20180514Idaho Power Comments.pdf

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LISA D. NORDSTROM
Lead Counsel
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May 14,2018
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. GNR-U-18-01 - lmpact of FederalTax Code Revisions
on Utility Costs and Ratemaking
ldaho Power's Comments in Support of Settlement Stipulation
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and seven (7) copies of ldaho
Power Company's Comments in support of the Settlement Stipulation filed in this matter on April
12,2019.
Sincerely,
Lisa D. Nordstrom
LDN.KKt
Enclosures
P.O. Box 70 (83707)
'1221 W. ldaho St.
Boise, lD 83702
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I no rdstrom @ id ah opowe r. com
IN THE MATTER OF THE
INVEST]GATION INTO THE IMPACT OF
FEDERAL TAX CODE REVISIONS ON
UTILIry COSTS AND RATEMAKING
RIC =
IV ED
?fri0liiqY ilt PH 2: I I
-!rA.. ir.,: ,_. ,._;i{glgiri, :l . i,,-,rt,rr'(L
Attorney for ldaho Power Company
BEFORE THE !DAHO PUBLIC UTILITIES COMMISSION
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CASE NO. GNR-U-18-01
IDAHO POWER COMPANY'S
COMMENTS IN SUPPORT OF
SETTLEMENT STI PU LATION
ldaho Power Company ("ldaho Power" or "Company"), by and through its
undersigned attorney, hereby submits to the ldaho Public Utilities Commission
("Commission") these comments in the above-captioned proceeding. The Company's
comments are organized as follows:
Section I - provides the procedural background and summarizes the Company's
filing in this case pursuant to Order No. 33965;
Section ll - details the agreed upon terms of the Settlement Stipulation
("Stipulation") reached by all parties; and
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION . 1
Section lll - summarizes why the proposed Stipulation is in the public interest and
should be approved.
I. BACKGROUND
On December22,2017, the U.S. Tax Cuts and Jobs Act ("2017 Tax Act") was
signed into law. See Pub. L. No. 115-97,131 Stat 2045. Effective January 1,2018, the
2017 Tax Act lowers the corporate tax rate to 21 percent from the existing maximum rate
of 35 percent, provides for expanded bonus depreciation, limits the deductibility of interest
expense, eliminates alternative minimum tax, repeals the manufacturing deduction, and
imposes additional limitations on the deductibility of executive compensation.
Public utility companies, such as ldaho Power, retain the fulldeductibility of interest
expense but are no longer eligible for the bonus depreciation provisions; however,
traditional accelerated tax depreciation methods are still available. While the change in
the corporate income tax rate will reduce the Company's income tax expense beginning
in 2018, Generally Accepted Accounting Principles required ldaho Power to remeasure
deferred income tax assets and liabilities as of the date of the enactment, significantly
reducing net deferred tax liabilities, as well as causing an increase in income tax expense
for 2017.
On January 17, 2018, the Commission issued a Notice of lnvestigation in Order
No. 33965 directing all rate-regulated utilities (besides small water companies with less
than 200 customers, and the small electric utility, Atlanta Power) to: (1) immediately
account for the financial benefits from the January 1, 2018, tax rate reduction to 21
percent as a deferred regulatory liability, and (2) by Friday, March 30,2018, file a report
with the Commission identifying and quantifying all tax changes individually.
Order No. 33965 specified that each report must disclose the federal income tax
components for the year 2017, and the federal income tax components if the utility had
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 2
been subject to the 2017 Tax Act's revisions to the tax code, including lhe 21 percent tax
rate. Each utility's report must include proposed tariff schedules that show the revenue
requirement impacts from the 2017 Tax Act, with the differences between the law in effect
on December 31 ,2017, and the law in effect on and after January 1,2018. ld. Utilities
that operate in ldaho and in other states must separately calculate system-wide and
ldaho-specific figures to show how the 2017 Tax Act impacts total operations and ldaho
operations. /d.
On February 22,2018, the Commission also issued a Notice of Deadline for: (1)
Persons to lntervene, and (2) Utility-Parties to Request Settlement Notification. Order
No. 33991. The lndustrial Customers of ldaho Power ('lClP") was the only party to file a
petition to intervene in ldaho Power's proceeding and the Commission granted rts
intervention in Order No. 33994.
As required by Order No. 33965, ldaho Power identified and quantified its federal
income tax components that changed because of the 2017 Tax Act, as well as changes
that result from the 2018 ldaho state tax rate change (federal and state changes
collectively referred to as "Tax Reform"), in a report filed in this docket on March 30, 2018.
ldaho Power's 2017 proforma analysis, on a total system and jurisdictional basis, is
summarized as follows:
Tax Reform ct-2017 Proforma Anal
Note: The "Other'' category reflects tax benefits apportioned to the Company's other retailand wholesale
jurisdictions.
The Company, Commission Staff ("Staff'), and lClP (collectively, the "Parties") met
on March 19,26, and 29, 2018, for settlement discussions regarding rate issues related
System ldaho Other
Current Tax lmpact (Cash)($15,416,760)($1 1 ,178,487)($4,238,273)
($15,690,25e)($14,918,298)($771 ,e61)Deferred Tax lmpact (Non-Cash)
($31,107,019)($26,096,785)($5,010,234)Total Tax Reform Impact
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 3
to the inclusion of revenue requirement changes stemming from Tax Reform in ldaho
Power's rates. Based upon these settlement discussions, and as a compromise of the
respective positions of the Parties, the Parties came to an agreement and a settlement
stipulation was prepared and signed by the Parties.
ldaho Power filed the agreed upon Stipulation and corresponding Motion to
Approve on April 12,2018. The Stipulation was entered into by ldaho Power, Staff, and
ICIP.
On April 23,2018, the Commission issued Order No. 34039 setting a comment
deadline of May 14,2018, and a reply comment deadline of May 21,2018.
II. SETTLEMENT STIPULATION
The Parties agree that a total annual ldaho jurisdictional benefit of $26,497,560
associated with Tax Reform, which is a combination of current tax expense and a portion
of deferred tax reductions, will be provided to customers through a direct rate reduction
beginning June 1,2018. The direct rate reduction will be provided to customers via two
rate components on June 1 ,2018: $18,678,936 will be provided as a base rate reduction
and $7,818,624 will be provided through the Earnings Sharingl component of the Power
Cost Adjustment ('PCA') mechanism. Assuming no out-of-cycle adjustment by the
Federal Energy Regulatory Commission ("FERC"), beginning June 1, 2019, the Parties
agree this credit to the PCA will be reduced to $2,680,957 to reflect: (1) the removal of
the one-time credit associated with the January - May 2018 tax savings deferral, and (2)
the impact of three months of reduced third-party transmission revenues that occurs
1 Pursuant to Order Nos. 30978, 32424, and 33149, ldaho Power credits customer bills through
the Earnings Sharing component of the PCA for any revenues shared pursuant to these orders.
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 4
beginning October 1, 2019. Beginning June 1, 2020,this credit to the PCA will be reduced
to zero to reflect the impact of a full year of reduced third-party transmission revenues.
ln addition, Tax Reform resulted in changes to deferred tax expense. The Parties
agree ldaho Power will provide a non-cash customer benefit resulting from deferred tax
reductions of $7,417,848 as an offset to regulatory assets, or amounts customers owe,
annually beginning on June 1, 2018, until the Company's next general rate case
proceeding or until otherwise modified by the Commission. ldaho Power will provide the
non-cash customer benefit in the following order: (1) first, to offset in its entirety, the
regulatory asset account established pursuant to Order No. 33706, that includes
incremental operations and maintenance expenses associated with participation in the
Energy lmbalance Market, (2) second, $2,771,815 in ldaho jurisdictional Baker County
settlement agreement expenses incurred through December 31,2015, and deferred to a
regulatory asset established pursuant to Order No. 34031, and (3) finally, the remaining
non-cash customer benefits will be provided as an offset to non-specific current or future
deferrals deemed prudent and approved for recovery from customers by the Commission.
The Settlement Stipulation also provides for an indefinite extension of the existing
Accumulated Deferred Income Tax Credit ('AD|TC") / Revenue Sharing mechanism
beyond the current termination date of December 31, 2019, with certain modified terms to
become effective January 1,2020. As detailed in the Stipulation, these modified terms
include increases to the customer portion of the sharing percentages in the event that
revenue sharing is achieved, as well as lowering the return on equity ("ROE') floor up to
which ldaho Power may support earnings with accelerated ADITC amortization from the
current 9.5 percent to 9.4 percent. The Parties agree that once the Company has fully
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 5
amortized the $45 million of ADITC, revenue sharing will cease: however, ldaho Power may
at any time request to replenish the total amount of ADITC it is permitted to amortize, and if
approved by the Commission, revenue sharing would continue. The Stipulation also
eliminates any specified termination date for the mechanism. Except as otherwise provided
for in the Stipulation or ordered by the Commission, in no event shall any additional
amounts of amortized ADITC be reflected in the utility operating results of the Company
for ratemaking purposes, regulatory financial statement purposes, and for purposes of
the Company's regulated books of account.
III. SETTLEMENT IS FAIR. JUST. AND REASONABLE
AND IN THE PUBLIC INTEREST
ldaho Power supports the Stipulation in this case because it (1) provides for a
reasonable resolution for the revenue requirement reduction associated with Tax Reform,
representing a fair and balanced outcome for both customers and shareowners, (2) offers
customers the timely recognition of Tax Reform benefits by incorporating the revenue
requirement changes into rates effective June 1,2018, (3) achieves a result that limits the
potential negative financial impact on the Company, and (4) extends indefinitely the ADITC
/ Revenue Sharing mechanism that will continue to serve as a benefit to both ldaho Power
and its customers.
A. Fair and Balanced Provision of Benefits to Customers.
As discussed above, the Stipulation in this case was developed through multiple
discussions with Staff and lClP, using the 2017 proforma analysis as the basis for the
quantification of benefits. Through these discussions, Parties developed the Stipulation that
results in the provision of income tax benefits to customers in a manner that reasonably
reflects the actual changes to the Company's revenue requirement resulting from Tax
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 6
Reform. Therefore, the proposed rate impact resulting from this Stipulation is fair and
balanced from the perspectives of both ldaho Power and its customers, providing a
reasonable level of income tax benefits to customers in a timely manner while limiting the
potential negative financial impact to the Company. ln addition, the detennination of the $26
million direct rate reduction and the $7 million deferral offset aligns with the Commission's
directive in Order No. 33965 by quantifying and providing benefits to customers based on
the Company's 2017 proforma analysis. While the specific provisions of the Stipulation do
not exactly align with expected actual cash and non-cash impacts of the Tax Reform, the
Company believes that the Stipulation as a whole represents a reasonable compromise that
appropriately balances the interests of ldaho Power and its customers.
B. Timely Recoqnition of Benefits.
lf approved, the Stipulation will result in the timely recognition of benefits in customer
rates beginning June 1 ,2018. The Stipulation allows for the provision of direct benefits to
customers as soon as administratively feasible following the enactment of the2017 Tax Act
and subsequent action by the Commission. The Stipulation not only provides for the
ongoing recognition of income tax benefits through customer rates beginning June 1,2018,
but also recognizes benefits of Tax Reform that occurred in the first five months of 2018.
Additionally, direct benefits included in the Stipulation incorporate approximately $3.5 million
in benefits associated with reduced FERC-jurisdictional income tax expense that will
ultimately be reflected in the Company's Open Access Transmission Tariff ("OATT")
transmission formula rate, allowing ldaho retailcustomers to benefit from timing differences
between the enactment of Tax Reform and the corresponding impact to the Company's
OATT transmission formula rates. In its entirety, the Stipulation results in the reasonable
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 7
and timely recognition of income tax benefits in customer rates as soon as administratively
feasible.
C. Limited'Neqative lmpact to ldaho Power.
ln addition to providing income tax benefits to customers in afair and timely manner,
the terms of the Stipulation also reasonably limit the potential for negative financial impacts
to ldaho Power stemming from credit rating concerns or the need to issue additional debt or
equity to provide benefits to customers. Due to Idaho Power's use of flow-through income
tax accounting which has historically reduced income tax expense and contributed to lower
rates for customers, Tax Reform did not reduce ldaho Power's income tax expense as
significantly as the income tax expense of some peers in the utility industry who use fully
normalized income tax accounting, resulting in affirmation of ldaho Power's stable outlook
from the rating agency, as can be seen in the Moody's lnvestors Service press release dated
February 5, 2018, and included as Attachment 1. Although the stipulated direct rate
reductions exceed the actual cash benefits the Company expects to realize, ldaho Power
believes the compromise reflected in the Stipulation reasonably limits the potential for
negative financial impacts to the Company, and should not result in a material negative
impact to the Company's credit metrics or overall credit rating. In addition to avoiding
negative credit rating impacts, the level of cash benefits provided to customers will not result
in the need for ldaho Powerto issue any additional long-term debt orequityto accommodate
the direct reduction in retail revenue. Lastly, additional provisions of the Stipulation, such
as the extension of the ADITC / Revenue Sharing mechanism and the ability to modify the
temporary OATT-related benefit in the event of an out-of-cycle FERC action, appropriately
provide benefits to customers while limiting the potential for negative financial impacts to
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 8
ldaho Power due to differences between the stipulated rate reductions and actual financial
results.
D. Lonq-Term Benefits throuqh Extension of ADITC / Revenue Sharing.
Absent the action taken by the Commission and the resulting Stipulation in this case,
the Company's current ADITC / Revenue Sharing mechanism would have flowed through
to customers the benefits of Tax Reform in the form of revenue sharing (in the event the
Company's ROE exceeded 10 percent) or the preservation of ADITC (in the event the
Company's ROE fell below 9.5 percent). ln recognition that the agreement detailed in the
Stipulation modifies the manner through which customers receive benefits associated with
changes in net income, the Stipulation contains a provision that extends the current ADITC
/ Revenue Sharing mechanism with certain modifications as detailed above.
As discussed in the Company's 2018 PCA filing, from 2011 through 2015 the ADITC
/ Revenue Sharing mechanism resulted in revenue sharing with customers totaling $121.2
million, either as a direct offset in the PCA or as an offset to amounts that would have
otherwise been collected in rates. ln the future, the enhanced sharing percentages detailed
in the Stipulation effective January 1 ,2020, will serve to increase the potential for customers
to realize direct benefits resulting from revenue sharing.
ln addition to the direct financial benefits provided to customers, the ADITC /
Revenue Sharing mechanism also provides ldaho Power with the ability to support its
earnings if its year-end ldaho jurisdictional ROE falls below a certain level, currently set at
9.5 percent under the existing mechanism. As discussed above, effective January 1,2020,
the ROE floor incorporated into the mechanism will decrease to 9.4 percent, unless the
Company's ROE is otherwise modified by Commission order. This reduction in the ROE
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 9
floor will continue to provide ldaho Power earnings stability by mitigating downside risk, while
the reduced amount will serve to preserve ADITCs available over time to facilitate the long-
term viability of the mechanism. The Company believes the use of 9.4 percent until its next
general rate case reflects an appropriate compromise within the context of the broader
Stipulation.
Since its inception, the ADITC / Revenue Sharing mechanism has allowed for direct
customer benefits through revenue sharing, in addition to rate stability resulting from the
ability of ldaho Powerto support its earnings through the accelerated amortization of ADITC.
By eliminating the termination date for the existing mechanism and modifying the terms as
discussed in the Stipulation, both ldaho Power and its customers will continue to receive the
benefits of this mechanism beyond the existing December 31, 2019, termination date.
tv. coNcLUSloN
ldaho Power believes the terms agreed to in the Stipulation represent a compromise
of the respective positions of the Parties, balancing the interest of customers and ldaho
Power by providing a customer benefit of $33.9 million for the June 1 , 2018, through May
31,2019, time period. Although the timing of the stipulated amount does not align perfectly
with the expected cash and non-cash savings resulting from Tax Reform, the Stipulation will
result in the timely provision of benefits to customers while limiting the potentially negative
financial impact to ldaho Power. Further, the Stipulation also acknowledges ldaho Power's
deviation from the provisions of the currentADlTC / Revenue Sharing mechanism thatwould
normally flow decreases in income tax expense to customers by extending that mechanism
beyond the current termination date.
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION. 1O
For all of the reasons presented in these comments, ldaho Power urges the
Commission to adopt the Stipulation submitted in this proceeding as filed, without
modification, and to issue an order authorizing the terms of the Stipulation. The Company
respectfully requests that the Commission issue an order on or before June 1 , 2018,
authorizing the terms of the Stipulation.
DATED at Boise, ldaho, this 14th day of May 2018.
LISA D
Attorney for
IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 11
Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of May 2018 I served a true and correct
copy of the IDAHO POWER COMPANY'S COMMENTS lN SUPPORT OF SETTLEMENT
STIPULATION upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Karl T. Klein
Deputy Attorneys General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customerc of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hil! Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S COMMENTS IN SUPPORT OF SETTLEMENT STIPULATION - 12
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR.U.I 8.01
IDAHO POWER COMPANY
ATTACHMENT 1
Moopv's
INVESTORS SERVICE
Rating Action: Moody's affirms ldaho Power at A3 and IDACORP at Baal;
outlooks stable
Global Credit Research - 05 Feb 2018
New York, February 05, 20'18 - Moody's lnvestors Service, ("Moody's") today affirmed the ratings of ldaho
Power Company (lPC), including its A3 lssuer rating, A1 senior secured rating, its P-2 short term rating for
commercial paper and its VMIG 2 industrial revenue bond rating. Moody's affirmed the ratings of its parent
company, IDACORP's (lDA) Baal lssuer rating and its P-2 short term rating for commercial paper. The
outlooks of IPC and IDA are stable. IDA's credit profile is based primarily on its principal subsidiary, lPC, with
one notch of structural subordination applied. IDA has no standalone long-term debt, but is an occasional
issuer of commercial paper.
RATINGS RATIONALE
"Nearly loooh of IDACORP's revenue, assets and cash flow are derived from utility operations at ldaho Power.
The low business risk profile, financial performance and credit profile of IDACORP's primary subsidiary are the
most important factors supporting IDACORP's rating" said Robert Petrosino, Vice PresidenUSenior Analyst.
IDA's other operating subsidiaries are relatively small and include: IDACORP Financial Services, an investor in
affordable housing projects and other real estate investments; and lda-West Energy, an operator of nine small
hydro-electric generation projects that satisfy the requirements of the Public Utility Regulatory Policies Act of
1978.
IPC enjoys a constructive regulatory environment and a unique asset base that largely mitigate the utility's
weaker relative cash flow metrics, including CFO pre-WC to debt consistently in the mid-to-high teens. This
compares poorly to A3-rated vertically integrated peers, which typically produce between 2Oo/o and 25o/o CFO
pre-WC to debt. IPC does not fully benefit from tax deferrals as they are flowed back to customers in rates, and
has a longer depreciable asset life given its hydro generation centric asset base, both of which contribute to
the relative weakness in CFO metrics.
Nevertheless, given the predictability of IPC's financial profile and the above average regulatory support in
ldaho, we see a high degree of credit stability. IPC's financial and regulatory consistency support the A3 rating,
compared to peers that have a higher degree of risk in regulatory decisions or increased financial volatility.
The cooperative regulatory environment that the IPUC maintains helps to lower IPC's business risk, as the
suite of cost recovery provisions allowed is above average compared to the other states across the US. These
mechanisms provide certainty to cash flow generation in any given year, with variances typically due to hydro
or weather conditions that average out over time.
ln addition to the commodity and conservation trackers, and decoupling, IPC is currently operating under a
settlement stipulation through 2019. The settlement is a significant credit positive, since it allows IPC to
amortize additional accumulated deferred investment tax credits (ADITC) in an aggregate amount up to $45
million should its return on equity (ROE) fall below 9.5% in its ldaho jurisdiction. This essentially provides an
earnings floor level for lPC. Assuming the $45 million availability is not exhausted, this enhances the
predictability of IPC's earnings and cash flow for the three year term of the settlement. However, IPC has not
needed to use ADITC amortization to meet its 9.5% ROE since the settlement was enacted.
ln May 2017,lPC received approval to accelerate rate base recovery related to its ownership interests in the
North Valmy coal plant. IPC expects to end participation in the North Valmy plant by 2025.
ln December 2017,lPC filed with its ldaho regulators for approval of a stipulation of settlement related to the
expenses incurred in the re-licensing process of its Hells Canyon Hydro-electric Complex (HCC). The company
is seeking a prudence determination on $216.5 million to be included in customer rates in the future. HCC has
1,167 MWs of generation capacity, representing 34o/o of IPC's total capacity. The company has been collecting
$6.5 million annually in AFUDC related to HCC's relicensing. When a relicensed HCC is moved into rate base,
IPC's hydro generation will represent a value of approximately $600/kw. IPC expects a new 40 to 50 year
license no earlier lhan 2021.
IPC is experiencinq qood qrowth across customer classes driven bv its nation leadinq population qrowth in
ldaho as well as Ui ittracting new business and existing business expansion. The stite and its citles are
experiencing population groMh as existing companies expand operations and new companies open their
doors in IPC's service territory.
IPC's generation resources are sufficient to meet the company growing load profile. IPC's 2017 lntegrated
Resource Plan does not call for any additional generation resources over the near to intermediate term with no
resource needs prior lo 2026. Longer term planning needs are largely expected to be met by the mid-2020s
expected in-service date of its Boardman to Hemingway (B2H) transmission line, currently in development with
minor permitting approvals remaining.
We expect a gradual absolute and relative improvement in IPC's financial profile. A consistent capital plan
which averages $300 million annually over the next few years has largely been funded with cash flow. IDA has
achieved steady dividend growth and its payout is commensurate with the industry and peers.
Rating Outlook
IDA s stable outlook is substantially driven by the outlook of lPC. IPC's stable rating outlook reflects a very
supportive regulatory environment that offers timely cost recovery and constructive rate making policies,
providing very consistent and predictable cash flow.
Factors that Could Lead to an Upgrade
IDA's rating would likely be upgraded with the upgrade of lPC. The rating of IPC could be upgraded if key
credit metrics improve such that cash flow from operations pre-working capital (CFO pre-WC) to debt
approaches mid 2oo/o percent on a sustained basis.
Factors that Could Lead to a Downgrade
IDA's rating would likely be downgraded with the downgrade of lPC. IPC could be downgraded if financial
metrics were to weaken, such that CFO pre-WC to debt persists below the high teens. Additionally, IPC's rating
could be downgraded if the company were to experience a decline in the level of regulatory support for its
operating or capital expenditures.
Outlook Actions:
..lssuer: IDACORP, lnc.
....Outlook, Remains Stable
..lssuer: ldaho Power Company
....Outlook, Remains Stable
Affirmations:
..lssuer: American Falls Reservoir District, lD
....Senior Unsecured Revenue Bonds, Affirmed A3
....Senior Unsecured Revenue Bonds, Affirmed VMIG 2
..lssuer: Humboldt (County of) NV
....Senior Secured Revenue Bonds, Affirmed A1
..lssuer: IDACORP, lnc.
.... lssuer Rating, Affirmed Baal
....Senior Unsecured Commercial Paper, Affirmed P-2
..lssuer: ldaho Power Company
.... Commercial Paper, Affirmed P-2
.... lssuer Rating, Affirmed A3
....Senior Secured First Mortgage Bonds, Affirmed 41
....Senior Secured Regular Bond/Debenture, Affirmed A1
....Underlying Senior Secured Regular Bond/Debenture, Affirmed 41
..lssuer: Morrow (Port of) OR
....Senior Unsecured Revenue Bonds, Affirmed A3
....Senior Unsecured Revenue Bonds, Affirmed VMIG 2
..lssuer: Sweetwater (County of) WY
....Senior Secured Revenue Bonds, Affirmed 41
The principal methodology used in these ratings was Regulated Electric and Gas Utilities published in June
2017. Please see the Rating Methodologies page on www.moodys.com for a copy of this methodology.
REGULATORY DISCLOSURES
For ratings issued on a program, series or category/class of debt, this announcement provides certain
regulatory disclosures in relation to each rating of a subsequently issued bond or note of the same series or
category/class of debt or pursuant to a program for which the ratings are derived exclusively from existing
ratings in accordance with Moody's rating practices. For ratings issued on a support provider, this
announcement provides certain regulatory disclosures in relation to the credit rating action on the support
provider and in relation to each particular credit rating action for securities that derive their credit ratings from
the support provider's credit rating. For provisional ratings, this announcement provides certain regulatory
disclosures in relation to the provisional rating assigned, and in relation to a definitive rating that may be
assigned subsequent to the final issuance of the debt, in each case where the transaction structure and terms
have not changed prior to the assignment of the definitive rating in a manner that would have affected the
rating. For further information please see the ratings tab on the issuer/entity page for the respective issuer on
www.moodys.com.
For any affected securities or rated entities receiving direct credit support from the primary entity(ies) of this
credit rating action, and whose ratings may change as a result of this credit rating action, the associated
regulatory disclosures will be those of the guarantor entity. Exceptions to this approach exist for the following
disclosures, if applicable to jurisdiction: Ancillary Services, Disclosure to rated entity, Disclosure from rated
entity.
Regulatory disclosures contained in this press release apply to the credit rating and, if applicable, the related
rating outlook or rating review.
Please see www.moodys.com for any updates on changes to the lead rating analyst and to the tr/oody's legal
entity that has issued the rating.
Please see the ratings tab on the issuer/entity page on www.moodys.com for additional regulatory disclosures
for each credit rating.
Robert Petrosino
Vice President - Senior Analyst
lnfrastructure Finance Group
Moody's lnvestors Service, lnc.
250 Greenwich Street
New York, NY '10007
U.S.A.
JOURNALISTS: 1 212 553 0376
Client Service: 1 212 553 1653
Jim Hempstead
MD - Utilities
lnfrastructure Finance Group
JOURNALISTS:1 212 553 0376
Client Service: 1 212 553 1653
Releasing Office:
Moody's lnvestors Service, lnc.
250 Greenwich Street
New York, NY 10007
U.S.A.
JoURNALISTS:1 212 553 0376
Client Service:1212 553 1653
MooDY's
INVESTORS SERVICE
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affiliates (collectively, "MOODY'S"). All rights reserved.
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AFFILIATES ("MtS") ARE MOODY'S CURRENT OPINIONS OF THE RELATTVE FUTURE CREDTT
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