS
Name of apCic€nt(s) (if difierent than liler) and idedmcaton number(s) (see instrudions)person s telephone numbcr
Power Gmm Ell'l 82-ltl 3ogl0
lf the applicant is a member of a consolidated check this box
the type appropri.btrtrD
trtr
lndividual
Corporation
Controlled foreign corporaton
(Sec. 957)
1 0/50 corporation (Sec. 9M(dX2XE))
Qualified personal service
corporation (Sec. aagtdX2))
of accounting method change being requested.
(see inskuctions)
Deprecaation or Amortizetion
Financial Products and/or Financial Activities of
Financial lnstih.rtions
ftlother (specrfyl >
LATE PARTIAL D]SPOSITION ELECTION
Exempt organization. Enter Code secton >
To be eligible lor opprovol of the requested chonqe in method oI accounting, the toxpoyer must provide oll infomotion thot is relevant to the toxpayet
or to the toxpoyer's requested chonge in method of dccounting- Thb includes oll infomotion requested on this Form 3715 (including its instructions), os
well os any other infoflnation thot is not specifically requested.
The hrp.yar must attach all applicable supplemental statements requested this form.
Enter the applicable desrgnated automatic accounting method change number for the requested automaiic change. Enter
only one designated automatic accounting method change number, excepl as provided for in guidance published hy the
lRS. lfthe requested drange has no designated automatic accounung method change number, check "Other," and provide
both a description of tie change and citation of the IRS guidance providing the automatic change. See inslructions.
> (a) Change No 196 (b) Other I Description ].
Do any of the scope limitations described in section 4.02 of Rev. Proc. 2008-52 cause automatic consent to be
unavailable for the applicanf s requested change? lf "Yes," attach an explanation. SEE ArACHiIENT
Paft ll bebw and then Paft lV. and also Schedules A E of this fom
Did or will the applicant cease to engage in the kade or business to which
terminate its existence, in the tax year of change (see instructions)?
the requested change relates, or
lf "Yes," the applicant is not eligible to make the change under automatic change request procedures.
4a Does the applicant (or any present or former consolidated group in which the applicant was a member during the
applicable tax year(s)) have any Federal income tax return(s) under examination (see instructions)?
lf "No," go to line 5.b ls the method of accounting the applicant is requesting to change an issue (with respect to either the applicant or
any present or former consolidated group in which the applicant was a member during the applicable tax years(s))
either {i} under consrderation or
Signature (see instruction s)
Under penaliies of perjury, I dcdare that I have examined this application, including accompanying schedules and slatements, and to the best of my knwledge and belief
the application contains all the relevanl facls relating to the applicalion and it is true, corect, and complete. Dedaration of preparer (olher than apdicnl) is based on all
infomatron of which prcparer has any knowledge.
Neme and title (print or typel
l{ame of flrm preparlng tte appllcauon
lf Form 2848, Power of Attorney and Dedaration of Representative, is attached (see instructions for when Form 2848 is
R. KEEN, SVP, CFO AND TREASURER
Slgnetura of individual preparlng the applicatlon end
BRYAN PLESKAG
DELOITTE TAX LLP
For Privacy Act and Paperwork Reduction Act Notice, see the instructions,Cat No 19280E Form 3115 (Rev- 12-2oog)
Form 31 15 IDACORP, INC.
4c ls the method of accounting the applicant is requesting to change an issue pending (with respect to either the
applicant or any present or former consolidated group in which the applicant was a member during the applicabh
tax year(s)) for any tax year under examination (see instructions)?
d ls the request to change the method of accounting being filed under the procedures requiring that the operating
division director @nsent to the filing of the request (see instructions)?.
lf 'Yes," attach the consent stiatement from he director.
e ls the request to change the method of accounting being filed under the 90-day or 12O4ay window period?
_[ Yes," check Qq box for the applicable window period and attach the required statement (see instructions).
[so Oay fltzo Oay: Date examination ended > NrA
f lf you answered "Yes' to line 4a, enter the name and telephone number of the examining agent and the tax
yea(s) under examination.
Name )SHERRIE SHULTS Telephone number > 20g-387-2829,x286 Taxyear(s) ) 20l,lcAPPrsm
Has a copy of this Form 31 '15 been provided to the examining agent identlfied on line 4f?.
Does the applicant (or any present or former consolidated group in which the applicant was a member during the
applicable tax year(s)) have any Federal income tax retum(s) before Appeals and/or a Federal court?.
lf"Yes,"enterthenameofthe(checkthebox) tr Appealsofficerand/or fl counsel forthegovemment,
telephone number, and the tax years(s) before Appeals and/or a Federal court
Name ) N/A Telephone number > N/A Taxyea(s) > NrA
b Has a copy of this Form 31 15 been provided to the Appeals officer and/or counsel for the govemment identified
on line 5a?
ls the method of accounting the applicant is requesting to change an issue under consideration by Appeals and/or
a Federal court (for either the applicant or any present or former consolidated group in which the applicant was a
member for the tax year(s) the applicant was a member) (see instructions)?
lf "Yes," attach an explanation.
lf the applicant answered "Yes" to line 4a and/or 5a with respect to any present or former consolidated group,
attach a statement that provides each parent corporation's (a) name, (b) identification number, (c) address,
and (d) tax year(s) during which the applicant was a member that is under examination, before an Appeals office,
and/or before a Federal court.SEE ATTACHTENT
lf, for federal income tax purposes, the applicant is either an entity (including a limited liability company) treated as
a partnership or an S corporation, is it requesting a change from a method of accounting that is an issue under
consideration in an examination, before Appeals, or before a Federal court, with respect to a Federal income tax
retum of a partner, member, or shareholder of that entity?
lf "Yes," the applicant is not eligible to make the change.
Does the applicable revenue procedure (advance consent or automatic consent) state that the applicant does not
receive audit protection for the requested change (see instructions)? .
lf "Yes," attach an explanation. NrA
Has the applicant, its predecessor, or a related party requested or made (under either an automatic change
procedure or a procedure requiring advance consent) a change in method of accounting within the past 5 years
(including the year of the requested change)?b lf 'Yes," for each trade or business, attach a description of each requested change in method of accounting
(including the tax year of change) and state whether the applicant received consent.SEE ATTACHTENT
c lf any application was withdrawn, not perfected, or denied, or if a Consent Agreement granting a change was not
signed and returned to the lRS, or the change was not made or not made in the requested year of change, attach
an explanation. N/A
10a Does the applicant, its predecessor, or a related party currently have pending any request (including any
concurrently filed request) for a private letter ruling, change in method of accounting, or technical advice?b lf 'Yes," for each request attach a statement providing the name(s) of the tarpayer, identification number(s), the
type of request (private letter ruling, change in method of accounting, or technical advice), and the specific issue(s)
in the request(s).SEE ATTACHTENT
11 ls the applicant requesting to change its overall method of accounting?
lf "Yes," check the appropriate boxes below to indicate the applicant's present and proposed methods of
accounting. Also, complete Schedule A on page 4 of this form.
Prcsent method: t] Cash tr Accrual tr Hybrid (attach description)
2
No
s
5a
t{/A
N/A
8a
b
9a
Proposed method:Cash Accrual Hybrid (attach description)
(Rw. 12-2009)
Form 31 1 5 IDACORP, INC.E$0505802
lf the applicant is either (i) not changing its overall
accounting and also changing to a special method
complete description for each of the following:
The item(s) being changed.
The applicants present method for the item(s) being changed.
The applicants proposed mehod for the item(s) being changed.
The applicants present overall method of accounting (cash, accrual, or hybrid).
Attach a detailed and complete description of he applicants trade(s) or business(es), and the principal business
activity code for each. lf the applicant has more than one trade or business as defined in Regulations section
1.446-1(d), describe: whether each trade or business is accounted for separately the goods and services
provided by each trade or business and any other types of activities engaged in that generate gross income; the
overall method of accounting for each trade or business; and which trade or business is requesting to change its
accounting method as part of this application or a separate application.SEE ATT
14 Will the proposed method of accounting be used for the applicants books and records and financial statements?
For insurance companies, see the instructions
lf "No," attach an explanation.
2nd preceding preceding
12
a
b
c
d
l3
20
21
22
23a
b
method of accounting, or (ii) is changing its overall method of
of accounting for one or more items, attach a detailed and
SEE
SEE
19
I 5a Has the applicant engaged, or will it engage, in a transaction to which section 381 (a) applies (e.9., a
reorganization, merger, or liquidation) during the proposed tax year of change determined without regard to any
potential closing of the year under section 381(b)(1)?
b lf 'Yes," for the items of income and expense that are the subject of this application, attach a statement identifying
the methods of accounting used by the parties to the section 381(a) transaction immediately before the date of
distribution or transfer and the method(s) that would be required by section 381 (c)(4) or (cX5) absent consent to
the change(s) requested in this application. N/A
l6 Does the applicant request a conference with the IRS National ffice if the IRS proposes an adverse response?
17 lf the applicant is changing to either the overall cash method, an overall accrual method, or is changing its method
of accounting for any property subject to section 2634, any long-term contract subject to section 460, or
inventories subject to section 474, enter the applicant's gross receipts for the 3 tax years preceding the tax year of
change.
1st preceding
ended: mo.ended: mo.ended: mo.
lE ls the applicanfs requested change described in any revenue procedure, revenue ruling, notice, regulation, or
other published guidance as an automatic change request?.
lf "Yes," attach an explanation describing why the applicant is submitting its request under advance consent
request procedures.
Attach a full eplanation of the legal basis supporting the proposed method for the item being changed. lnclude a
detailed and complete description of the facts that erplains how the law specifically applies to the applicants
situation and that demonstrates that the applicant is authorized to use the proposed method. lnclude all authority
(statutes, regulations, published rulings, court cases, etc.) supporting the proposed method. Also, include either a
discussion of the contrary authorities or a statement that no contrary authority exists.
Attach a copy of all documents related to the proposed change (see instructions).
Attach a statement of the applicanfs reasons for the proposed change.
lf the applicant is a member of a consolidated group for the year of change, do all other members of the
consolidated group use the proposed method of accounting for the item being changed? .
lf "No," attach an explanation.
Enier the amount of user fee attached to this application (see instruc{ions). } $ xn
lf the for a reduced user fee. attach the information or certifi cation
Does the applicable revenue procedure, revenue ruling, notice, regulation, or other published guidance require the applicant to
implement the requested change in method of accounting on a cut-off basis rather than a section 481(a) adjustment? .
lf "Yes," do not complete lines 25,26, and 27 below.
Enter the section 481(a) adjustment. lndicate whether the adjustrnent is an increase (+) or a decrease (-) in
income. ) $ o- Attach a summary of the computation and an explanation of the methodology
used to determine the section 481(a) adjustment. lf it is based on more than one component, show the
computation for each component. lf more than one applicant is applying for the method change on the same
application, attach a list of the name, identification number, principal business activity code (see instructions), and
24
25
the amount of the 48',1 attributable to each SEE ATT
(Rev. 12-2009)
a
b
Form 3115 IDACORP. INC.E5-0505802
Yes No
(a) ad.iustment is an less than does the to take the
entire amount of the adjustnent into account in the year of cfrange?27 ls any part of the section 48'l(a) adjustrnent attributable to transactions between members of an affiliated group, a
consolidated group, a controlled group, or other related parties?
tf 'Yes." attach
Schedule A-Change in Overall Method of Accounting (lf Schedule A applies, Part I belorv must be completed.) N/A
in Overall Method (see instructions
2
3
Enter the following amounts as of the close of the tax year preceding the year of change. lf none, state "None." Also, attach a
statement providing a breakdown of the amounts entered on lines I a through 19.
I Ar__t
lncome accrued but not received (such as accounts receivable) . . .lS
lncome received or reported before itwas eamed (such as advanced payments). Attach a description of
the income and the legal basis for the proposed method . . . . . I
Expenses accrued but not paid (such as accounts payable)
Prepaid expense previously deducted
Suppliesonhandpreviouslydeductedand/ornotpreviouslyreported
lnventoryonhandpreviouslydeductedand/ornotpreviouslyreported.GompleteScheduleD,Partll
Other amounts (specify). Attach a description of the item and the legal basis for its inclusion in the I
Icalculation of the section 481(a) adjustment. )
Net section 481(a) adjustment (Combine lines 1a-1 g.) lndicate whether the adjustment is an increase (+) I
or decrease (-) in income. Also enter the net amount of this section 481(a) adjustnrent amount on Part lV, Iline 25 .
ls the applicant also requesting the recuning item exception under section 461(hX3)? . ! Ves E fo
Attach copies of $e profit and loss statement (Schedule F (Form 1040) forfarmers) and the balance sheet, if applicable, as of
the close of the tax year preceding the year of change- Also attach a statement specifuing the accounting method used when
preparing the balance sheet. lf books of account are not kept, attach a copy of the business schedules submitted with the
Federal income tax return or other retum (e.9., tax-exempt organization retums) for that period. lf the amounts in Part l, lines
1a through 19, do not agree with those shown on both the profit and loss statement and the balance sheet, attach a statement
inino the differences.
to the Cash Method For Advance Consent
Applicants requesting a change to the cash method must attach the following information:I A description of inventory items (items whose production, purchase, or sale is an income-producing factor) and materials and
supplies used in carrying out the business.2 An explanation as to whether the apolicant is required to use the accrual method under anv section of the Code or reoulations.
Schedule B-Change to the Deferral Method for Advance Payments (see instructions)N/A
lf the applicant is requesting to change to the Defenal Method for advance payments described in section 5.02 of Rev. Proc.
2004-34,2004-1 C.B. 991, attach the following information:a A statement explaining how the advance payments meet the definition in section 4.01 of Rev. Proc. 2004-34.b lf the applicant is filing under the automatic change procedures of Rev. Proc. 2008-52, the information required by section
8.02(3)(a)-(c) of Rev. Proc. 2OO4-34.
c lf the applicant is filing under the advance consent provisions of Rev. Proc.97-27, the information required by section
8.03(2)(a)-(f) of Rev. Proc. 2004-34.
lf the applicant is requesting to change to the defenal method for advance payments described in Regulations section
1.451-5(b)(1 Xii), attach the following.
A statement explaining how the advance payments meet the definition in Regulations section 1.451-s(aXl ).
A statement explaining what portions of the advance payments, if any, are attributable to services, whether such services are
integral to the provisions of goods or items, and whether any portions of the advance payments that are attributable to
non-integral services are less than five percent of the total contract prices. See Regulations sections 1.451-5(a)(2)(i) and (3).
A statement explaining that the advance payments will be included in income no later than when included in gross receipts for
purposes of the applicant's financial reports. See Regulations section 1.451-5(bX1)(ii).
A statement explaining whether the inventoriable goods exception of Regulations section 1 .a51-5(c) applies and if so, when
substantial advance payments will be received under the contracts, and how the exception will limit the defenal of income.
c
d
e
t
s
a
b
Form 3115 (Rev. 12.2009)
Form 31 15 (Rev. 12-2009) IDACORP, lNC. ESO5O58O2 Page 5
Schedule C-Changes Within the LIFO lnventory Method (see instructions)N/A
lnformation
Complete this section if the requested change involves changes within the LIFO inventory method. Also, attrach a copy of all
Forms 970, Application To Use LIFO lnventory Methcd, fiied to adopt or expand lhe use of the LIFO method.I Attach a description of the applicant's present and proposed LIFO methods and submethods for each of the following
items:
a Valuing inventory (e.9., unit method or dollar-value method).b Pooling (e.g., by line or type or class of goods, natural business unit, multiple pools, raw material content, simplified dollar-
value method, inventory price index computation (lPlC) pools, vehicle-pool method, etc.).c Pricing dollar-value pools (e.9., double-extension, index, link-chain, link-chain index, lPlC method, etc.).d Determining the cunent-year cost of goods in the ending inventory (i.e., most recent acquisitions, earliest acquisitions during
the cunent year, average cost of cunent-year acquisitions, or other permitted method).2 lt any present method or submethod used by the applicant is not the same as indicated on Form(s) 970 filed to adopt or
expand the use of the method, aftach an eplanation.
3 lf the proposed change is not requested for all the LIFO inventory, attach a statement specifying the inventory to which the
change is and is not applicable.4 lf the proposed change is not requested for all of the LIFO pools, attach a statement specifying the LIFO pool(s) to which the
change is applicable.5 Attach a statement addressing whether the applicant values any of its LIFO inventory on a method other than cost. For
example, if the applicant values some of its LIFO inventory at retail and the remainder at cost, identify which inventory items
to the lPlC 970.
lnventories
I lf the applicant is proposing to change its pooling method or the number of pools, attach a description of the contents of, and
state the base year for, each dollar-value pool the applicant presently uses and proposes to use.2 lf the applicant is proposing to use natural business unit (NBU) pools or requesting to change the number of NBU pools,
attach the following information (to the extent not already provided) in sufficient detail to show that each proposed NBU was
determined under Regulations section 1.4724(b)(1) and (2):
a A description of the types of products produced by the applicant. lf possible, attach a brochure.b A description of the types of processes and raw materials used to produce the products in each proposed pool.
c lf all of the products to be included in the proposed NBU pool(s) are not produced at one facility, state the reasons for the
separate facilities, the location of each facility, and a description of the products each facility produces.d A description of the natural business divisions adopted by the taxpayer. State whether separate cost centers are maintained
and if separate profit and loss statements are prepared.
e A statement addressing whether the applicant has inventories of items purchased and held for resale that are not further
processed by the applicant, including whethersuch items, if any, will be included in any proposed NBU pool.
f A statement addressing whether all items including raw materials, goods-in-process, and finished goods entering into the
entire inventory investment for each proposed NBU pool are presently valued under the LIFO method. Describe any items that
are not presenUy valued under the LIFO method that are to be included in each proposed pool.g A statement addressing whether, within the proposed NBU pool(s), there are items both sold to unrelated parties and
transfened to a different unit of the applicant to be used as a component part of another product prior to final processing.
3 lf the applicant is engaged in manufacturing and is proposing to use the multiple pooling method or raw material content
pools, attach information to show that each proposed pool will consist of a group of items that are substantially similar. See
Regulations section 1 .47 2-e(il@).4 lf the applicant is engaged in the wholesaling or retailing of goods and is requesting to change the number of pools used,
attach information to show that each of the proposed pools is based on customary business classifications of the applicant's
,r"0" o'. Or",n"a". a"" *".r,",'on. "."t,on , .Orr-4,"r. ,* ,r, _ ,rrr, ,rr_,
are valued undereach method.
No
No
2a
b
3a
b
To tre extent not already provided, aftach a description of &re applicanfs present and proposed methods for reporting income
and expenses from long-term conbacts. Also, attach a representiative actual contract (without any deletion) for the requested
change. lf the applicant is a construdion contractor, attactr a detailed description of its construction activities.
Are the applicants contracts long-term contracts as defined in section 460(0(1) (see instruciions)? [Ves
lf 'Yes," do all the contracts qualify for the exception under section 460(e) (see instructions)? . f]Ves
lf line 2b is "No," attach an erplanation.
lf line 2b is'Yes," is the applicant requesting to use the percentage-of-completion method using cost-to-
cost under Regulations section 1.4604(b)? .flves
lf line 2c is "No," is the applicant requesting to use the exempt-contract percentage-of-completion
methodunderRegulationssectionl.a6}a(c\Q\? ....flVes
lf line 2d is "Yes," attach an eplanation of what cost comparison the applicant will use to determine a
contract s completion factor.
lf line 2d is "No," attach an explanation of what method the applicant is using and the authority for its use.
Does the applicant have long-term manufacturing contracts as defined in section 460(0(2)?. .[Ves
lf "Yes," attach an explanation of the applicant's present and proposed method(s) of accounting for long-
term manufacturing contracts.
Attach a description of the applicant's manufacturing activities, including any required installation of manufactured goods.
To determine a contracts completion factor using the percentage-of-completion method:
Will the applicant use the cost-to-cost method in Regulations section 1.460-4(b)? . [Ves E tto
lf line 4a is "No," is the applicant electing the simplified cost-to-cost method (see section 460(b)(3) and
Attach a statement indicating whether any of the applicants contracts are either cost-plus long-term
contracts or Federal contracts.
Part lllon 7 and 8.
Attach a description of the inventory goods being changed.
Attach a description of the inventory goods (if any) NOT being changed,
ls the applicani subject to section ze5nz f "tto," io to line 4; . . . .Ey"s ! xo
ls the applicanfs present inventory valuation method in compliance with section 263A (see instructions)?
lf "No," attach a detailed explanation
4a Check the appropriate boxes below.
lnventory Not
Being Changed
tltr
fl x"
Eto
flno
fl tto
I
2
3a
b
ldentifi cation methods:
Specific identification
FIFO.
LIFO.
Other (attach explanation)
Valuation methods:
Cost.
Cost or market, whichever is lower
Retail cost
Retail, lower of cost or market
Other (attach explanation)
Enter the value at the end of the tax year preceding the year of change
lf the applicant is changing from the LIFO inventory method to a non-LIFO method, attach the following information (see
instructions).
Copies of Form(s) 970 filed to adopt or expand the use of the method.
Only for applicants requesting advance consent A statement describing whether the applicant is changing to the method
required by Regulations section 1 .472-6(a) or (b), or whether the applicant is proposing a different method.
Only for applicants requesting an automatic change. The statement required by section 22.01(5) of the Appendix of Rev.
Present method
b
5
a
b
Proc. 2008-52 (or its
(Rw. 12-2009)
to section 263A or long-term contracts as described in section 460 (see instruclions)). N/A
Attach a description (including sample computations) of the present and proposed method(s) he applicant uses to capitalize Cirect
and indirect costs properly allocable to real or tangible personal property produced and property acquired for resale, or to allocate
and, where appropriate, capitalize direct and indirect costs properly allocable to long-term contracts. lnclude a desoiption of the
inethod(s) used for allocating inclirect costs to intermediate cost objectives such as departments or activities prior to the allocation of
such costs to long-term contracts, real or tangible personal property produced, and property acquired for resale. The description
must include the following:
I Themethodofallocatingdirectandindirectcosts(i.e.,specificidentification,burdenrate,standardcost,orotherreasonable
allocation method).
2 The method of allocating mixed service costs (i.e., direct reallocation, step-allocation, simplified service cost using the labor-
based allocation ratio, simplified service cost using the production cost allocation ratio, or other reasonable allocation
method).
3 The method of capitalizing additional section 263A costs (i.e., simplified production with or without the historic absorption
ratio election, simplified resale with orwithout the historic absorption ratio election including permissible variations, the U.S.
ratio, or other reasonable allocation method).
Section B-Direct and lndirect Costs Required to be Allocated
Check the appropriate boxes showing the costs that are or will be fully included, to the extent required, in the cost of real or tangible
personal property produced or property acquired for resale under section 2634 or allocated to long-term contracts under section
460. Mark "N/A" in a box if those costs are not incuned by the applicant. lf a box is not checked, it is assumed that those costs are
for boxes that are not checked.
Proposed method
1
2
3
1
5
6
7
8
I
t0
11
12
13
14
15
t6
17
t8
l9
20
21
22
23
21
25
26
27
Direct material
Rent
Bidding expenses incuned in the solicitation of contracts awarded to the applicant
Licensing and franchise costs
Direct labor
lndirect labor
Offi cers' compensation (not including selling activities)
Pension and other related costs
Employee benefits
lndirect materials and supplies
Purchasing costs
Handling, processing, assembly, and repackaging costs
Offsite storage and warehousing costs
Depreciation, amortization, and cost recovery allowance for equipment and facilities
placed in service and not temporarily idle
Depletion
Taxes other than state, local, and foreign income taxes
lnsurance
Utilities
Maintenance and repairs that relate to a production, resale, or long-term contract activity
Engineering and design costs (not including section 174 research and e&erimental
expenses)
Rework labor, scrap, and spoilage
Tools and equipment
Quality control and inspection
Capitalizable service costs (including mixed service costs)
Administrative costs (not including any costs of selling or any retum on capital)
Research and e&erimental expenses attributable to long-term contracts
lnterest
2E Other costs a list of
(Rev. 12-2009)
1
2
3
4
5
6
7
E
I
t0
Form 3115 IDACORP. INC 8$0505802
Costs Not Required To Be Section C only if the applicant is requesting to change its
for these costs.
Proposed method
Marketing, selling, advertising, and distribution expenses
Research and experimental expenses not included in Section B, line 26
Bidding epenses not included in Section B,line 22
General and administrative costs not included in Section B
lncome traxes
Cost of strikes
Wananty and product liability costs
Section 179 costs
On-site storage
Depreciation, amortization, and cost recovery allowance not included in Section B,
line 'l 1
'i1 Other costs a list of
Schedule E-Ghange in Depreciation or Amortization (see instructions)N/A
Applicants requesting approval to change their method of accounting for depreciation or amortization complete this section.
Applicants must provide this information for each item or class of property for which a change is requested.
Note: See the List of Automatic Accounting Method Changes in the instructions for information regarding automatic changes
undersectionsS6, 167, 168, 197, 14001, 1400L,orformersection168. DonotfileForm3llSwithrespecttocertainlateelections
and election revocations (see instructions).
I ls depreciation for the property determined under Regulations section 1.167(al-11 (CLADR)? fl Ves tr No
lf "Yes," the only changes permitted are under Regulations section 1.167(a)-11(c)(1)(iii).2 ls any of the depreciation or amortization required to be capitalized under any Code section (e.9., section263A1? ...f1 ves E No
lf "Yes," enter the applicable section )
Has a depreciation, amortization, or erpense election been made for the property (e.9., the election under
sections 168(0(1), 179, or 179C1? .! Ves tr No
lf "Yes," state the election made >
4a To the extent not already provided, attach a statement describing the property being changed. lnclude in the description the
type of property, the year the property was placed in service, and the property's use in the applicanfs trade or business or
income-producing activity.
b lf the property is residential rental property, did the applicant live in the property before renting t? . . , ! Ves
c ls the property public utillty property? .f] Ves5 To the extent not already provided in the applicants description of its present method, attach a statement explaining how the
property is treated under the applicant's present method (e.9., depreciable property, inventory property, supplies under
Regulations section 1.162-3, nondepreciable section 263(a) property, property deductible as a current expenses, etc.).6 lf the property is not currently treated as depreciable or amortizable property, attach a statement of the facts supporting the
proposed change to depreciate or amortize the property.7 lf the property is cunently treated and/or will be treated as depreciable or amortizable property, provide the following
information for both the present (if applicable) and proposed methods:a The Code section underwhich the property is orwill be depreciated or amortized (e.9., section 168(g)).b The applicable asset class from Rev. Proc. 87-56, 1987-2 C.8.674, for each asset depreciated under section 168 (MACRS) or
under section 1400L; the applicable asset class from Rev. Proc. 83-35, 1 983-1 C.B. 745, for each asset depreciated under
former section 168 (ACRS); an explanation why no asset class is identified for each asset for which an asset class has not
been identified by the applicant.c The facts to support the asset class for the proposed method.d The depreciation or amortization method of the property, including the applicable Code section (e.g., 200% declining balance
method under section 168(b)(1)).e The useful life, recovery period, or amortization period of the property.f The applicable convention of the property.g A statement of whether or not the additional first-year special depreciation allowance (for example, as provided by section
1 68(k), 1 68(l), I 68(m), 168(n), 'l 400L(b), or 1400N(d)) was or will be claimed for the property. lf not, also provide an explanation
EfI No
No
IDACORP,Inc.
Attachment to Fonn 3l15
EIN:85-0505802
FYE: l2l3ll20l4
Transition Rule Filinq Under Section 15.02(lxaxii) of Re . 20l5-13
The Applicant is filing this method change under Rev. Proc.20ll-14 pursuant to the transition rules set
forth in Section 15.02(l)(aXii) of Rev. Proc.2015-13, as modified by Rev. Proc. 2015-33.
Part I, Line2
Pursuant to Appendix section 6.33(4) of Rev. Proc. 201 l-14 (as modified by section 3.02(4) of Rev. Proc.
2014-54), the scope limitations in section 4.02 of Rev. Proc. 20ll-14 do not apply to a taxpayer that
makes this change in method of accounting under Appendix section 6.33 of Rev. Proc. 20ll-14 for any
taxable year beginning before January l, 20 I 5.
Part II, Line 6
Parent:
EIN:
Address:
Under Exam:
IDACORP,Inc.
85-0505802
PO Box 70
Boise, Idaho 83707
2Ol4 CAP Program
Part II, Line 9b & lOb
The Applicant is concurrently changing its method of accounting for treatment of generation property
expenditures to use the unit of property definitions and the corresponding major component definitions
described in Rev. Proc.2013-24 under the automatic consent procedures of Rev. Proc.20ll-14 for the
taxable year ended December 31,2014.
The Applicant is concurrently changing its method of for deducting employee incentive compensation
expense under the automatic consent procedures of Rev. Proc. 2015-14 for the taxable year ended
December 31,2014.
The Applicant is concurrently changing its method of accounting for amount paid for repairs,
maintenance and improvements to comply with Treas. Reg.$$ 1.162-4 and 1.263(a)-3, including a
change in identifying the unit of property under Treas. Reg. $ 1.263(a)-3(e) for purposes of applying the
improvement standards under Treas. Reg. $ 1.263(a)-3, and its method for incidental and non-incidental
materials and supplies under Treas. Reg. $ 1.162-3, under the automatic consent procedures of Rev. Proc.
20ll-14 for the taxable year ended December 31,2014.
The Applicant is concurrently changing its method of accounting for the dispositions of electric
generation tangible assets as provided in Treas. Reg. $ 1.168(i)-8(d)(l) under the automatic consent
procedures of Rev. Proc. 201l-14 for the taxable year ended December 31,2014.
ldaho Power Company (EIN: 82-0130980) made a late general asset account ("GA"A") election under
I.R.C. $ 168(iX4) and Treas. Reg.$$ 1.168(i)-l and 1.168(i)-1T and made a late election to recognize
gain or loss on the disposition of assets that are the subject of the late GAA election in accordance with
Treas. Reg. $ 1.168(i)-1T(eX3Xii) under the automatic consent procedures of Rev. Proc. 201l-14 for the
taxable year ended December 3l , 2013 .
Page I
IDACORP,Inc.
Attachment to Form 3115
EIN: t5-0505802
FYEz l2l3ll20l4
Idaho Power Company (EIN: 82-0130980) changed its method of accounting for transmission and
distribution property safe harbor method for repair expenditures per Section 5 of Rev. Proc.2011-43
under the automatic consent procedures of Rev. Proc. 201l-14 for the taxable year ended December 31,
201 l.
Part II, Line 12
a. The Applicant is making a late partial disposition election under Treas. Reg. $ 1.168(i>8(dx2xi)
for certain dispositions of portions of electrical generation assets. The Applicant placed the
electrical generation assets in service during 1987 through 2013, and owns the assets, as ofthe
beginning of the year of change. Portions of the electrical generation assets were permanently
withdrawn from use in the Applicant's trade or business during the taxable years 1987 through
20 I 3. The late panial disposition election is being made for Electrical generation property assets
consists of electrical generation properfy units of properly and their major components as
determined under Sections2,3, and 4 of Appendix A of Rev. Proc.2013-24.
Under its present method of accounting, the Applicant recognizes a loss upon the disposition of a
portion of electrical generation assets. Under its present method of accounting, the Applicant
depreciates the remaining portion of the electrical generation assets using the applicable method,
recovery period, and convention under I.R.C. $ 168 and Rev. Proc. 87-56.
Under the proposed method, the Applicant will make a late partial disposition election under
Treas. Reg. $ 1.168(i)-8(dx2xi) for the electrical generation assets that are the subject ofthis
request. The Applicant will apply the rules under Treas. Reg. $$ 1.168(D-8(f)(3) and (h) to
determine the portion of the assets disposed of and the portion of the assets retained. See Treas.
Reg. $ I .168(i)-8(i), Examples 3 and 7. The Applicant will not claim any future depreciation
deductions associated with the disposed portions ofthe asset that are the subject ofthis request.
This request does not apply to any assets for which the Applicant has made a GAA election.
d. The Applicant's overall method of accounting is an accrual method.
Part II, Line 13
The Applicant is a regulated electric utility engaged in the production, transmission, distribution, and sale
of electric energy throughout ldaho and Eastern Oregon. The principal business activity code is 221100.
Part II, Line 14
The Applicant will not use the proposed method of accounting in its books and records or its financial
statements because the proposed method does not conform to generally accepted accounting principles
(GAAP).
Part fV, Line 25
There is no difference between the present and proposed methods of calculating dispositions for these
assets, therefore the t.R.C. $ a8l(a) adjustment is $0.
b.
Page2
IDACORP,Inc. EIN: t5-11505t02
Attachment to Form 3ll5 FYE: l2lJl20l4
Statement Required Under Section 6.33(6xbxvi) of Rev. Proc. 20ll-14, as amended by Rev. Proc.
2Al+54
The Applicant agrees to the following additional terms and conditions:
(A) A normalization method of accounting (within the meaning of I.R.C. $ 168(iX9)) will be used for
the public utility property subject to the application;
(B) As of the beginning of the year of change, the taxpayer will adjust its deferred ta:( reserve account
or similar account in the taxpayer's regulatory books of account by the amount of the deferral of
federal income ta:r liability associated with the I.R.C. $ 481(a) adjustment applicable to the public
utility property subject to the application; and
(C) Within 30 calendar days of filing the federal income tar return for the year of change, the ta(payer
will provide a copy of the completed application to any regulatory body having jurisdiction over the
public utility property subject to the application.
Request for Facsimile Transmission Pursuant to Section 9.04(3) of Rev. Proc.20l5-l
In accordance with the procedures set forth
requests that a copy of any document related
representatives via fax at the numbers below:
Applicant's Representatives
Jane Rohrs
Bryan Pleskac
section 9.04(3) of Rev. Proc. 2015-1, the Applicant
this request be provided to the Applicant's authorized
in
to
Fax Number
(877) s0t-2s99
(402) s9e-6002
Frn 3115
{Rw Cromba2009)
ffi#il,::iT,:ff
Application for Change in Accounting Method O{t B No. 1ilS152
numbsr (Sea ins{ructions}
businGs .divrty 6dc numb.r (sce instrudions)
-{-*glg:-sr0lu.9-9fiY12 _ -- _ 01,01no1 /t
of drre end3 tUlrEOrYYYYl 121111fr11
tltrE
Etl
lndividual
Corporation
Controlled forei gn corporatron
(Sec.957)
I 0150 corporation (Sec. 904(dX2XE))
Oualilied personal service
corporation (Sec. 448(dX2))
Exempt organizafion. Enter Code section >
Ca|,[|p/.t, To be ellgible lor opprovol of the requested chonge in metw of accout ting, the toeowr must provi& oll infomotion thot is relevont to the toxwyel
or to the toxpoyer's requested chonge in method of occounting. This inclvdes oll inlormdtion rcquested on this Forn 3175 (including its in*rudions), o:
well as ony other inlomo6on hot is not specificolly requested.
The must attach all applicable supplemerilal statemenls requBted this fotm.
Enter he applicable designated automatic accounting melhod change number for the requested automatic change. Enter
only one designated automatic accounting melhod cfiange number, except as provided for in guidance published by the
lRS. lfthe requested change has no designated autornatic accounung method change number, cfieck "Other.'and provide
bolh a description of the change and citalion of lhe IRS guidance providing the automatic change- See instructions.
) (a) Change No. 206 (b) Other ! Description ).
Do any of the scope limitations described in section 4.02 of Rev. Proc. 200&52 cause automatic consent to be
unavailable for the applicant's requested change? lf "Yes," attach an explanation.SEE ATTACHIIENT
Note: Corro4ote Peil ll below and then Paft N. and als Schedu/es A tlnomh E of this form
Did or will the applicant cease to engage in the trade or business to which the requested change relates, or
terminate its existence, in the tax year of change (see instructions)?
lf "Yes," the applicant is not eligible to make the change under automatic change request procedures.
Does the applicant (or any present or former consolidated group in which the applicant was a member during the
applicable tax year(s)) have any Federal income cax refurn(s) under examination (see inskuctions)?
lf "No," go to line 5.
b ls the method of accounting the applicant is requesting to change an issue (with respect to either the applicant or
any present or former consolidated group in which the applicant was a member during the applicable tax years(s))
either (i) under consideration or
Signature (see in structions)
Under penalties of pcrjury, I dedare that I haw examined this applicaion, induding accompanying schedules and datements, and to the b.st of my knowledge and bclief
the application cont€ins all the rdevant facls rdding to the applicdiffi, and it is true. con c1. and comdetc. Odaratim of prcparcr (olher than appficant) is based m dl
informatjon ol which preparer has any knowledge.
and date
N.me ofindividu.l prcp.ring the .pplicrtion (print or type)
OELOITTE TAX LLP
Name of firm pruparing the application
1a
ftCmoeravatsec. 1381)
l-leartnersnip
IS corporation
llnsurance co, (Sec. 816(a))
fllnsurance co. (Sec. 831)
f]other (speci!) >
Narrn o( fibr (na.rE of parent corporation il a onsolidded grcup) (s€ inslructions)
loAcoRP. Drc.
Itmber. strclt. and roo{r ot suite no. tf a P.O box. se€ the inslrucLons.
City or toxtt, state, and ZIP code
Name of apdican(s) (f ditferenl rhan flcr) and identification numbe(s) (sec inslructiom)
Elil
lf the is a member of a consolidated
of contacl p€rion (sac instructlons)
p€rson's tdephone number
of accounting method change being requested.
(see instructions)
I Depreciation or funortization
IFinancial Products and/or Financial Activities of
Financial lnstititions
filother (specjfy) >
DETERIINAIIOI{ Of TAIiI(IBLE ASSETS DISPOSED
check this box.
typs appropri.t box b
lf Form 2648, Power of Attorney and Declaration of Representative, is attached (see instructions for when Form 2848 is
SVP, CFO ANO
(prlnt or typef
BRYAN PLESKAC
For Prlvacy Act and Papenrvork Reductlon Act Notice, see the instructions.cat. No 19280E Form 3115 (Rev. 12-2009)
Form 3115 IDACORP. INC.8$0505802
4c ls the method of accounting the applicant is requesting to change an issue pending (with respect to either the
applicant or any present or former consolidated group in which the applicant was a member during the applicable
tax year(s)) for any tax year under examination (see instructionsp .d ls the request to change the method of accounting being filed under the procedures requiring that the operating
division director consent to the filing of the request (see instructions)?.
lf 'Yes," attach the consent statement from the direclor.e ls the request to change the method of accounting being filed under the 9Gday or 1204ay window period?.
_!I_Yes," check the box for the applicable window period and attach the required statement (see instructions).
lSO aay fltZO Aay: Date examination ended > N/Af lf you answered 'Yes" to line 4a, enter the name and telephone number of the examining agent and the tax
year(s) under examination.
Name )SHERRIE SHULTS Telephone number > 20s.3s7-2829, rz86 Tax year(s) ) 2014 cAp Plgm
Has a copy of this Form 31 15 been provided to the examining agent identifed on line 4f? .
Does the applicant (or any present or former cpnsolidated group in which the applicant was a member during the
applicable tax year(s)) have any Federal income tax retum(s) before Appeals and/or a Federal court? .
lf'Yes,"enterthenameofthe(checkthebox) tr Appealsofficerand/or I counsel forthegovemment,
telephone number, and the tax years(s) before Appeals and/or a Federal court.
Name ) N/A Telephone number )N/A Tax year(s) )N/A
Has a copy of this Form 31 15 been provided to the Appeals officer and/or counsel for the govemment identified
on line 5a?
ls the method of accounting the applicant is requesting to change an issue under consideration by Appeals and/or
a Federal court (for either the applicant or any present or former consolidated group in which the applicant was a
member for the tax year(s) the applicant was a member) (see instructions)?
lf 'Yes," attach an explanation.
If the applicant answered 'Yes" to line 4a and/or 5a with respect to any present or former consolidated group,
attach a statement that provides each parent corporation's (a) name, (b) identification number, (c) address,
and (d) tax year(s) during which the applicant was a member that is under examination, before an Appeals office,
and/or before a Federal court.SEE ATTACHTENT
ll for federal income tax purposes, the applicant is either an entity (including a limited liability company) treated as
a partnership or an S corporation, is it requesting a change from a method of accounting that is an issue under
consideration in an examination, before Appeals, or before a Federal court, with respect to a Federal income tax
retum of a partner, member, or shareholder of that entity?
lf 'Yes," the applicant is not eligible to make the change.
8a Does the applicable revenue procedure (advance consent or automatic consent) state that the applicant does not
receive audit protection for the requested change (see instructions)? .
b lf 'Yes," aftach an explanation. NrA
9a Has the applicant, its predecessor, or a related party requested or made (under either an automatic change
procedure or a procedure requiring advance consent) a change in method of accounting within the past 5 years
(including the year ofthe requested change)?b lf 'Yes," for eacfi trade or business, attach a description of each requested change in method of accounting
(including the tax year of change) and state whether the applicant received consent.SEE ATTACHMENTc lf any application was withdrawn, not perfected, or denied, or if a Consent Agreement granting a change was not
signed and retumed to the lRS, or the change was not made or not made in the requested year of change, attach
an explanation. N/A
10a Does the applicant, its predecessor, or a related party cunently have pending any request (induding any
concunently filed request) for a private letter ruling, change in method of accounting, or technical advice?b lf "Yes," for each request attach a statement providing the name(s) of the taxpayer, identification number(s), the
type of request (private letter ruling, change in method of accounting, or technical advice), and the specific issue(s)
in the request(s).SEE ATTAGHiIENT11 ls the applicant requesting to change its overall method of accounting?
lf "Yes," check the appropriate boxes below to indicate the applicant's present and proposed methods of
accounting. Also, complete Schedule A on page 4 of this form.
Presentmethod: n Cash tr Accrual E Hybrid (attach desoiption)
2
No
1{/A
N/A
N'A
s
5a
N/A
ItlrA
me0rod:Cash Accrual Hybrid (attach desoiption)
Form 3115
12
a
b
c
d
13
23a
b
SEE ATT
The item(s) being changed.
The applicanfs present method for the item(s) being changed.
The applicant's proposed method for the item(s) being changed.
The applicanfs present overall method of accounting (cash, accrual, or hybrid).
Attacfi a detailed and complete description of the applicanfs trade(s) or business(es), and the principal business
activity code for each. lf the applicant has more than one trade or business as defined in Regulations section
1.,14&1(d), describe: whether each trade or business is accounted for separately; the goods and services
provided by each trade or business and any other types of activities engaged in that generate gross income; the
overall method of accounting for each trade or business; and which trade or business is requesting to change its
accounting method as part of this application or a separate application.SEE A14 \Mll the proposed method of accounting be used for the applicant's books and records and financial statements?
For insurance companies, see the instructions
lf "No," attach an explanation. SEE ATT
l5a Has the applicant engaged, or will it engage, in a transaction to which section 381 (a) applies (e.9., a
reorganization, merger, or liquidation) during the proposed tax year of change determined without regard to any
potential closing of the year under section 381 (bxl )?b lf "Yes," for the items of income and expense that are the subject of this application, attach a statement identifying
the methods of accounting used by the parties to the section 381(a) transaction immediately before the date of
distribution or transfer and the method(s) that would be required by section 381(cX ) or (c)(5) absent consent to
the change(s) requested in this application. N/Al6 Does the applicant request a conference with the IRS National ffice if the IRS proposes an adverse response?
17 If the applicant is changing to either the overall cash method, an overall accrual method, or is changing its method
of accounting for any property subject to section 2634, any long-term contract subject to section 460, or
inventories subject to section 474, enter the applicanfs gross receipts for the 3 tax years preceding the tax year of
change.
1st prcceding preceding
ended: mo.
preceding
N/A
l8 ls the applicants requested change described in any revenue procedure, revenue ruling, notice, regulation, or
other published guidance as an automatic change request?.
lf 'Yes," attach an explanation describing why the applicant is submitting its request under advance consent
request procedures.
Attrach a full explanation of the legal basis supporting the proposed method for the item being changed. lnclude a
detailed and complete description of the facts that explains how the law specifically applies to the applicant's
situation and that demonstrates that the applicant is authorized to use the proposed method. lnclude all authority
(statutes, regulations, published rulings, court cases, etc.) supporting the proposed method. Also, include either a
discussion of the contrary authorities or a statement that no contrary authority exists.
Attach a copy of all documents related to the proposed change (see instructions).
Attach a statement of the applicanfs reasons for the proposed change.
lf the applicant is a member of a consolidated group for the year of change, do all other members of the
consolidated group use the proposed method of accounting for the item being changed?
lf "No," attach an explanation.
Enter the amount of user fee attached to this application (see instruc{ions). } $ I\lll
lf the for a
Does the applicable revenue procedure, revenue ruling, notice, regulation, or other published guidance require the applicant to
implement the requested change in method of accounting on a cut-off basis rather than a section 481 (a) adjustment?.
lf 'Yes," do not complete lines 25, 26, and 27 below.
Enter the section 481(a) adjustment. lndicate whether the adiustment is an increase (+) or a decrease (-) in
income. ) $ -(r-Attach a summary of the computation and an explanation of the methodology
used to determine the section 481(a) adjustment. lf it is based on more than one component, show the
computration for each component. lf more than one applicant is applying for the method change on the same
application, attach a listof the name, identification number, principal business activity code (see instructions), and
IDACORP. INC.8$0505802
lf the applicant is either (i) not changing its overall method of accounting, or (ii) is changing its overall method of
accounting and also changing to a special method of accounting for one or more items, attach a detrailed and
complete description for each of the following:
ended: mo-
t9
20
21
22
24
Form 3115 (Rev. 12-200e)
25
the amount of the section 481 attributable to each SEE A
26
27
Form 31 1 5 (Rev. 12-2009)IDACORP. INC.8$0505E02 4
Yes No
an increase to less than does the applicant elect to take the
entire amount of the adjustnent into account in the year of change?
ls any part of the section 481(a) adjustrnent attributable to transactions between members of an affiliated group, a
consolidated group, a controlled group, or other related parties?
" attacfi an
in Overall Method (see instructions
Enter the following amounts as of the close of the tax year preceding the year of change. lf none, state "None." Also, attach a
statement providing a breakdown of the amounts entered on lines 1 a through 19.
I Ar*,,r
lncome accrued but not received (such as accounts receivable) lL
lncome received or reported before it was earned (such as advanced payments). Attach a description of
the income and the legal basis for the proposed method . . . . .lExpensesaccruedbutnotpaid(suchasaccountspayable)l-
Prepaid expense previously deducted I
Supplies on hand previously deducted and/or not previously reported I
lnventoryonhandpreviouslydeductedandlornotpreviouslyreported.CompleteScheduleD,Partll
Other amounts (specifl). Attach a description of the item and the tegal basis for its inclusion in the Icalculation of the section 481(a) adjustment. )
Net section 461(a) adjustment (Combine lines 1a-19.) lndicate whether the adjustment is an increase (+) Ior decrease (-) in income. Also enter the net amount of this section 481(a) adjustnrent amount on Part lV, Iline 25 . lS -
ls the applicant also requesting the recuning item exception under section 461 (h)(3)? . ! Ves E Xo
Attach copies of the profit and loss statement (Schedule F (Form 1040) for farmers) and the balance sheet, if applicable, as of
the close of the tax year preceding the year of change. Also attach a statement specifying the accounting method used when
preparing the balance sheet. lf books of account are not kept, attach a copy of the business schedules submitted with the
Federal income tax return or other return (e.9., tax-exempt organization retums) for that period. lf the amounts in Part l, lines
1a through 19, do not agree with those shown on both the profit and loss statement and the balance sheet, attach a statement
inq the differences.
to the Cash Method For Advance Consent Request(see
Applicants requesting a change to the cash method must attach the following information:I A description of inventory items (items whose production, purchase, or sale is an income-producing factor) and materials and
supplies used in carrying out the business.
2 An explanation as to whether the applicant is required to use the accrual method under anv section of the Code or reoulations.
Schedule B-Change to the Deferral Method for Advance Payments (see instructions)
lf the applicant is requesting to change to the Deferral Method for advance payments described in section 5.02 of Rev. Proc.
2004-34,2004-1 C.B. 991 , attach the following information:
A statement explaining how the advance payments meet the definition in section 4.01 of Rev. Proc. 2004-34.
lf the applicant is filing under the automatic change procedures of Rev. Proc. 2OO8-52, the information required by section
8.02(3)(a)-(c) of Rev. Proc. 2004-34.
lf the applicant is filing under the advance consent provisions of Rev. Proc. 97-27 , lhe information required by section
8.03(2)(a)-(0 of Rev. Proc. 2OO4-U.
lf the applicant is requesting to change to the deferral method for advance payments described in Regulations section
1.451-s(bx1 Xii), attach the following,
A statement explaining how the advance payments meet the definition in Regulations section 1.451-5(a)(1).
A statement explaining what portions of the advance payments, if any, are attributable to services, whether such services are
integral to the provisions of goods or items, and whether any portions of the advance payments that are attributable to
non-integral services are less than five percent of the total contract prices. See Regulations sections 1.451-5(a)(2)(i) and (3).
A statement explaining that the advance payments will be included in income no later than when included in gross receipts for
purposes of the applicant's financial reports. See Regulations section 1 .451-5(b)(1 )(ii).
A statement explaining whether the inventoriable goods exception of Regulations section 1 .451-5(c) applies and if so, when
substantial advance payments will be received under the contracts, and how the exception will limit the deferral of income.
a
b
c
d
e
f
s
2
3
N/A
a
b
a
b
Schedule A-Change in Overall Method of Accounting (lf Schedule A applies, Part I below must be completed.) N/A
Form 3l I 5 (Rev. 12-2oos)
Form 3115 (Rcv. 12-2009) IDACORP, lNC. 89'0505802 Page 5
Schedule C-Changes Wthin the LIFO lnventory Method (see instructions)N/A
LIFO
Complete this section if the requested change involves changes within the LIFO inventory method. Also, attach a copy of all
Forms ozo, Application To Use LIFO lnventory Method. filed to adopt or expand the use of the LIFO method.
I Attach a description of the applicanfs present and proposed LIFO methods and submethods for each of the following
items:a Valuing inventory (e.9., unit method or dollar-value method).
b Pooling (e.g., by line or type or class of goods, natural business unit, multiple pools, raw material content, simplified dollar-
value method, inventory price index computation (lPlC) pools, vehicle.pool method, etc.).
c Pricing dollar-value pools (e.9., double-extension, index, link-chain, link-chain index, lPlC method, etc.).d Determining the current-year cost of goods in the ending inventory (i.e., most recent acquisitions, earliest acquisitions during
the cunent year, average cost of current-year acquisitions, or other permitted method).
2 ll any present method or submethod used by the applicant is not the same as indicated on Form(s) 970 filed to adopt or
expand the use ofthe method, attach an explanation.3 lf the proposed change is not requested for all the LiFO inventory, attach a statement speciffing the inventory to which the
change is and is not applicable.4 lf the proposed change is not requested for all of the LIFO pools, attach a statement specifying the LIFO pool(s) to which the
change is applicable.5 Attach a statement addressing whether the applicant values any of its LIFO inventory on a method other than cost. For
example, if the applicant values some of its LIFO inventory at retail and the remainder at cost, identify which inventory items
are valued under each method.
6lf method. attach a comoleted Form 970.
in Poolinq lnventories
I lf the applicant is proposing to change its pooling method or the number of pools, attach a description of the contents ol and
state the base year for, each dollar-value pool the applicant presently uses and proposes to use.2 lf the applicant is proposing to use natural business unit (NBU) pools or requesting to change the number of NBU pools,
attach the following information (to the extent not already provided) in sufficient detail to show that each proposed NBU was
determined under Regulations section 1.472-8(bX1\ and (2):
a A description ofthe types of products produced by the applicant. lf possible, attach a brochure.b A description of the types of processes and raw materials used to produce the products in each proposed pool.c lf all of the products to be induded in the proposed NBU pool(s) are not produced at one facility, state the reasons for the
separate facilities, the location of each facility, and a description of the products each facility produces.
d A description of the natural business divisions adopted by the taxpayer. State whether separate cost centers are maintained
and if separate profit and loss statements are prepared.e A statement addressing whether the applicant has inventories of items purchased and held for resale that are not further
processed by the applicant, including whether such items, if any, will be included in any proposed NBU pool.
f A statement addressing whether all items including raw materials, goods-in-process, and finished goods entering into the
entire inventory investment for each proposed NBU pool are presently valued under the LIFO method. Describe any items that
are not presenUy valued under the LIFO method that are to be included in each proposed pool.g A statement addressing whether, within the proposed NBU pool(s), there are items both sold to unrelated parties and
transfened to a different unit of the applicant to be used as a component part of another product prior to final processing.
3 lf the applicant is engaged in manufacturing and is proposing to use the multiple pooling method or raw material content
pools, attach information to show that each proposed pool will consist of a group of items that are substantially similar. See
Regulations section 1.47 2-8(b)(3).4 lf the applicant is engaged in the wholesaling or retailing of goods and is requesting to change the number of pools used,
attach information to show that each of the proposed pools is based on customary business classifications of the applicants
Form 3115 (Rev. 12-2009) IDACORP, lNC. 8H505E02 Pagc 6
Schedule D-Change in the Treatment of Long-Term Contracts Under Section 460, lnventories, or Other
Section 263A Assets (see instructions) NrA
I To the extent not already provided, attrach a desoiption of the applicants present and proposed methods for reporting income
and expenses from long-term contracts. Also, attach a representative actual contract (without any deletion) for the requested
change. lf the applicant is a construction contractor, attach a detailed description of its construction activities.
2a Are the applicants contracts long-term contracts as defined in section 460(0(1) (see instructions)? [Vesb lf 'Yes," do all the contracts qualiff for the exception under section 460(e) (see instructions)?. . [Ves
lf line 2b is "No," attach an explanation.c lf line 2b is'Yes," is the applicant requesting to use the percentage-of-completion method using cost-te'
cost under Regulations section 1.460*4(b)? . flVesd lf line 2c is "No," is the applicant requesting to use the exempt-contract percentage-of-completion
methodunderRegulationssectionl.46O4(c)(2)? . . .EV"s [Xo
lf line 2d is "Yes," atiach an explanation of what cost comparison the applicant will use to determine a
contracts completion factor.
lf line 2d is "No," attach an explanation of what method the applicant is using and the authorig for its use.
3a Does the applicant have long-term manufacturing contracts as defined in section 460(fX2)?. .[Vesb lf 'Yes," attach an explanation of the applicanfs present and proposed method(s) of accounting for long-
term manufacturing contracts.
c Attach a description of the applicant's manufacturing activities, including any required installation of manufactured goods.
4 To determine a contracfs completion factor using the percentage-of-completion method:
a \Mll the applicant use the cost-to-cost method in Regulations section 1.4604(b)? . lVes f] Xob lf line 4a is "No," is the applicant electing the simplified cost-to-cost method (see section 460(b)(3) and
Regulations section 1.a60-5(c))?. . lVes E t{o5 Attach a statement indicating whether any of the applicant's contracts are either cost-plus long-term
contracts or Federal long-term cpntracts.
I Attach a description ofthe inventory goods being changed.2 Att:ach a description of the inventory goods (if any) NOT being changed.3a ls the applicant subject to section 263A? lf 'No,' go to line 4a f]Ves E Xob ls the applicants present inventory valuation method in compliance with section 263A (see instructions)?
lf "No," attach a detailed explanation
4a Check the appropriate boxes below.
lnventory Not
Being Changed
ldentification methods:
Specific identification
FIFO.
LIFO.
Other (attach explanation)
Valuation methods:
Cost.
Cost or market, whichever is lower
Retail cost
Retail, Iower of cost or market
Other (attach explanation)
b Enter the value at the end of the tax year preceding the year of change5 lf the applicant is changing from the LIFO inventory method to a non-LIFO method, attach the following information (see
instructions).a Copies of Form(s) 970 filed to adopt or expand the use of the method.b Only for applicants requesting advance consent A statement describing whether the applicant is changing to the method
required by Regulations section 1.472-6(a) or (b), or whether the applicant is proposing a different method.c Only for applicants requesting an automatic change. The statement required by section 22.01(5) of the Appendix of Rev.
trtl No
No
Eto
E tto
Present method
Form 3115(Rev. 12-2009) IDACORP, lNC. 8$0505E02 pl14
to section 263A or long-term contracts as described in section 460 (see instructions)). N/A
Aftach a description (including sample computations) of the present and proposed method(s) the applicant uses to capitalize direct
and indirect costs properly allocable to real or tangible personal property produced and property acquired for resale, or to allocate
and, where appropriate, capitalize direct and indirect costs properly allocable to long-term contracts. lndude a description of the
method(s) used for allocating indirect costs to intermediate cost oblectives such as departments or activities prior to the allocation of
such costs to long-term contracts, real or tangible personal property produced, and property acquired for resale. The description
must include the following:I The method of allocating direct and indirect costs (i.e., specific identification, burden rate, standard cost, or other reasonable
allocation method).
2 The method of allocating mixed service costs (i.e., direct reallocation, stepallocation, simplified service cost using the labor-
based allocation ratio, simplified service cost using the production cost allocation ratio, or other reasonable allocation
method).
3 The method of capitalizing additional section 263,4 costs (i.e., simplified production with or without the historic absorption
ratio election, simplified resale with or without the historic absorption ratio election including permissible variations, the U.S.
ratio, or other reasonable allocation method).
Section B-Direct and lndirect Costs Required to be Allocated
Chec* the appropriate boxes showing the costs that are or will be fully included, to the extent required, in the cost of real or tangible
personal property produced or property acquired for resale under section 2634 or allocated to long-term contracts under section
460. Mark "N/A' in a box if those costs are not incurred by the applicant. lf a box is not checked, it is assumed that those costs are
for
Proposed method
1
2
3
1
5
6
7
E
9
l0
11
12
13
Direct material
Direct labor
lndirect labor
Officers' compensation (not including selling activities)
Pension and other related costs
Employee benefits
lndirect materials and supplies
Purchasing costs
Handling, processing, assembly, and repackaging costs
Offsite storage and warehousing costs
Depreciation, amortization, and cost recovery allowance for equipment and facilities
placed in service and not temporarily idle
Depletion
Rent14 Taxes other than state, local, and foreign income taxes
15 lnsurance
l6 Utilities17 Maintenance and repairs that relate to a production, resale, or long-term contract activityl8 Engineering and design costs (not including section 't74 research and experimental
expenses)
Rework labor, scrap, and spoilage
Tools and equipment
Quality control and inspection
Bidding expenses incuned in the solicitation of contracts awarded to the applicant . . . .
Licensing and franchise costs
Capitalizable service costs (including mixed service costs)
Administrative costs (not including any costs of selling or any retum on capital)
Research and experimental expenses attributable to long-term contracts
lnterest
19
20
21
22
23
21
25
26
27
2E Other costs a list of these
(Rev.12-2009)
1
2
3
1
5
6
7I
I
t0
Form 3l15 85-0505E02
Costs Not Required To Be Allocated Section C only if the applicant is requesting to change its
costs.
Proposed method
Marketing, selling, advertising, and distribution expenses
Research and experimental expenses not included in Section B, line 26
Bidding expenses not included in Section B, line 22
General and administrative costs not included in Section B
lncome taxes
Cost of strikes
Wananty and product liability costs
Section 179 costs
On-site storage
Depreciation, amortization, and cost recovery allowance not included in Section B,
line 1111 Other costs a list of
Schedule E-Change in Depreciation or Amortization (see instructions)N/A
Applicants requesting approval to change their method of accounting for depreciation or amortization complete this section.
Applicants z,usf provide this information for each item or class of property for which a change is requested.
Note: See the List of Automatic Accounting Method Changes in the instructions for information regarding automatic changes
under sections S6, 1 67, 1 68, 197, 14001, 1 400L, or former section 1 68. Do no t file Form 3l l S with respect to certain late elections
and election revocations (see instructions).
I ls depreciation for the property determined under Regulations section 1 .167(a)-1 1 (CLADR)?. . I Ves E No
lf 'Yes," the only changes permitted are under Regulations section 1 .167(a)-1 1 (c)(1 )(iii).
ls any of the depreciation or amortization required to be capitalized under any Code section (e.9., section263A)? .. f] ves tr No
lf "Yes," enter the applicable section >
Has a depreciation, amortization, or expense election been made for the property (e.9., the election under
sections 168(0(1), 179, or 179C)?
lf "Yes," state the election made )
To the extent not already provided, attach a statement describing the property being changed. lnclude in the description the
type of property, the year the property was placed in service, and the property's use in the applicants trade or business or
income-producin g activity.
2
3
4a
fl ves n No
ls the property public utility property? . ! Ves
fl ves trEb lf the property is residential rental property, did the applicant live in the property before renting it?
c ls the prooertv oublic utilitv orooerfu?
No
No
To the extent not already provided in the applicant's description of its present method, attach a statement explaining how the
propefi is treated under the applicants present method (e.9., depreciable property, inventory property, supplies under
Regulations section 1.162-3, nondepreciable section 263(a) property, property deductible as a current expenses, etc.).
lf the property is not currently treated as depreciable or amortizable property, attach a statement of the facts supporting the
proposed change to depreciate or amortize the property.
7 lf the property is currently treated and/or will be treated as depreciable or amortizable property, provide the following
information for both the present (if applicable) and proposed methods:
a The Code section under which the property is or will be depreciated or amortized (e.9., section 168(g)).b The applicable asset class from Rev. Proc. 87-56, 1987-2 C.B. 674, for each asset depreciated under section 168 (MACRS) or
undersection 1400L; theapplicable assetclassfrom Rev. Proc.83-35, 1983-1 C.B.745,for each assetdepreciated under
former section 168 (ACRS); an explanation why no asset class is identified for each asset for which an asset class has not
been identified by the applicant.c The facts to support the asset class for the proposed method.d The depreciation or amortization method of the property, including the applicable Code section (e.9., 200olo declining balance
method under section 168(bX1)).
e The useful life, recovery period, or amortization period of the property.f The applicable convention of the property.g A statement of whether or not the additional first-year special depreciation allowance (for example, as provided by section
168(k), 168(l), 168(m), 168(n), 1400L(b), or 1400N(d)) was or will be claimed for the property. lf not, also provide an explanation
"r ,o *n, no .0"",r' 0"0r"","*,on ",'o*rn* *"" or *',, O" ",r'r"0. F;;; !i iE E:;: ;;,;il;;
IDACORP,INC.
Attachment to Form 3l l5
EIN: t5-0505802
FYE: 12131/2014
Transition Rule Filins Under Section 15.02(1XaXiil of Rev. Proc. 2015-13
Applicant is filing this method change under Rev. Proc.20l l-14 pursuant to the transition rules set forth in
Section 15.02(lXaXii) of Rev. Proc.20l5-13, as moditied by Rev. Proc.20l5-33.
Pert I, Line2
PursuanttoAppendix$ l0.ll(2)ofRev.Proc.20ll-14(asaddedbysection3.02ofRev.Proc.20l4-16),
the scope limitations in section 4.02 of Rev. Proc.20l l-14 do not apply to ataxpayerthat makes this change
in method of accounting under Appendix section 10.11 of Rev. Proc. 20ll-14 for any taxable year
beginning before January 1,2015.
Part II, Line 6
Parent:
EIN:
Address:
Under Exam:
IDACORP,Inc.
85-0505802
PO Box 70
Boise, Idaho 83707
2014 CAP Program
Part II, Line 9b & lOb
The Applicant is concurrently changing its method of accounting for treatment of generation property
expenditures to use all or some of the unit of property definitions and the corresponding major component
definitions described in Rev. Proc.2013-24 under the automatic method change in Rev. Proc. 2015-14 for
the taxable year ending December 31,2014.
The Applicant is concurrently changing its method of account for the certain dispositions of certain electric
generation tangible assets as provided in Treas. Reg. $ 1.168(i)-8(d)(l) under the automatic consent
procedures of Rev. Proc. 2011-14 for the taxable year ending December 31,2014.
The Applicant is concurrently changing its method of for deducting employee incentive compensation
expense under the automatic method change in Rev. Proc. 2015-14 for the taxable year ending December
31,2014.
The Applicant is concurrently changing its method of accounting for amount paid for repairs, maintenance
and improvements to comply with Treas. ReS. $$ 1.162-4 and 1.263(a)-3, including a change in identifying
the unit of property under Treas. Reg. $ 1.263(a)-3(e) for purposes of applying the improvement standards
under Treas.Reg. $ 1.263(a)-3 and its method for incidental and non-incidental materials and supplies
under Treas. Reg g 1.162-3 under the automatic method change in Rev. Proc.20l l-14 for the taxable year
ended December 31, 2014.
Idaho Power Company made a late general asset account ("GAA") election under I.R.C. $ 168(iXa) and
Treas. Reg. $$ 1.168(i)-l and 1.168(i)-1T and made a late election to recognize gain or loss on the
disposition of assets that are the subject of the late GAA election in accordance with Treas. Reg. $ l. 168(i)-
lT(e)(3Xii) under the automatic consent procedures of Rev. Proc. 20ll-14 for the taxable year ending
December 31,2013.
Page I
IDACORP,INC.
Attachment to Form 3l15
EIN: t5-0505802
FYEz l2l3ll20l4
Idaho Power Company changed its method of accounting for transmission and distribution property safe
harbor method for repair expenditures per Section 5 of Rev. Proc. 201 l-43 for the taxable year ended
December 31, 201 l.
Part II, Line 12 - Disposition of Tangible Depreciable Assets (Other than a Building or its Structural
Components); Information Required by $ 6.39(5)(a) of Rev. Proc.2015-14
a. The Applicant is changing its method of accounting that is specified in Section 6.39(3) of Rev.
Proc.2015-14 for disposing of I.R.C. $ 1245 property or a depreciable land improvement or
disposing of a portion of I.R.C. $ 1245 properly or a depreciable land improvement to which the
partial disposition rule in Treas. Reg. $ 1.168(i)-8(d)(l) applies. This change also affects the
determination of gain or loss from disposing of the I.R.C. $ 1245 property, the depreciable land
improvement, or a portion of the I.R.C. $ 1245 property or depreciable land improvement, and may
affect whether the taxpayer must capitalize amounts paid to restore a unite of property (as
determined under Treas. Reg. $$ 1.263(a)-3(e) or (f)) under g 1.263(a)-3(k).
b. Under its present method of accounting, the Applicant determines whether plant property has been
disposed of consistent with its method of accounting for financial statement purposes. Consistent
with its method of accounting financial statement purposes, the Applicant treated the partial
dispositions of plant properfy that are the subject of this requests as dispositions of entire assets
under its present method of accounting.
c. Under the proposed method of accounting, the Applicant is concurrently changing its method of
accounting for treatment of generation property expenditures to use the unit of property definitions
and the corresponding major component definitions described in Rev. Proc.2013-24 Appendix A
Sections 2,3, and 4 under the automatic method change in Rev. Proc. 2015-14 for the taxable year
ending December 3l,2}l4.t Under its proposed method of accounting, the Applicant will treat
those units of property or major components as the assets for dispositions of plant property under
Treas. Reg. S 1.168(i)-8(cXaXi).
The Applicant is concurrently making a late partial disposition election under Treas. Reg.
$ 1.168(i)-8(dx2xi) for the plant property that are the subject of this request. The Applicant will
recognize loss in the amount of the adjusted depreciable basis of the plant property at the time of
the partial dispositions (taking into account the applicable convention) under Treas. Reg. $ I . I 68(i)-
8(eX2), and will determine the adjusted depreciable basis at the time of partial dispositions under
Treas. Reg. $ 1.168(i)-8(fX3). The Applicant will stop depreciating the plant property at the time
of partial dispositions (taking into account the applicable convention) under Treas. Reg. $ 1.168(i)-
8(hxl). The Applicant will continue to depreciate the portions of the assets not disposed under
Treas. Reg. $ 1.168(i)-8(dx2xi) using the applicable method, recovery period, and convention
underl.R.C. $ 168.
d. The Applicant's overall method of accounting is an accrual method.
Part II, Line 13
The Applicant is a regulated electric utility engaged in the production, transmission, distribution, and sale
of electric energy throughout Idaho and Eastern Oregon. The principal business activity code is 221100.
1 Refer to the Form 3115 filed by the Applicant
Part II, Line 14
The Applicant will not use the proposed method of accounting in its books and records or its financial
statements because the proposed method does not conform to generally accepted accounting principles
(GAAP).
Part fV, Line 25 - Disposition of Tangible Depreciable Assets (Other than a Building or its Structural
Components)
There is no difference between the current and proposed methods that would result in an I.R.C. $ a8l (a)
adjustment.
Statement Required Under Section 639(a)(a)(v) of Rev. Proc.201a.l4
The Applicant agrees to the following additional terms and conditions:
(A) A normalization method of accounting (within the meaning of I.R.C. $ 168(iX9)) will be used
for the public utility property subject to the Form 3 I I 5;
(B) As of the beginning of the year of change, the taxpayer will adjust its deferred tax reserve
account or similar account in the taxpayer's regulatory books of account by the amount of the
deferral of federal income tax liability associated with the I.R.C. $ a8 I (a) adjustment applicable
to the public utility property subject to this application; and
(C) Within 30 calendar days of filing the federal income tax retum for the year of change, the
taxpayer will provide a copy of the completed Form 3l15 to any regulatory body having
jurisdiction over the public utility property subject to this application.
Request for Facsimile Transmission Pursuant to Section 9.04(3) of Rev. Proc. 2015-1
In accordance with the procedures set forth in section 9.04(3) of Rev. Proc. 20 l5- I , the Applicant requests
that a copy ofany document related to this request be provided to the Applicant's authorized representatives
via fax at the numbers below:
IDACORP,INC.
Attachment to Form 3l15
Applicant's Representatives
Jane Rohrs
Bryan Pleskac
Fax Number
(877) s0t-2s99
(402') 599-6002
EIN: 85-0505802
FYE: l2l3ll20l4
Page 3
<EHm*
An TDACORP Company
LISA D. NORDSTROM
Lead Counsel
I nordstrom@idahopower. com
September 23,2015
Public Utility Commission of Oregon
Filing Center
550 Capitol Street NE, Suite 215
P.O. Box 2148
Salem, OR 97308-2148
RE: ldaho Power Company
lnternal Revenue Service Form 3115, Application for Change in Accounting Method
Attention Filing Center:
On September 11 ,2015,IDACORP, lnc., on behalf of its subsidiary ldaho Power Company
("ldaho Powe/'), filed Form3115, Application for Change in Accounting Method, with the lnternal
Revenue Service ('lRS") along with its federal income tax return for 2014. Pursuant to lRS Rev.
Proc. 2011-14, as modified by Rev. Proc. 2012-20, ldaho Power is providing a copy of two Form
3115s to the Public Utility Commission of Oregon ("Commission") within 30 days of its submittal to
the lRS.
The purpose of the first Form 3115 is for ldaho Power to make a late partial disposition
election. Specifically, this Form 3115 is related to certain dispositions of portions of electrical
generation assets placed in service after December 31, 1986, and prior to January 1, 2014.
The purpose of the second Form 3115 is for ldaho Power to notify the IRS of a change in
treatment of dispositions. Specifically, this Form 3115 is related to the gain or loss calculated upon
the disposition or partialdisposition of IRC S1245 property or depreciable land improvements.
The filing of this election has no impact to the financial statements of IDACORP, lnc. or
ldaho Power. The submission is protective in nature and is unrelated to any change in accounting
for Generally Accepted Accounting Principles purposes. Similarly, there are no ratemaking
implications as a result of the change. Accordingly, as this filing is for informational purposes only,
no action is required of the Commission nor is action being requested by ldaho Power.
Please find ldaho Power's Form 31 15s attached. Thank you for your attention to this matter.
lf you have any questions, please contact Courtney Waites, Senior Regulatory Analyst, at (208)
388-561 2.
Very truly yours,
X* !-("1*t.-*,
LDN/KKI
Enclosures
cc Mencl:Gene Marchioro
Marc Hellman
Lisa D. Nordstrom