IDACORP INC
For the period ended Mar 31, 2025. Filed May 1, 2025.
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Mar 31, 2025 · Filed May 1, 2025
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Item 2. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION
AND RESULTS OF OPERATIONS
In MD&A in this report, the general financial condition and results of operations for IDACORP and its subsidiaries and Idaho Power and its subsidiary are discussed. While reading this MD&A, please refer to the accompanying condensed consolidated financial statements of IDACORP and Idaho Power. Also refer to "Cautionary Note Regarding Forward-Looking Statements" in this report for important information regarding forward-looking statements made in this MD&A and elsewhere in this report. This discussion updates the MD&A included in the 2024 Annual Report, and should also be read in conjunction with the information in that report. The results of operations for an interim period generally will not be indicative of results for the full year, particularly in light of the seasonality of Idaho Power's sales volumes, as discussed below.
INTRODUCTION
IDACORP is a holding company formed in 1998 whose principal operating subsidiary is Idaho Power. IDACORP’s common stock is listed and trades on the New York Stock Exchange under the trading symbol "IDA". Idaho Power is an electric utility whose rates and other matters are regulated by the IPUC, OPUC, and FERC. Idaho Power generates revenues and cash flows primarily from the sale and distribution of electricity to customers in its Idaho and Oregon service areas, as well as from the wholesale sale and transmission of electricity. Idaho Power experiences its highest retail energy sales during the summer irrigation and cooling season, with a lower peak in the winter that generally results from heating demand.
Idaho Power is the parent of IERCo, a joint-owner of BCC, which mines and supplies coal to the Jim Bridger plant owned in part by Idaho Power. IDACORP’s other notable subsidiaries include IFS, an investor in affordable housing and other real estate tax credit investments, and Ida-West, an operator of small PURPA-qualifying hydropower generation projects.
EXECUTIVE OVERVIEW
Management's Outlook and Company Objectives
In the 2024 Annual Report, IDACORP's and Idaho Power's management included a summary of their business objectives for the companies for 2025 and beyond, under the heading "Executive Overview" in the MD&A. As of the date of this report, management's outlook and strategy remain consistent with that discussion, as updated by some of the discussion in this MD&A. Some notable developments that have occurred since that report include the following:
Idaho Power continues to focus on timely recovery of costs and earning a reasonable return on investment. In March 2025, Idaho Power provided notice to the IPUC of its intent to file a general rate case in Idaho on or after May 30, 2025. Idaho Power also filed requests with the IPUC for rate changes for the FCA in March and the PCA in April, which if approved would result in a rate decrease of a combined $135.5 million for applicable customer classes. In addition, in March 2025, Idaho Power filed a request with the IPUC for an order authorizing an increase in customer rates of $29.7 million, effective June 1, 2025, to increase cash collection of AFUDC associated with the HCC relicensing project. The IPUC's decisions in these matters are pending.
Idaho Power continues to experience and forecast positive customer growth in its service area. During the twelve months ended March 31, 2025, Idaho Power's customer count grew by over 16,500 customers and the customer growth rate was 2.6 percent.
Idaho Power's need to acquire additional power supply and transmission resources to meet growing demand continues. To help meet those growing capacity and energy needs in 2025 and beyond, in February 2025 Idaho Power entered into the following transactions:
a 100MW solar facility PPA, coupled with a 100 MW energy storage agreement, with a scheduled online date of June 2027; and
an agreement to become a partial owner of SWIP-N, a planned 285-mile high-voltage transmission line, including an ownership of 250 MW and lease rights to an additional 250 MW of northbound capacity on the transmission line.
Summary of Financial Results
The following is a summary of Idaho Power's net income, net income attributable to IDACORP, and IDACORP's earnings per diluted share for the three months ended March 31, 2025 and 2024 (in thousands, except earnings per share amounts):
| Three months endedMarch 31, | ||
|---|---|---|
| 2025 | 2024 | |
| Idaho Power net income | $58,127 | $47,302 |
| Net income attributable to IDACORP, Inc. | $59,647 | $48,173 |
| Weighted average outstanding shares – diluted | 54,126 | 50,792 |
| IDACORP, Inc. earnings per diluted share | $1.10 | $0.95 |
The table below provides a reconciliation of net income attributable to IDACORP for the three months ended March 31, 2025, from the same period in 2024 (items are in millions and are before related income tax impact unless otherwise noted):
| Three months ended | |
|---|---|
| Net income attributable to IDACORP, Inc. - March 31, 2024 | $48.2 |
| Increase (decrease) in Idaho Power net income: | |
| Retail revenues per MWh, net of power cost adjustment mechanisms | 11.3 |
| Customer growth, net of associated power supply costs and power cost adjustment mechanisms | 7.3 |
| Usage per retail customer, net of associated power supply costs and power cost adjustment and FCA mechanisms | (2.1) |
| Other O&M expenses | (7.2) |
| Depreciation expense | (5.8) |
| Other changes in operating revenues and expenses, net | 1.9 |
| Increase in Idaho Power operating income | 5.4 |
| Non-operating expense, net | (2.2) |
| Additional ADITC amortization | 6.8 |
| Income tax expense, excluding additional ADITC amortization | 0.8 |
| Total increase in Idaho Power net income | 10.8 |
| Other IDACORP changes (net of tax) | 0.6 |
| Net income attributable to IDACORP, Inc. - March 31, 2025 | $59.6 |
IDACORP's net income increased $11.4 million for the first quarter of 2025 compared with the first quarter of 2024, due primarily to higher net income at Idaho Power.
A net increase in retail revenues per MWh, net of power cost adjustment mechanisms, increased operating income by $11.3 million in the first quarter of 2025 compared with the first quarter of 2024. This benefit was due primarily to an overall increase in Idaho base rates, effective January 1, 2025, per the 2024 Idaho Limited-Issue Rate Case. For more information on the 2024 Idaho Limited-Issue Rate Case, see Note 3 - "Regulatory Matters" to the consolidated financial statements included in the 2024 Annual Report.
At Idaho Power, customer growth increased operating income by $7.3 million in the first quarter of 2025 compared with the first quarter of 2024, as the number of Idaho Power customers grew by approximately 16,500, or 2.6 percent, during the twelve months ended March 31, 2025. Usage per retail customer was relatively consistent in the first quarter of 2025 compared with the first quarter of 2024. Residential usage per customer increased, as lower temperatures in the first quarter of 2025 compared with the first quarter of 2024 led residential customers to use more energy for heating purposes, but the increase was offset by a slight decrease in industrial usage per customer and the effects of customer mix changes. An increase in the deferral of residential and small commercial customer revenues through the FCA mechanism negatively affected retail revenues by $1.5 million.
Other O&M expenses in the first quarter of 2025 were $7.2 million higher than the first quarter of 2024, partially related to an approximate $3.2 million increase in wildfire mitigation program and related insurance expenses. In addition, other O&M expenses increased $1.8 million due to a decrease in grant funding received for maintenance work in the first quarter of 2025 as compared to the first quarter of 2024. Inflationary pressures on labor-related costs also contributed to the increase in other O&M expenses.
Depreciation expense increased $5.8 million in the first quarter of 2025 compared with the first quarter of 2024, due primarily to an increase in plant-in-service.
Other changes in operating revenues and expenses, net, increased operating income by $1.9 million in the first quarter of 2025 compared with the first quarter of 2024, due primarily to a decrease in net power supply expenses that were not deferred for future recovery in rates through Idaho Power's PCA mechanism, which increased other changes in operating revenues and expenses, net, compared with the same period in 2024. More moderate and less volatile wholesale natural gas and power market prices in the western United States decreased Idaho Power's net power supply expenses in the first quarter of 2025 compared with the first quarter of 2024.
Non-operating expense, net, increased $2.2 million in the first quarter of 2025 compared with the first quarter of 2024. Higher long-term debt balances and an increase in transmission customer deposits, on which Idaho Power must pay interest to the customer, led to an increase in interest expense. This increase was partially offset by an increase in AFUDC in the first quarter of 2025 compared with the first quarter of 2024, as the average construction work in progress balance was higher.
The decrease in income tax expense was principally the result of an increase in additional ADITC amortization. Based on Idaho Power's current expectations of full-year 2025 financial results, Idaho Power recorded $19.3 million of additional ADITC amortization under its Idaho regulatory settlement stipulation during the first quarter of 2025, compared with $12.5 million of additional ADITC amortization during the same period in 2024.
Overview of General Factors and Trends Affecting Results of Operations and Financial Condition
IDACORP's and Idaho Power's results of operations and financial condition are affected by a number of factors and trends, and the impact of those factors and trends is discussed in more detail below in this MD&A. To provide context for the discussion elsewhere in this report, some of the more notable factors and trends are as follows:
Regulatory Filings: The prices that Idaho Power is authorized to charge for its electric and transmission service are a critical factor in determining IDACORP's and Idaho Power's results of operations and financial condition. Those rates are established by state regulatory commissions and the FERC and are intended to allow Idaho Power an opportunity to recover its expenses and earn a reasonable return on investment. Idaho Power is focused on timely recovery of its costs through filings with its regulators and prudent management of expenses and investments.
To address the regulatory lag in recovery of costs primarily associated with Idaho Power’s current and anticipated significant infrastructure investments, including those that are intended to help meet projected near-term capacity deficits, in March 2025 Idaho Power provided notice to the IPUC of its intent to file a general rate case in Idaho on or after May 30, 2025. Idaho Power expects the processing of a general rate case would span at least seven months before new rates would be in effect.
Rate Base Growth and Infrastructure Investment: The rates established by the IPUC, OPUC, and FERC are determined with the intent to provide an opportunity for Idaho Power to recover authorized operating expenses and depreciation and earn a reasonable return on “rate base.” Rate base is generally determined by reference to the original cost (net of accumulated depreciation) of utility plant in service and certain other assets, subject to various adjustments for deferred income taxes and other items. Over time, rate base is increased by additions to utility plant in service and reduced by depreciation of utility plant and write-offs as authorized by the IPUC and OPUC. Idaho Power is pursuing significant enhancements to its utility infrastructure in an effort to maintain system reliability, ensure an adequate supply of electricity, and provide service to new customers, including major ongoing transmission projects such as the B2H, GWW, and SWIP-N projects. Idaho Power's existing hydropower and thermal generation facilities also require continuing upgrades and equipment replacement, and the company is undertaking a significant relicensing effort for the HCC, its largest hydropower generation resource. Idaho Power intends to pursue timely inclusion of completed capital projects into rate base as part of a 2025 general rate case and intends to continue to do so in future general rate cases or other appropriate regulatory proceedings.
Idaho Power expects its capital expenditures on infrastructure investments in the next five years or more will be considerable as it works to address projected energy and capacity deficits. For more information about forecasted capital expenditures and expected rate base growth, see the "Liquidity and Capital Resources" section of this MD&A.
Economic Conditions and Loads: Economic conditions impact consumer demand for energy, revenues, collectability of accounts, the volume of wholesale energy sales, and the need to construct and improve infrastructure, purchase power, and implement programs to meet customer load demands. In recent years, Idaho Power has seen significant growth in the number of customers in its service area. Over the twelve months ended March 31, 2025, Idaho Power's customer count grew by 2.6 percent. While recessionary or volatile economic conditions could slow the rate of customer growth, Idaho Power expects its number of customers and, to a greater extent its load due to anticipated commercial and industrial customer growth, to increase in the foreseeable future.
Idaho Power is preparing its 2025 IRP, its 20-year forecast of load and power supply resource options. Included in the below table are the load forecast assumptions the company anticipates using in the 2025 IRP as of the date of this report, and for comparison purposes, the analogous average annual growth rates Idaho Power used in the prior two IRPs.
| 5-Year Forecasted Annual Growth Rate | 20-Year Forecasted Annual Growth Rate | |||
|---|---|---|---|---|
| Retail Sales(Billed MWh) | Annual Peak(Peak Demand) | Retail Sales(Billed MWh) | Annual Peak(Peak Demand) | |
| 2025 IRP (preliminary) | 8.3% | 5.1% | 2.7% | 1.9% |
| 2023 IRP | 5.5% | 3.7% | 2.1% | 1.8% |
| 2021 IRP | 2.6% | 2.1% | 1.4% | 1.4% |
Customer growth has contributed to increases in peak loads experienced in recent years. For example, Idaho Power's highest all-time winter peak demand of 2,719 MW occurred on January 16, 2024, and on July 22, 2024, Idaho Power reached a new all-time summer peak demand of 3,793 MW. Idaho Power's prior all-time peak demand was 3,751 MW, set in June 2021. Idaho Power believes that existing and sustained growth in customers, load, and peak demand for electricity, along with changes in the regional transmission markets that have constrained the availability of transmission outside Idaho Power’s service area to import energy during peak load periods, require Idaho Power to increase its investment in capacity resources, transmission, and distribution infrastructure. This includes the B2H, GWW, and SWIP-N transmission projects, along with other capacity, energy, and transmission resource procurements, described in "Liquidity and Capital Resources" in this MD&A.
Weather Conditions: Weather and agricultural growing conditions have a significant impact on Idaho Power's energy sales. Relatively low and high temperatures result in greater energy use for heating and cooling, respectively. During the agricultural growing season, which in large part occurs during the second and third quarters of each year, irrigation customers use electricity to operate irrigation pumps, and weather conditions can impact the timing and extent of use of those pumps. Idaho Power also has tiered rates and seasonal rates, which contribute to increased revenues during higher-load periods, most notably during the third quarter of each year when overall customer demand is highest. Much of the adverse or favorable impact of weather on sales of energy to residential and small commercial customers is mitigated through the FCA mechanism, which is described in Note 3 - "Regulatory Matters" to the condensed consolidated financial statements included in this report.
Further, as Idaho Power's hydropower facilities comprise over one-half of Idaho Power's nameplate generation capacity, precipitation levels impact the mix of Idaho Power's generation resources. When hydropower generation decreases, Idaho Power must rely on more expensive generation sources and purchased power. When favorable hydropower generating conditions exist for Idaho Power, they also may exist for other Pacific Northwest hydropower facility operators, lowering regional wholesale market prices and impacting the revenue Idaho Power receives from wholesale energy sales. Much of the adverse or favorable impact of this volatility is addressed through the Idaho and Oregon power cost adjustment mechanisms, which mitigate in large part the impact on earnings. For 2025, Idaho Power expects generation from its hydropower resources to be in the range of 7.0 million to 8.5 million MWh, compared with actual generation of 7.2 million MWh in 2024 and a 30-year average annual total of approximately 7.7 million MWh.
Mitigation of Impact of Fuel and Purchased Power Expense: In addition to hydropower generation, Idaho Power relies significantly on natural gas and coal to fuel its generation facilities, long-term PPAs (including PURPA agreements), and power purchases in the wholesale markets. Fuel costs are impacted by electricity sales volumes, the terms and conditions of contracts for fuel, Idaho Power's generation capacity, the availability of hydropower generation resources, transmission capacity, energy market prices, and Idaho Power's hedging program for managing fuel costs. Purchased power costs are impacted by the terms and conditions of contracts for purchased power, the rate of expansion of alternative energy generation sources such as wind or solar energy, generation resource maintenance outages, wholesale energy market prices, transmission availability, and the outcome of Idaho Power's hedging programs. The Idaho and Oregon power cost adjustment mechanisms mitigate in large part the potential adverse earnings impacts to Idaho Power of fluctuations in power supply costs. However, collection from customers or return to customers of most of the difference between actual power supply costs compared with those included in retail rates is deferred to a subsequent period, which can affect Idaho Power’s operating cash flow and liquidity until those costs are recovered from or returned to customers.
Regulatory and Environmental Compliance Costs; Coal Plant Retirements: Idaho Power is subject to extensive federal and state laws, policies, and regulations, as well as regulatory actions and audits by agencies and quasi-governmental agencies, including the FERC, the North American Electric Reliability Corporation, and the Western Electricity Coordinating Council. Compliance with these requirements directly influences Idaho Power's operating environment and affects Idaho Power's operating costs. Moreover, environmental laws and regulations may increase the cost of constructing new facilities, may increase the cost of operating generation plants, may require that Idaho Power install additional pollution control devices at existing generating plants, may result in penalties for non-compliance, even where inadvertent, or may require that Idaho Power curtail or cease operating certain generation plants. Idaho Power expects to spend significant amounts on environmental compliance and controls for the foreseeable future. Due to economic factors in part associated with the costs of compliance with environmental regulation, Idaho Power accelerated the retirement date of its North Valmy plant, ceasing participation in coal-fired operations at one unit in 2019 and planning to cease its participation in coal-fired operations at the remaining unit by year-end 2025. Idaho Power's jointly-owned coal plant in Boardman, Oregon, ceased operations as planned in October 2020. In 2022, the IPUC approved Idaho Power's request to allow the coal-related assets at the Jim Bridger plant to be fully depreciated and recovered by end-of-year 2030. Idaho Power's 2023 IRP identified a preferred resource portfolio and action plan that includes the conversion from coal to natural gas of two units at the Jim Bridger plant in 2024, the two units at the North Valmy plant in 2026, and the remaining two units at the Jim Bridger plant in 2030. Units 1 and 2 at the Jim Bridger plant were successfully converted to natural gas in the second quarter of 2024. In July 2024, Idaho Power executed an agreement with its co-owner to facilitate the planned conversion of the two units at the North Valmy plant from coal to natural gas by mid-2026.
Water Management and Relicensing of Hydropower Projects: Because of Idaho Power's reliance on stream flow in the Snake River and its tributaries, Idaho Power participates in numerous proceedings and venues that may affect its water rights, seeking to preserve the long-term availability of its rights for its hydropower projects. Also, Idaho Power is involved in renewing its long-term federal licenses for the HCC, its largest hydropower generation source, and for American Falls, its second largest hydropower generation source. Given the number of parties involved, Idaho Power's relicensing costs have been and are expected to continue to be substantial. As of the date of this report, Idaho Power cannot determine the ultimate terms of, and costs associated with, any resulting long-term licenses for the HCC or American Falls hydropower facilities.
Wildfire Mitigation Efforts: In recent years, the western United States has experienced an increasing number of wildfires of unprecedented severity. A variety of factors have contributed to this trend including increased wildland-urban interfaces, historical land management practices, climate change, and overall wildland and forest health. Idaho Power is taking a proactive approach to wildfire risk in its service area and transmission corridors. Idaho Power has developed and adopted a WMP that outlines actions Idaho Power is taking or is working to implement to reduce wildfire risk and to strengthen the resiliency of its transmission and distribution system to wildfires. In April 2025, Idaho enacted the Wildfire Standard of Care Act, and Idaho Power plans to file a new Idaho-specific WMP with the IPUC based upon that statute after it becomes effective on July 1, 2025. Idaho Power's approach to wildfire mitigation includes identifying areas subject to elevated risk; system hardening programs, vegetation management, and field personnel practices to mitigate wildfire risk; incorporating current and forecasted weather and field conditions into operational practices; public safety power shutoff protocols; and evaluating the performance and effectiveness of its approach through metrics and monitoring. Idaho Power has regulatory authorization in both Idaho and Oregon to defer, for potential future amortization, certain actual incremental O&M expenses necessary to implement the WMP. The WMP regulatory deferrals are described in more detail in Note 3 - "Regulatory Matters" to the consolidated financial statements included in the 2024 Annual Report and the condensed consolidated financial statements included in this report.
RESULTS OF OPERATIONS
This section of MD&A takes a closer look at the significant factors that affected IDACORP’s and Idaho Power’s earnings during the three months ended March 31, 2025. In this analysis, the results for the three months ended March 31, 2025, are compared with the same period in 2024.
The table below presents Idaho Power’s energy sales and supply (in thousands of MWh) for the three months ended March 31, 2025 and 2024.
| Three months endedMarch 31, | ||
|---|---|---|
| 2025 | 2024 | |
| Retail energy sales | 3,723 | 3,599 |
| Wholesale energy sales | 439 | 404 |
| Energy sales bundled with renewable energy credits | 541 | 687 |
| Total energy sales | 4,703 | 4,690 |
| Hydropower generation | 2,124 | 1,749 |
| Steam generation(1) | 674 | 515 |
| Natural gas and other generation | 774 | 1,049 |
| Total system generation | 3,572 | 3,313 |
| Purchased power | 1,477 | 1,704 |
| Line losses | (346) | (327) |
| Total energy supply | 4,703 | 4,690 |
(1) "Steam generation" is composed of generation from steam plants that are fueled by only coal or by both coal and natural gas.
Weather-related information for Boise, Idaho, for the three months ended March 31, 2025 and 2024, is presented in the table below. While Boise, Idaho weather conditions are not necessarily representative of weather conditions throughout Idaho Power's service area, the greater Boise area has the majority of Idaho Power's customers and is included for illustrative purposes.
| Three months endedMarch 31, | |||
|---|---|---|---|
| 2025 | 2024 | Normal (2) | |
| Heating degree-days(1) | 2,416 | 2,264 | 2,402 |
| Cooling degree-days(1) | — | — | — |
| Precipitation (inches) | 5.1 | 6.5 | 3.7 |
(1) Heating and cooling degree-days are common measures used in the utility industry to analyze the demand for electricity and indicate when a customer would use electricity for heating and cooling. A degree-day measures how much the average daily temperature varies from 65 degrees. Each degree of temperature above 65 degrees is counted as one cooling degree-day, and each degree of temperature below 65 degrees is counted as one heating degree-day.
(2) Normal heating degree-days and cooling degree-days elements are, by convention, the arithmetic mean of the elements computed over 30 consecutive years. The normal amounts are the sum of the monthly normal amounts. These normal amounts are computed by the National Oceanic and Atmospheric Administration.
Sales Volume and Generation: Retail sales volumes increased 3 percent in the first quarter of 2025 compared with the same period in 2024, primarily due to growth in the number of Idaho Power customers and an increase in usage per residential customer. The number of Idaho Power customers grew by 2.6 percent over the prior twelve months. For more information on the changes in sales volume, see the "Operating Revenues" section below in this MD&A.
Total system generation increased 8 percent for the first quarter of 2025 compared with the same period in 2024, which consists of an increase in hydropower generation and steam generation, partially offset by decreased natural gas generation. For more information on the changes in generation, see the "Operating Expenses" section below in this MD&A.
The financial impacts of fluctuations in wholesale energy sales, purchased power, fuel expense, and other power supply-related expenses are addressed in Idaho Power's Idaho and Oregon power cost adjustment mechanisms, which are described below in "Power Cost Adjustment Mechanisms."
Operating Revenues
Retail Revenues: The table below presents Idaho Power’s retail revenues (in thousands) and MWh sales volumes (in thousands) for the three months ended March 31, 2025 and 2024, and the number of customers as of March 31, 2025 and 2024.
| Three months endedMarch 31, | ||
|---|---|---|
| 2025 | 2024 | |
| Retail revenues: | ||
| Residential (includes $(2,193), and $(687) respectively, related to the FCA)(1) | $190,705 | $184,300 |
| Commercial (includes $(43) and $(53), respectively, related to the FCA)(1) | 97,852 | 94,697 |
| Industrial | 68,607 | 65,206 |
| Irrigation | 1,113 | 1,038 |
| Deferred revenue related to HCC relicensing AFUDC(2) | (2,064) | (2,084) |
| Total retail revenues | $356,213 | $343,157 |
| Volume of retail sales (MWh) | ||
| Residential | 1,702 | 1,624 |
| Commercial | 1,075 | 1,064 |
| Industrial | 934 | 901 |
| Irrigation | 12 | 10 |
| Total retail MWh sales | 3,723 | 3,599 |
| Number of retail customers at period end | ||
| Residential | 550,207 | 534,858 |
| Commercial | 79,823 | 78,781 |
| Industrial | 148 | 135 |
| Irrigation | 22,457 | 22,342 |
| Total customers | 652,635 | 636,116 |
(1) The FCA mechanism is an alternative revenue program in the Idaho jurisdiction and does not represent revenue from contracts with customers.
(2) The IPUC allows Idaho Power to recover a portion of the AFUDC on construction work in progress related to the HCC relicensing process, even though the relicensing process is not yet complete and the costs have not been moved to utility plant in service. Idaho Power is collecting approximately $8.8 million annually in the Idaho jurisdiction but is deferring revenue recognition of the amounts collected until the license is issued and the accumulated license costs approved for recovery are placed in service.
Changes in rates, changes in customer demand, customer growth, and changes in FCA mechanism revenues are the primary reasons for fluctuations in retail revenues from period to period. The primary influences on customer demand for electricity are weather, economic conditions, and energy efficiency. Extreme temperatures increase sales to customers who use electricity for cooling and heating, while moderate temperatures decrease sales. Precipitation levels and the timing of precipitation during the agricultural growing season also affect sales to customers who use electricity to operate irrigation pumps. Rates are also seasonally adjusted, providing for higher rates during summer peak load periods, and residential customer rates are tiered, providing for higher rates based on higher levels of usage. The seasonal and tiered rate structures contribute to seasonal fluctuations in revenues and earnings.
Retail revenues increased $13.1 million during the first quarter of 2025 compared with the same period in 2024. The factors affecting retail revenues during the periods are discussed below.
Rates: Customer rates, excluding revenues related to power cost adjustment mechanisms, increased retail revenues by $11.3 million for the first three months of 2025 compared with the same period in 2024, due primarily to an overall increase in Idaho base rates, effective January 1, 2025, per the 2024 Idaho Limited-Issue Rate Case. Customer rates also include the collection from customers of amounts related to the power cost adjustment mechanisms, which decreased revenues by $8.3 million in the first quarter of 2025 compared with the same period of 2024. The amount collected from customers in rates under the power cost adjustment mechanisms has relatively little effect on operating income as a corresponding amount is recorded as expense in the same period it is collected through rates.
Customers: Customer growth of 2.6 percent during the twelve months ended March 31, 2025, increased retail revenues by $10.8 million in the first quarter of 2025 compared with the same period of 2024.
Usage: Overall usage (on a per customer basis) was relatively consistent between the first quarters of 2025 and 2024. Residential usage per customer increased, as lower temperatures in the first quarter of 2025 compared with the first quarter of 2024 led to residential customers to use more energy for heating purposes, but the increase was partially offset by a decrease in industrial usage per customer and the effects of customer mix changes.
FCA Mechanism: An increase in the deferral of residential and small commercial customer revenues through the FCA mechanism negatively affected retail revenues by $1.5 million.
Wholesale Energy Sales: Wholesale energy sales consist primarily of long-term sales contracts, opportunity sales of surplus system energy, and sales into the energy imbalance market in the western United States, and do not include derivative transactions. The table below presents Idaho Power’s wholesale energy sales for the three months ended March 31, 2025 and 2024 (in thousands, except for revenue per MWh amounts).
| Three months endedMarch 31, | ||
|---|---|---|
| 2025 | 2024 | |
| Wholesale energy revenues | $19,548 | $38,069 |
| Wholesale MWh sold | 439 | 404 |
| Wholesale energy revenues per MWh | $44.53 | $94.23 |
In the first quarter of 2025, wholesale energy revenues decreased $18.5 million compared with the same period of 2024, due primarily to lower wholesale market prices. Wholesale energy prices were lower during the first three months of 2025 compared with 2024 as more moderate winter weather resulted in lower power prices in the wholesale markets in the region. The financial impacts of fluctuations in wholesale energy sales are largely mitigated by Idaho Power's Idaho and Oregon power cost adjustment mechanisms, which are described below in this section of the MD&A under "Power Cost Adjustment Mechanisms."
Operating Expenses
Purchased Power: The table below presents Idaho Power’s purchased power expenses and volumes for the three months ended March 31, 2025 and 2024 (in thousands, except for per MWh amounts).
| Three months endedMarch 31, | ||
|---|---|---|
| 2025 | 2024 | |
| Purchased power expense | $74,109 | $111,899 |
| MWh purchased | 1,477 | 1,704 |
| Average cost per MWh | $50.18 | $65.67 |
Purchased power expense decreased $37.8 million, or 34 percent, during the first quarter of 2025 compared with the same period of 2024, primarily due to lower wholesale energy market prices in the region. Also, increased system generation led to a decrease in total MWh purchased of 13 percent compared to 2024.
Fuel Expense: The table below presents Idaho Power’s fuel expenses and thermal generation for the three months ended March 31, 2025 and 2024 (in thousands, except for per MWh amounts).
| Three months endedMarch 31, | ||
|---|---|---|
| 2025 | 2024 | |
| Expense | ||
| Steam(1) | $30,917 | $28,595 |
| Natural gas(2) | 38,484 | 63,646 |
| Total fuel expense | $69,401 | $92,241 |
| MWh generated | ||
| Steam(1) | 674 | 515 |
| Natural gas(2) | 774 | 1,049 |
| Total MWh generated | 1,448 | 1,564 |
| Average cost per MWh - Steam | $45.87 | $55.52 |
| Average cost per MWh - Natural gas | $49.72 | $60.67 |
| Weighted average, all sources | $47.93 | $58.98 |
(1) "Steam" is composed of expenses and generation from steam plants that are fueled only by coal or by both coal and natural gas.
(2) Includes a negligible amount of expense and generation related to the Salmon diesel-fired generation plant.
The majority of the fuel for Idaho Power’s jointly-owned plants is purchased through long-term contracts, including purchases from BCC, a one-third owned investment of IERCo. The price of coal from BCC is subject to fluctuations in mine operating expenses, geologic conditions, and production levels. BCC supplies the majority of the coal used by the Jim Bridger plant and BCC does not have significant sales to third parties. Natural gas is mainly purchased on the regional wholesale spot market at published index prices. In addition to commodity (variable) costs, both natural gas and coal expenses include costs that are more fixed in nature for items such as capacity charges, transportation, and fuel handling. Period to period variances in fuel expense per MWh are noticeably impacted by these fixed charges when generation output is substantially different between the periods.
Fuel expense decreased $22.8 million, or 25 percent, in the first quarter of 2025 compared with the same period of 2024, primarily due to a 19 percent decrease in the total average cost per MWh from all sources and a 7 percent decrease in MWh generated from steam and natural gas generation. Hydropower generation increased 21 percent during the first three months of 2025, compared with the same period of 2024, which reduced utilization of steam and natural gas generation to serve load and provide power for wholesale energy sales.
Included in fuel expense are losses and gains on settled financial gas hedges entered into in accordance with Idaho Power's energy risk management policy. For the first quarters of 2025 and 2024, losses on financial gas hedges of $12.2 million and $24.1 million, respectively, increased natural gas fuel expense. Most of these realized hedging losses and gains are passed on to customers through the power cost adjustment mechanisms described below.
Power Cost Adjustment Mechanisms: Idaho Power's power supply costs (primarily purchased power and fuel expense, less wholesale energy sales) can vary significantly from year to year. Volatility of power supply costs arises from factors such as weather conditions, wholesale market prices, volumes of power purchased and sold in the wholesale markets, Idaho Power's hydropower and thermal generation volumes and fuel costs, generation plant availability, and retail loads. To address the volatility of power supply costs, Idaho Power's power cost adjustment mechanisms in the Idaho and Oregon jurisdictions allow Idaho Power to recover from customers, or refund to customers, most of the fluctuations in power supply costs. In the Idaho jurisdiction, the PCA includes a cost or benefit sharing ratio that allocates the deviations in net power supply expenses between customers (95 percent) and Idaho Power (5 percent), with the exception of PURPA power purchases and demand response program incentives, which are allocated 100 percent to customers. The Idaho deferral period, or PCA year, runs from April 1 through March 31. Amounts deferred or accrued during the PCA year are primarily recovered or refunded during the subsequent June 1 through May 31 period. However, the IPUC directed Idaho Power to spread recovery of the March 31, 2023 PCA deferral balance over a two-year period from June 1, 2023 to May 31, 2025. Because of the power cost adjustment mechanisms, the primary financial impact of power supply cost variations is that cash is paid out but recovery from customers does not occur until a future period, or cash that is collected is refunded to customers in a future period, resulting in fluctuations in operating cash flows from year to year.
The table below presents the components of the Idaho and Oregon power cost adjustment mechanisms for the three months ended March 31, 2025 and 2024 (in thousands).
| Three months endedMarch 31, | ||
|---|---|---|
| 2025 | 2024 | |
| Idaho power supply cost accrual | $29,443 | $922 |
| Oregon power supply cost deferral | (2,657) | (528) |
| Amortization of prior year authorized balances | 20,899 | 21,969 |
| Total power cost adjustment (income statement) | $47,685 | $22,363 |
The power supply accruals (deferrals) represent the portion of the power supply cost fluctuations accrued (deferred) under the power cost adjustment mechanisms. When actual power supply costs are lower than the amount forecasted in power cost adjustment rates, most of the difference is accrued as an increase to a regulatory liability or decrease to a regulatory asset. When actual power supply costs are higher than the amount forecasted in power cost adjustment rates, most of the difference is deferred as an increase to a regulatory asset or decrease to a regulatory liability. During the first quarter of 2025, purchased power costs led to lower actual power supply costs compared with the forecasted amount, which resulted in an accrual of power supply costs by the mechanism. The amortization of the prior year’s balances represents the offset to the amounts being collected or refunded in the current power cost adjustment year that were deferred or accrued in the prior PCA year (the balancing adjustment component of the power cost adjustment mechanism).
Other O&M Expenses: Other O&M expenses in the first quarter of 2025 were $7.2 million higher than the first quarter of 2024, partially related to an approximate $3.2 million increase in wildfire mitigation program and related insurance expenses. In addition, other O&M expenses increased $1.8 million due to a decrease in grant funding received for maintenance work in the first quarter of 2025 as compared with the first quarter of 2024. Inflationary pressures on labor-related costs also contributed to the increase in other O&M expenses.
Income Taxes
IDACORP's and Idaho Power's income tax expense decreased $6.9 million and $7.6 million, respectively, for the three months ended March 31, 2025, when compared with the same period in 2024, primarily due to increased ADITC amortization from the regulatory mechanism described in Note 3 – “Regulatory Matters” to the condensed consolidated financial statements included in this report. For information relating to IDACORP's and Idaho Power's computation of income tax expense, see Note 2 - "Income Taxes" to the condensed consolidated financial statements included in this report.
LIQUIDITY AND CAPITAL RESOURCES
Overview
Idaho Power funds its liquidity needs for capital expenditures through cash flows from operations, debt offerings, commercial paper markets, credit facilities, and capital contributions from IDACORP. Idaho Power periodically files for rate adjustments for recovery of operating costs and capital investments to provide the opportunity to align Idaho Power's earned returns with those allowed by regulators.
As of April 25, 2025, IDACORP's and Idaho Power's access to debt, equity, and credit arrangements included the following:
their respective $100 million and $400 million revolving credit facilities;
their issuance of commercial paper, with program sizes of $100 million and $300 million, respectively. Idaho Power's commercial paper program may be increased up to the $400 million capacity of its credit facility;
IDACORP's shelf registration statement filed with the SEC on February 21, 2025, which may be used for the issuance of debt securities and common stock, including a remaining aggregate gross sales price of up to $155 million in shares of IDACORP common stock available for issuance through its ATM offering program;
IDACORP's executed FSAs under its ATM offering program, which may be physically settled with common stock in exchange for net proceeds, which as of April 25, 2025, would have been approximately $144 million; and
Idaho Power's shelf registration statement filed with the SEC on February 21, 2025, which may be used for the issuance of first mortgage bonds and other debt securities; $500 million remains available for issuance pursuant to state regulatory authority.
IDACORP uses original issuances of shares for the IDACORP, Inc. Dividend Reinvestment and Stock Purchase Plan and also intends to use original issuances for share purchases within the Idaho Power Company Employee Savings Plan beginning in the second half of 2025. IDACORP may discontinue using original issuances of shares for these plans at any time.
During 2025, IDACORP executed FSAs under its ATM offering program with various counterparties, at an aggregate gross sales price of $52 million. For more detailed information about IDACORP's equity transactions, see below in this MD&A and Note 6 - "Common Stock" to the condensed consolidated financial statements included in this report.
Further, during 2025, Idaho Power issued $400 million in first mortgage bonds and repaid approximately $20 million in maturing variable rate bonds. For more detailed information about Idaho Power's long-term debt transactions, see Note 5 - "Long-Term Debt" to the condensed consolidated financial statements included in this report.
The proceeds from these issuances of common stock and first mortgage bonds are expected to be used for general corporate purposes, including funding Idaho Power's capital projects.
IDACORP and Idaho Power monitor capital markets with a view toward favorable debt and equity transactions, taking into account current and potential future long-term needs. As a result, IDACORP may issue debt securities or common stock, and Idaho Power may issue first mortgage bonds or other debt securities, if the companies believe terms available in the capital markets are favorable and that issuances would be financially prudent. IDACORP may also elect to issue common stock, from time to time, under its ATM offering program, depending on market conditions and capital needs. Idaho Power also periodically analyzes whether partial or full early redemption of one or more existing outstanding series of first mortgage bonds is desirable, and in some cases, may refinance indebtedness with new indebtedness.
Based on planned capital expenditures and other O&M expenses, the companies believe they will be able to meet capital and debt service requirements and fund corporate expenses during at least the next twelve months and thereafter for the foreseeable future with a combination of existing cash, operating cash flows generated by Idaho Power's utility business, availability under existing credit facilities, access to commercial paper, short-term and long-term debt markets, and equity issuances.
IDACORP and Idaho Power generally seek to maintain capital structures of approximately 50 percent debt and 50 percent equity. Maintaining this ratio influences IDACORP's and Idaho Power's debt and equity issuance decisions. As of March 31, 2025, IDACORP's and Idaho Power's capital structures, as calculated for purposes of applicable debt covenants, were as follows:
| IDACORP | Idaho Power | |
|---|---|---|
| Debt | 51% | 53% |
| Equity | 49% | 47% |
IDACORP and Idaho Power generally maintain their cash and cash equivalents in highly liquid investments, such as U.S. Treasury Bills, money market funds, and bank deposits.
At March 31, 2025, IDACORP and Idaho Power believed they were in compliance with all credit facility and long-term debt covenants. Further, IDACORP and Idaho Power do not anticipate they will be in violation or breach of their respective debt covenants during 2025.
Operating Cash Flows
IDACORP's and Idaho Power's principal sources of cash flows from operations are Idaho Power's sales of electricity and transmission capacity. Significant uses of cash flows from operations include the purchase of fuel and power, other operating expenses, interest, income taxes, and plan contributions. Operating cash flows can be significantly influenced by factors such as weather conditions, rates and the outcome of regulatory proceedings, and economic conditions. As fuel and purchased power are significant uses of cash, Idaho Power has regulatory mechanisms in place that provide for the deferral and recovery of the majority of the fluctuation in those costs. However, if actual costs rise above the level currently allowed in retail rates, deferral balances increase (reflected as a regulatory asset), negatively affecting operating cash flows until such time as those costs, with interest, are recovered from customers.
IDACORP’s and Idaho Power’s operating cash inflows for the three months ended March 31, 2025, were $124 million and $111 million, respectively, an increase in cash flows from operations of $15 million for IDACORP and $4 million for Idaho Power, when compared with the same period in 2024. With the exception of cash flows related to income taxes, IDACORP's operating cash flows are principally derived from the operating cash flows from Idaho Power. Significant items that affected the companies' operating cash flows in the first three months of 2025 when compared with the same period in 2024 were as follows:
an $11 million increase in IDACORP and Idaho Power net income;
changes in regulatory assets and liabilities, mostly related to the relative amounts of costs deferred and collected under the PCA and FCA mechanisms, increased IDACORP and Idaho Power operating cash flows by $36 million;
changes in deferred taxes and taxes accrued and receivable combined to increase operating cash flows for IDACORP by $2 million and decrease operating cash flows for Idaho Power by $8 million;
changes in distributions from equity-method investments from IERCo, a wholly-owned subsidiary of Idaho Power, decreased IDACORP and Idaho Power operating cash flows by $3 million, which was due to the timing and amount of the subsidiary's funding decisions; and
changes in working capital balances due primarily to timing, including fluctuations as follows:
the timing of collections of accounts receivable and unbilled revenues decreased operating cash flows by $27 million for IDACORP and $28 million for Idaho Power,
the changes in materials, supplies, and fuel stock increased operating cash flows by $18 million for IDACORP and Idaho Power, which was due to the timing of purchases and consumption of materials and supplies inventory at Idaho Power, and coal at Idaho Power's jointly-owned coal-fired generating plants; and
the changes in other assets and liabilities decreased operating cash flows by $25 million for IDACORP and Idaho Power. This decrease was primarily due to changes in accrued paid time off and leave, deferred revenue from renewable energy credit sale agreements, accrued interest, utility property removal cost and salvage activities, and customer deposits, partially offset by performance assurance collateral activity for margin agreements relating to wholesale commodity contracts.
Investing Cash Flows
Investing activities consist primarily of capital expenditures related to new construction of, and improvements to, Idaho Power’s power supply, transmission, and distribution facilities. IDACORP’s and Idaho Power’s net investing cash outflows for the three months ended March 31, 2025, were $183 million and $177 million, respectively, decreasing cash outflow by $52 million for IDACORP and by $57 million for Idaho Power when compared with the same period in 2024. Investing cash outflows for 2025 and 2024 were primarily for construction of utility infrastructure needed to address Idaho Power’s customer growth and peak resource needs, aging plant and equipment, and environmental and regulatory compliance requirements. Investing cash outflows were partially offset in 2025 and 2024 by reimbursements from a B2H project joint permitting participant relating to a portion of the permitting expenditures.
Financing Cash Flows
Financing activities primarily provide supplemental cash for both day-to-day operations and capital requirements, as needed. IDACORP's and Idaho Power's net financing cash inflows for the three months ended March 31, 2025, were $324 million and $326 million, respectively, an increase of $369 million for IDACORP and Idaho Power when compared with the same period in 2024. IDACORP and Idaho Power financing cash inflows for 2025 were primarily related to Idaho Power's net proceeds from the issuance of first mortgage bonds, partially offset by the repayment of variable rate bonds and dividend payments. Idaho Power funds liquidity needs for capital investment, working capital, managing commodity price risk, dividends, and other financial commitments through cash flows from operations, debt offerings, commercial paper markets, credit facilities, and capital contributions from IDACORP. IDACORP funds its cash requirements, such as payment of taxes, payment of dividends, capital contributions to Idaho Power, and non-utility expenses allocated to IDACORP, through cash flows from operations, commercial paper markets, sales of common stock, and credit facilities.
Financing Programs and Available Liquidity
IDACORP Equity Programs: In March 2025, IDACORP executed FSAs under its ATM offering program with various counterparties, at an aggregate gross sales price of $52 million. At March 31, 2025, IDACORP's cumulative aggregate gross sales price of executed and outstanding FSAs under its ATM offering program was $145 million, and $155 million in shares of IDACORP’s common stock remained available for issuance. IDACORP may settle the FSAs at any time up to their respective maturity dates of approximately one year following execution. If IDACORP had elected to physically settle the FSAs as of April 25, 2025, by delivering shares of common stock, cash proceeds would have been approximately $144 million. Actual cash proceeds, if any, for settlement of the FSAs will depend on the method and timing IDACORP elects for settlement. For more detailed information about IDACORP's equity transactions, see Note 6 - "Common Stock" to the condensed consolidated financial statements included in this report. Depending on market conditions, its financial and regulatory strategy, and other factors, IDACORP could determine to issue additional equity securities in 2025.
Idaho Power First Mortgage Bonds: Idaho Power's issuance of long-term indebtedness is subject to the approval of the IPUC, OPUC, and WPSC. In February and March 2024, Idaho Power received orders from the IPUC, OPUC, and WPSC authorizing the company to issue and sell from time to time up to $1.2 billion in aggregate principal amount of debt securities and first mortgage bonds, subject to conditions specified in the orders. At March 31, 2025, $500 million remained available for debt issuance under the regulatory orders. For more detailed information about Idaho Power First Mortgage Bonds, see Note 5 - "Long-term Debt" to the condensed consolidated financial statements included in this report.
Available Short-Term Borrowing Liquidity
The table below outlines available short-term borrowing liquidity as of the dates specified (in thousands).
| March 31, 2025 | December 31, 2024 | |||
|---|---|---|---|---|
| IDACORP(2) | Idaho Power | IDACORP(2) | Idaho Power | |
| Revolving credit facility | $100,000 | $400,000 | $100,000 | $400,000 |
| Commercial paper outstanding | — | — | — | — |
| Identified for other use(1) | — | — | — | (19,885) |
| Net balance available | $100,000 | $400,000 | $100,000 | $380,115 |
(1) American Falls bonds that Idaho Power could have been required to purchase prior to maturity under the optional or mandatory purchase provisions of the bonds, if the remarketing agent for the bonds were unable to sell the bonds to third parties. The American Falls bonds were repaid in full on February 3, 2025.
(2) Holding company only.
On April 25, 2025, IDACORP and Idaho Power had no loans outstanding under their revolving credit facilities and had no commercial paper outstanding.
Impact of Credit Ratings on Liquidity and Collateral Obligations
IDACORP’s and Idaho Power’s access to capital markets, including the commercial paper market, and their respective financing costs in those markets, depend in part on their respective credit ratings. There have been no changes to IDACORP's or Idaho Power's ratings by Standard & Poor’s Ratings Services or Moody’s Investors Service from those included in the 2024 Annual Report. However, any rating can be revised upward or downward or withdrawn at any time by a rating agency if it decides that the circumstances warrant the change.
Idaho Power maintains margin agreements relating to its wholesale commodity contracts that allow performance assurance collateral to be requested of and/or posted with certain counterparties, which are discussed further in Part I - Item 3 "Quantitative and Qualitative Disclosures About Market Risk" included in this report.
Capital Requirements
Idaho Power's cash capital expenditures, excluding AFUDC, were $194 million during the three months ended March 31, 2025. The table below presents Idaho Power's estimated accrual-basis additions to property, plant, and equipment for 2025 (including amounts incurred to-date) through 2029 (in billions of dollars). The amounts in the table exclude AFUDC but include net costs of removing assets from service that Idaho Power expects would be eligible to be included in rate base in future rate case proceedings. Given the uncertainty associated with the timing of infrastructure projects and associated expenditures, actual expenditures and their timing could deviate substantially from those set forth in the table. The timing and amount of actual constructed projects and capital expenditures could be affected by Idaho Power’s ability to timely obtain labor or materials at reasonable costs, supply chain disruptions and delays, permitting, legal processes, regulatory determinations, inflationary pressures, macroeconomic conditions, tariffs, or other issues, including those described below.
| 2025 | 2026 | 2027-2029 | |
| Expected capital expenditures (excluding AFUDC), in billions of dollars | $1.00-$1.10 | $1.25-$1.35 | $3.10-$3.60 |
|---|
Major Infrastructure Projects: Idaho Power is engaged in the development of a number of significant projects and has entered into arrangements with third parties concerning joint infrastructure development. The discussion below provides a summary of developments in certain of those projects since the discussion of these matters included in Part II, Item 7 - MD&A - "Capital Requirements" in the 2024 Annual Report. The discussion below should be read in conjunction with that report.
Resource Additions to Address Projected Energy and Capacity Deficits: Idaho Power's existing and sustained growth in customers, load, and peak demand for electricity, along with transmission constraints, has created the need for Idaho Power to acquire significant generation, transmission, and storage resources to meet energy and capacity needs over the next several years. To help meet peak needs in 2025 through 2027, Idaho Power entered into:
contracts or plans to purchase, own, and operate 330 MW of battery storage assets with expected useful lives of approximately 20 years;
a contract to purchase and own a 300 MW wind facility;
two 20-year agreements to purchase the storage capacity from battery storage facilities totaling 250 MW;
an energy and capacity market purchase agreement with an energy marketer giving Idaho Power the right to acquire 200 MW on a daily basis during summer months beginning in 2026 for a term of at least five years;
a PPA for 300 MW output of a planned third-party wind facility; and
four PPAs for the combined 745 MW output of planned third-party solar facilities. Idaho Power plans to sell the output of three of these solar PPAs totaling 645 MW exclusively to a large industrial customer pursuant to an agreement under Idaho Power’s Clean Energy Your Way program.
The capital requirements table above includes capital expenditures of more than $1.1 billion from 2025 through 2027 for resource additions to address projected energy and capacity deficits in those years. To help address the additional capacity deficits projected for 2027 and beyond, Idaho Power continues to evaluate its RFP for additional resources. Depending on factors such as RFP results, the timing of project in-service dates, estimated load and resource balances and customer growth, the nature and quantity of resources owned versus acquired under PPAs or similar agreements, and the outcome of regulatory proceedings, actual expenditures and their timing could deviate substantially from Idaho Power's expected expenditures.
B2H Transmission Line: The B2H line, a planned 300-mile, high-voltage transmission project between a substation near Boardman, Oregon, and the Hemingway substation near Boise, Idaho, will provide transmission service to meet future resource needs. Material procurement is in process and long-lead-time materials are arriving in Oregon. Idaho Power expects construction will begin in 2025 and expects the in-service date for the transmission line will be no earlier than 2027.
As more fully described in the 2024 Annual Report, Idaho Power's ownership interest in the project is approximately 45 percent. Idaho Power has spent approximately $431 million, including Idaho Power's AFUDC, on the B2H project through March 31, 2025. Pursuant to the terms of the joint funding arrangements, Idaho Power has received $225 million in reimbursement as of March 31, 2025, from project co-participants for their share of costs and continues to receive reimbursement as costs are incurred. PacifiCorp is obligated to reimburse Idaho Power for its share of any future project permitting expenditures or agreed-upon early construction expenditures incurred by Idaho Power under the terms of the joint funding agreement. Idaho Power and PacifiCorp operate under a construction funding agreement filed with the FERC.
The permitting phase of the B2H project was subject to federal review and approval by various federal agencies. Federal agency records of decision have been received and all lawsuits challenging the federal rights-of-way have been resolved. However, Idaho Power has not yet received the required approval to construct from the applicable federal agencies.
In the separate State of Oregon permitting process, the state's EFSC approved Idaho Power's site certificate in September 2022. The Oregon Department of Energy subsequently issued a final order and site certificate. Idaho Power pursued two amendments to the site certificate to accommodate route changes, many of which are for the benefit of landowners along the route, and to enhance constructability. In September 2023, EFSC approved Idaho Power's first amendment request. The Union County Circuit Court dismissed a subsequent effort to contest the amendment approval in October 2024. Separately, in August 2024, EFSC approved Idaho Power's second amendment request. The approval of the second amendment was contested. On March 27, 2025, the Oregon Supreme Court upheld the EFSC approval of the second amendment to the site certificate. During the second quarter of 2023, the IPUC, OPUC, and WPSC granted Idaho Power and PacifiCorp their respective CPCNs related to the construction of the B2H project.
Total cost estimates for the project are between $1.5 billion and $1.7 billion, including Idaho Power's AFUDC. The capital requirements table above includes approximately $500 million of Idaho Power's share of estimated costs (excluding AFUDC) related to the remaining permitting phase, design, material procurement, and construction phases of the project. Actual construction costs could differ from Idaho Power's estimates based upon Idaho Power's or its contractors' ability to timely obtain labor or materials at reasonable costs, supply chain disruptions and delays, inflationary pressures, tariffs, macroeconomic conditions, or other issues.
GWW Transmission Line: Idaho Power and PacifiCorp are pursuing the joint development of the GWW project, a high-voltage transmission line project between a substation located near Douglas, Wyoming, and the Hemingway substation located near Boise, Idaho. In 2012, Idaho Power and PacifiCorp entered into a joint funding agreement for permitting of the project.
The permitting phase of the GWW project was subject to review and approval of the Bureau of Land Management (BLM). The BLM has published its records of decision for all segments of the transmission line. In 2020 and 2024, PacifiCorp completed construction and commissioned segments of its portion of the project in Wyoming. In March 2023, PacifiCorp initiated the pre-construction phase of 620 miles of 500-kV transmission line from the Populus substation near Downey, Idaho, to the Hemingway substation near Boise, Idaho. Current permitting and pre-construction activities are focused on the section of line between the Hemingway substation and the Midpoint substation near Jerome, Idaho. Idaho Power expects the in-service date for this section of line or a portion of this section will be 2028 or later. Idaho Power and PacifiCorp continue to coordinate the timing of next steps to best meet customer and system needs including potentially modifying the ownership structure of a few segments of the project.
Idaho Power has expended approximately $71 million, including Idaho Power's AFUDC, for its share of the permitting phase of the project through March 31, 2025. As of the date of this report, Idaho Power estimates the total cost for its share of the project (including both permitting and construction) to be between $900 million and $1.1 billion, including Idaho Power's AFUDC. The estimated cost range is based on assumptions about Idaho Power participation levels in the construction of certain project segments, and any changes in those assumptions or in Idaho Power's actual participation could affect future estimates and actual project costs. The capital requirements table above includes approximately $615 million of Idaho Power's share of estimated costs (excluding AFUDC) for the permitting phase of the project and early construction costs, based on Idaho Power's current estimate that it may commence construction of applicable segments during that time period. Actual construction costs could differ from Idaho Power's estimates based upon the ability of Idaho Power, PacifiCorp, or their respective contractors to timely obtain labor or materials at reasonable costs, supply chain disruptions and delays, inflationary pressures, tariffs, macroeconomic conditions, or other issues.
SWIP-N Transmission Line: In February 2025, Idaho Power entered into a commitment to become a partial owner of SWIP-N, a planned 285-mile, high-voltage transmission line between the Robinson Summit Substation near Ely, Nevada, and the Midpoint Substation near Jerome, Idaho. Upon the project being placed into service, the applicable agreements provide that Idaho Power will purchase an approximate 11 percent ownership interest in the project, entitling Idaho Power to approximately 11 percent of the total capacity of the SWIP-N line. In addition, Idaho Power entered into a capacity entitlement agreement entitling Idaho Power to approximately 11 percent of additional capacity on the SWIP-N line over a 40-year term commencing upon the project being placed in service. Idaho Power expects construction of the project to commence as early as 2025 and take approximately two years to complete. Idaho Power is responsible for approximately 11 percent of the total costs to develop and construct the project. The capital requirements table above includes Idaho Power's share of the costs to develop and construct the project. The project agreements do not require Idaho Power to incur any costs to purchase its ownership interest or begin paying for capacity under the capacity entitlement agreement until the line is in service. Idaho Power has an option to purchase the ownership interest associated with such capacity entitlement upon expiration of the 40-year term.
Jackalope Wind Project: In October 2024, Idaho Power entered into agreements with a counterparty and certain of its affiliates to develop the Jackalope Project, which consists of (i) a 35-year PPA between Jackalope Wind, LLC and Idaho Power, supplying approximately 300 MW of generation to Idaho Power's system from a wind-powered generation facility located in Sweetwater County, Wyoming, and (ii) a co-located wind turbine generator power plant to be owned by Idaho Power, providing approximately 300 MW of generation. The capital requirements table above includes Idaho Power's share of the costs to develop and construct the project but does not include any of the expected costs of the PPA. As of the date of this report, Idaho Power expects the Jackalope Project to begin operations in 2027.
Defined Benefit Pension Plan Contributions
Idaho Power has no minimum contribution requirement to its defined benefit pension plan in 2024, and during the three months ended March 31, 2025, Idaho Power made no contributions. Idaho Power is considering contributing up to $30 million in a continued effort to balance the regulatory collection of these expenditures with the amount and timing of contributions, as well as to mitigate the cost of being in an underfunded position. The primary impact of pension contributions is on the timing of cash flows, as the timing of cost recovery lags behind contributions.
Contractual Obligations
IDACORP’s and Idaho Power’s contractual cash obligations have not materially changed during the three months ended March 31, 2025, except as disclosed in Note 5 – “Long-Term Debt” and Note 8 – “Commitments” to the condensed consolidated financial statements included in this report.
Dividends
The amount and timing of dividends paid on IDACORP’s common stock are within the discretion of IDACORP’s board of directors. IDACORP's board of directors reviews the dividend rate periodically to determine its appropriateness in light of IDACORP’s current and long-term financial position and results of operations, capital requirements, rating agency considerations, contractual and regulatory restrictions, legislative and regulatory developments affecting the electric utility industry in general and Idaho Power in particular, competitive conditions, and any other factors the board of directors deems relevant. The ability of IDACORP to pay dividends on its common stock is generally dependent upon dividends paid to it by its subsidiaries, primarily Idaho Power.
For additional information relating to IDACORP and Idaho Power dividends, including restrictions on IDACORP’s and Idaho Power’s payment of dividends, see Note 6 - “Common Stock” to the condensed consolidated financial statements included in this report.
Off-Balance Sheet Arrangements
IDACORP's and Idaho Power's off-balance sheet arrangements have not changed materially from those reported in the MD&A in the 2024 Annual Report.
REGULATORY MATTERS
Introduction
Idaho Power is under the jurisdiction (as to rates, service, accounting, and other general matters of utility operation) of the IPUC, the OPUC, and the FERC. The IPUC and OPUC determine the rates that Idaho Power is authorized to charge to its retail customers. Idaho Power is also under the regulatory jurisdiction of the IPUC, the OPUC, and the WPSC as to the issuance of debt and equity securities. As a public utility under the Federal Power Act, Idaho Power has authority to charge market-based rates for wholesale energy sales under its FERC tariff and to provide transmission services under its Open Access Transmission Tariff. Additionally, the FERC has jurisdiction over Idaho Power's sales of transmission capacity and wholesale electricity, hydropower project relicensing, and system reliability, among other items.
Idaho Power develops its regulatory filings taking into consideration short-term and long-term needs for rate relief and several other factors that can affect the structure and timing of those filings. These factors include in-service dates of major capital investments, the timing and magnitude of changes in major revenue and expense items, and customer growth rates, as well as other factors.
Idaho Power's most recently concluded general rate case in Idaho was resolved by the IPUC's approval of the 2023 Settlement Stipulation in December 2023 for rates that went into effect for Idaho-jurisdiction customers on January 1, 2024. In 2024, Idaho Power also filed a limited-issue rate case in Idaho, the 2024 Idaho Limited-Issue Rate Case, which the IPUC resolved through its order issued in December 2024 for rates that went into effect for Idaho-jurisdiction customers on January 1, 2025. Idaho Power's most recently concluded general rate case in Oregon was resolved by the OPUC's approval of settlement stipulations in September 2024 for rates that went into effect for Oregon-jurisdiction customers on October 15, 2024. Refer to Note 3 - "Regulatory Matters" to the consolidated financial statements included in the 2024 Annual Report for additional information relating to the 2023 Idaho general rate case, 2024 Idaho Limited-Issue Rate Case, and Oregon general rate case. In March 2025, Idaho Power provided notice to the IPUC of its intent to file a general rate case in Idaho on or after May 30, 2025.
Between general rate cases, Idaho Power relies upon customer growth, an FCA mechanism, power cost adjustment mechanisms, tariff riders, limited-issue rate proceedings, and other mechanisms to mitigate the impact of regulatory lag, which refers to the period of time between making an investment or incurring an expense and recovering that investment or expense and earning a return.
The outcomes of significant proceedings are described in part in this report and further in the 2024 Annual Report. In addition to the discussion below, which includes notable regulatory developments since the discussion of these matters in the 2024
Annual Report, refer to Note 3 - "Regulatory Matters" to the condensed consolidated financial statements included in this report for additional information relating to Idaho Power's regulatory matters and recent regulatory filings and orders.
Notable Pending Retail Rate or Revenue Changes
During 2025, Idaho Power has filed applications requesting orders authorizing the rate or revenue changes summarized in the table below.
| Description | Status | Estimated Impact(1) | Notes |
|---|---|---|---|
| PCA - Idaho | Filed April 15, 2025; pending | $94.8 million PCA decrease for the period from June 1, 2025 to May 31, 2026 | The income statement impact of revenue changes associated with the PCA mechanism is largely offset by associated increases and decreases in actual power supply costs and amortization of deferred power supply costs. The rate decrease primarily reflects a decrease in the balancing adjustment, which is due primarily to the completed recovery of the 2023 balancing adjustment, which was recovered over two years. |
| FCA - Idaho | Filed March 14, 2025; pending | $40.7 million FCA decrease for the period from June 1, 2025 to May 31, 2026 | The FCA is designed to remove a portion of Idaho Power’s financial disincentive to invest in energy efficiency programs by partially separating (or decoupling) the recovery of fixed costs from the volumetric kilowatt-hour charge and instead linking it to a set amount per customer. |
| APCU - Oregon | Filed March 24, 2025; pending | $1.1 million APCU decrease for the period from June 1, 2025 to May 31, 2026 | The rate decrease reflects a decrease in expected net power supply expense for the March 2025 APCU forecast combined with an increase in normalized net power supply expense for the October 2024 APCU. |
| HCC - Idaho | Filed March 14, 2025; pending | $29.7 million annual increase, effective June 1, 2025 | The requested adjustment is to increase cash collection of AFUDC associated with the HCC relicensing project. |
(1) The annual amount collected in rates is typically not recovered on a straight-line basis (i.e., 1/12th per month), and is instead recovered in proportion to retail sales volumes.
Idaho Earnings Support and Sharing from Idaho Settlement Stipulation
The 2018 Settlement Stipulation and the 2023 Settlement Stipulation are each described in Note 3 - "Regulatory Matters" to the consolidated financial statements included in the 2024 Annual Report. The 2023 Settlement Stipulation modified the 2018 Settlement Stipulation in part. IDACORP and Idaho Power believe that the terms allowing additional amortization of ADITC in the settlement stipulations provide the companies with a greater degree of earnings stability than would be possible without the terms of the stipulations in effect. Based on its estimate of full-year 2025 Idaho ROE, in the first quarter of 2025, Idaho Power recorded $19.3 million in additional ADITC amortization under the settlement stipulations.
Change in Deferred (Accrued) Net Power Supply Costs and the Power Cost Adjustment Mechanisms
Deferred (accrued) power supply costs represent certain differences between Idaho Power's actual net power supply costs and the costs included in its retail rates, the latter being based on annual forecasts of power supply costs. Deferred (accrued) power supply costs are recorded on the balance sheets for future recovery or refund through customer rates.
Idaho Power's power cost adjustment mechanisms in its Idaho and Oregon jurisdictions address the volatility of power supply costs and provide for annual adjustments to the rates charged to retail customers. The power cost adjustment mechanisms and associated financial impacts are described further in "Results of Operations" in this MD&A and in Note 3 - "Regulatory Matters" to the condensed consolidated financial statements included in this report.
With the exception of power supply expenses incurred under PURPA, expenses under export credit mechanisms, and certain demand response program costs that are passed through to customers substantially in full, the PCA mechanism allows Idaho Power to pass through to customers 95 percent of the differences in actual net power supply expenses as compared with base net power supply expenses, whether positive or negative. Thus, the primary financial statement impact of power supply cost deferrals or accruals is that the timing of when cash is paid out for power supply expenses differs from when those costs are recovered from customers, impacting operating cash flows from year to year.
The following table summarizes the change in deferred (accrued) net power supply costs during the three months ended March 31, 2025 (in millions).
| Idaho | Oregon | Total | |
|---|---|---|---|
| Balance at December 31, 2024 | $18.5 | $(3.9) | $14.6 |
| Current period net power supply costs (accrued) deferred | (29.4) | 2.7 | (26.7) |
| Prior amounts (collected) refunded through rates | (21.1) | 0.1 | (21.0) |
| Renewable energy credit sales | (19.6) | (0.8) | (20.4) |
| Interest and other | 0.1 | 0.1 | 0.2 |
| Balance at March 31, 2025 | $(51.5) | $(1.8) | $(53.3) |
Integrated Resource Plan and Resource Procurement Filings
Idaho Power filed its most recent IRP with the IPUC and OPUC in September 2023 and expects to file its next IRP in June 2025. The 2023 IRP, which was acknowledged by the IPUC in June 2024 and by the OPUC in August 2024, identified the need for resources to meet projected capacity deficits in the near-term.
In August 2024, the OPUC issued an order approving Idaho Power's final RFP to procure resources for its anticipated energy and capacity needs in 2028 and beyond. Idaho Power issued the RFP in August 2024 soliciting resources with a commercial operation date (COD) no later than April 1, 2028 (2028 bids), as well as bids with a COD after April 1, 2028 (beyond 2028 bids). In March 2025, the OPUC acknowledged the final shortlist of 2028 bids in the RFP, subject to certain conditions. Idaho Power has received and is currently evaluating beyond 2028 bids.
In December 2024, Idaho Power filed an application with the IPUC for the Jackalope Project, one of the bids from an RFP to procure resources for its anticipated energy and capacity needs in 2027. The Jackalope Project consists of (i) a 35-year PPA between Jackalope Wind, LLC and Idaho Power, supplying approximately 300 MW of generation to Idaho Power's system, and (ii) a wind turbine generator power plant to be owned by Idaho Power, providing approximately 300 MW of generation. In its application, Idaho Power requested that the IPUC approve the PPA and grant a CPCN for the wind turbine generator power plant. Several parties have intervened in this case. As of the date of this report, the case remains pending.
Also in December 2024, Idaho Power filed an application with the IPUC to grant a CPCN for Idaho Power to acquire and own two battery storage facilities with a total of 100 MW of operating capacity to address Idaho Power's identified capacity deficiency in 2026. As of the date of this report, the case remains pending. These battery storage facilities are in addition to the 150 MW of battery storage to be acquired and owned by Idaho Power for which the IPUC approved a CPCN in November 2024.
In March 2025, Idaho Power filed an application with the IPUC to grant a CPCN for Idaho Power to acquire an ownership interest, including the rights to 250 MW of northbound capacity, in SWIP-N, a planned 285-mile, high-voltage transmission line between the Robinson Summit Substation near Ely, Nevada, and the Midpoint Substation near Jerome, Idaho. In its application, Idaho Power also requested that the IPUC approve the company's utilization of an additional 250 MW of rights to northbound capacity on SWIP-N. As of the date of this report, the case remains pending.
In March 2025, Idaho Power filed an application with the IPUC for an order (1) approving the 20-year PPA with Crimson Orchard Solar LLC supplying the 100 MW output to Idaho Power, (2) approving the 20-year energy storage agreement (ESA) with Crimson Orchard Solar for 100 MW of dispatchable energy storage capacity, and (3) acknowledging the lease accounting necessary to facilitate the transaction and that the resulting expenses associated with both the PPA and the ESA are prudently incurred for ratemaking purposes. As of the date of this report, the case remains pending.
Large Customer Rate Proceedings
Brisbie, LLC (Brisbie) Data Center and Clean Energy Your Way Special Contract: In May 2023, the IPUC approved a special contract (Brisbie Special Contract) between Idaho Power and a large load customer, Brisbie, a wholly-owned subsidiary of Meta Platforms, Inc., for service to a new enterprise data center. The Brisbie Special Contract allows Idaho Power to procure enough renewable resources to provide Brisbie with 100 percent renewable energy on an annual basis for Brisbie's facility. In November 2024, Idaho Power filed for IPUC approval of a PPA for Brisbie with a 320 MW solar project to be online as early as December 2027. Idaho Power will assign the cost and renewable attributes of the energy from the solar facility to Brisbie in accordance with the Brisbie Special Contract. As of the date of this report, the IPUC's decision regarding the PPA is pending.
Micron Fab Special Contract: In December 2024, Idaho Power filed an application with the IPUC for approval of a special contract for electric service for Micron Idaho Semiconductor Manufacturing (Triton) LLC, a subsidiary of Micron, for electric service for Micron's new memory manufacturing fabrication complex located in Boise. The special contract anticipates a significant increase in load on Idaho Power's system that will ramp over a number of years beginning in 2026. Following the intervention of several parties, the IPUC directed IPUC staff to propose a schedule for the case, including a technical hearing. As of the date of this report, the case remains pending.
Relicensing of Hydropower Projects
HCC Relicensing: In connection with Idaho Power's major efforts to relicense the HCC, Idaho Power's largest hydropower complex, as described in more detail in the 2024 Annual Report in Part II, Item 7 - MD&A – "Liquidity and Capital Resources" and "Regulatory Matters," in July 2020, Idaho Power submitted to the FERC its supplement to the final license application, incorporating the settlement agreement reached between Idaho and Oregon on the CWA Section 401 certifications. The supplement included feedback on proposed modifications of the 2007 final EIS for the HCC, as well as an updated cost analysis of the HCC and a request that the FERC issue a 50-year license and initiate a supplemental NEPA process at the FERC. In June 2022, the FERC issued a notice of intent to prepare a supplemental EIS in accordance with NEPA. The FERC also reinstated informal consultation with the U.S. Fish and Wildlife Service and the National Marine Fisheries Service under section 7 of the Endangered Species Act. In April 2025, the FERC issued an updated schedule for the supplemental EIS with target dates for issuance of the draft and final supplemental EIS of September 2025 and May 2026, respectively.
Relicensing costs of $507 million (including AFUDC) for the HCC were included in construction work in progress at March 31, 2025. As of the date of this report, the IPUC authorizes Idaho Power to include in its Idaho jurisdiction rates approximately $8.8 million of AFUDC annually relating to the HCC relicensing project. Collecting these amounts currently will reduce future collections when HCC relicensing costs are approved for recovery in base rates. As of March 31, 2025, Idaho Power's regulatory liability for collection of AFUDC relating to the HCC was $257 million. As discussed above, on March 14, 2025, Idaho Power filed an application with the IPUC to increase the annual cash collection of AFUDC associated with relicensing of the HCC project by $29.7 million effective June 1, 2025. This application is still pending.
As of the date of this report, Idaho Power believes issuance of a new HCC license by the FERC will be in 2027 or thereafter. Idaho Power is unable to predict the exact timing that the FERC will issue a new license or the ultimate capital investment and ongoing operating and maintenance costs Idaho Power will incur in complying with a new license. Idaho Power estimates that the annual costs it will incur to obtain a new long-term license for the HCC, including AFUDC but excluding costs expected to be incurred for complying with the license after issuance, are likely to range from $35 million to $45 million until issuance of the license. Upon issuance of a long-term license, Idaho Power expects that the annual capital expenditures and operating and maintenance expenses associated with compliance with the terms and conditions of the long-term license could also be substantial. In December 2016, Idaho Power filed an application with the IPUC requesting a determination that Idaho Power's expenditures of $220.8 million through year-end 2015 on relicensing of the HCC were prudently incurred, and thus eligible for future inclusion in retail rates in a future rate proceeding. In April 2018, the IPUC issued an order approving a settlement stipulation signed by Idaho Power, the IPUC staff, and a third-party intervenor recognizing that a total of $216.5 million in expenditures were reasonably incurred, and therefore should be eligible for inclusion in customer rates at a later date.
American Falls Relicensing: In 2020, Idaho Power filed with the FERC a notice of intent to file an application to relicense the American Falls hydropower facility, which is Idaho Power's largest hydropower facility outside of the HCC, with a nameplate generating capacity of 92.3 MW and FERC authorized installed capacity of 67.5 MW. Idaho Power owns the generation facility but not the structural dam or reservoir, which are owned by the U.S. Bureau of Reclamation. Idaho Power filed the final relicensing application with the FERC in February 2023. In September 2023, Idaho Power filed an application for CWA Section 401 water quality certification with the Idaho Department of Environmental Quality. In September 2024, the Idaho Department of Environmental Quality issued a final CWA Section 401 water quality certification. In October 2024, FERC issued a revised notice of intent to prepare an environmental assessment, signaling that FERC staff did not anticipate that licensing the project would constitute a major federal action that would significantly affect the quality of the human environment. The FERC released its environmental assessment on January 16, 2025, which initiated a 30-day comment period. Three parties commented on the environmental assessment, and Idaho Power has responded to those comments.
Idaho Power's previous license at American Falls expired in February 2025. On March 3, 2025, the FERC issued Idaho Power an annual license on the same terms and conditions as its prior license. The annual license is effective until February 28, 2026, or until the FERC issues a new license for the American Falls facility. As of the date of this report, Idaho Power anticipates the FERC will issue a new license for this facility in 2025.
ENVIRONMENTAL MATTERS
Overview
Idaho Power is subject to a broad range of federal, state, regional, and local laws and regulations designed to protect, restore, and enhance the environment, including the Clean Air Act, the CWA, the Resource Conservation and Recovery Act, the Toxic Substances Control Act, the Comprehensive Environmental Response, Compensation and Liability Act, and the Endangered Species Act, among other laws. These laws are administered by a number of federal, state, and local agencies. In addition to imposing continuing compliance obligations and associated costs, these laws and regulations provide authority to regulators to levy substantial penalties for noncompliance, injunctive relief, and other sanctions. Idaho Power's co-owned coal-fired power plant, its co-owned coal- and gas-fired power plant, and its three wholly-owned natural gas-fired combustion turbine power plants are subject to many of these regulations. Idaho Power's hydropower projects are also subject to a number of water discharge standards and other environmental requirements.
Compliance with current and future environmental laws and regulations may:
increase the operating costs of generating plants;
increase the construction costs and lead time for new facilities;
require the modification of existing generating plants, which could result in additional costs;
require the curtailment, fuel-switching, or shut-down of existing generating plants;
reduce the output from current generating facilities; or
require the acquisition of alternative sources of energy or storage technology, increased transmission wheeling, or construction of additional generating facilities, which could result in higher costs.
Current and future environmental laws and regulations could significantly increase the cost of operating fossil fuel-fired generation plants and constructing new generation and transmission facilities, in large part through the substantial cost of permitting activities and the required installation of additional pollution control devices. In many parts of the United States, some higher-cost, high-emission coal-fired plants have ceased operation or the plant owners have announced a near-term cessation of operation or conversion to natural gas, as the cost of compliance makes coal plants uneconomical to operate. The decision to cease operation of the Boardman power plant in 2020 was based in part on the significant cost of compliance with environmental laws and regulations. The decision to end participation in coal-fired operations of one unit at the North Valmy plant was also based in part on the economics of continuing coal-fired generation at the plant. Beyond increasing costs generally, these environmental laws and regulations could affect IDACORP's and Idaho Power's results of operations and financial condition if the costs associated with these environmental requirements and early plant retirements cannot be fully recovered in rates on a timely basis.
Part I, Item 1 - "Business - Utility Operations - Environmental Regulation and Costs" in the 2024 Annual Report includes a summary of Idaho Power's expected capital and operating expenditures for environmental matters during the period from 2025 to 2027. Given the uncertainty of future environmental regulations and technological advances, Idaho Power cannot make near-term estimates with certainty and is also unable to predict its environmental-related expenditures beyond 2027, though they could be substantial.
A summary of notable environmental matters (including conditions and events associated with climate change) impacting, or expected to potentially impact, IDACORP and Idaho Power is included in Part II, Item 7 - MD&A - "Environmental Matters" and MD&A - "Liquidity and Capital Resources - Capital Requirements - Environmental Regulation Costs" in the 2024 Annual Report. Recent developments in certain environmental matters relevant to Idaho Power are described below.
EPA Proposed Regulatory Actions
In March 2025, the EPA announced a set of proposed regulatory actions relating to environmental laws and regulations, many of which will impact Idaho Power if they are implemented. The proposed regulatory actions relate to the following laws and regulations, among others: the EPA's 2009 endangerment finding regarding six greenhouse gases; the Clean Power Plan 2.0; the Mercury and Air Toxics Standards; the Greenhouse Gas Reporting Program; effluent limitations guidelines and standards for the Steam Electric Power Generating Industry; the National Ambient Air Quality Standards for Particulate Matter (PM2.5); the Regional Haze Program; the “Good Neighbor Plan” and related State Implementation Plans; the coal ash program; and the definition of "Waters of the United States," which impacts applicability of the CWA to certain wetlands and water bodies. The
EPA has not yet taken official action on any of these items. Idaho Power will continue to actively monitor these proposals and any other pending or potential environmental regulations related to environmental matters that may have an impact on its future operations. Given uncertainties regarding the outcome and timing for these EPA proposals, Idaho Power is unable to estimate the impact on Idaho Power of any such proposals.
National Environmental Policy Act Matters
NEPA is a federal law that requires federal agencies to consider the environmental impacts of their actions and decisions. NEPA applies to Idaho Power’s transmission and distribution lines that are located on federal land, as well as other company activities involving federal actions. The Council on Environmental Quality (CEQ) under previous Presidential Administrations had issued guidance to federal agencies in issuing their own regulations regarding the implementation of NEPA for projects under their jurisdiction. However, in November 2024, the DC Circuit Court of Appeals ruled that the CEQ lacks the authority to issue binding regulations implementing NEPA (Marin Audubon Society v. Federal Aviation Administration). Subsequently, the current Presidential Administration issued Executive Order 14154, which revoked the CEQ’s authority to issue NEPA regulations and directed the CEQ to rescind all NEPA regulations. As a result, the CEQ issued an interim final rule in February 2025 to remove all CEQ NEPA implementing regulations. The interim final rule became effective on April 11, 2025. The impact that revocation of the CEQ’s NEPA regulations will have on agency-specific NEPA procedures is unclear, and as a result, Idaho Power is unable to predict what impact these actions will have on Idaho Power and its operations.
OTHER MATTERS
Executive Orders of the Current Presidential Administration
Since the start of the current Presidential Administration in January 2025, the Administration has released several executive orders that may impact Idaho Power. These executive orders include, but are not limited to, orders regarding tariffs, the electric grid, the coal industry, revocation of executive orders of prior Presidential Administrations, and other orders intended to regulate international trade, strengthen the U.S. energy industry, and/or promote deregulation, including with respect to environmental and energy-related regulations. The outcome of these executive orders and U.S. federal agencies' review of regulations covered by executive orders is difficult to predict.
In addition, the court system has become more active in reviewing Presidential and agency actions, resulting in even less certainty as to the outcome and durability of rules that are administratively implemented. Changes to or elimination of regulations may lower Idaho Power's costs of operating and maintaining fossil fuel-fired generation plants and constructing transmission lines, due to the reduction of potential environmental infrastructure upgrades or conversions or reduction or elimination of permitting requirements. More strict or robust regulations, or additional regulations, such as tariffs on supplies and materials that Idaho Power purchases, on the other hand, would likely increase Idaho Power's costs of operating and maintaining its facilities, and could impact Idaho Power's plans and construction activities related to its capital projects, which could lead to substantially higher costs and delays in construction.
Executive orders may be affected by Congressional action. Further, state and local governmental authorities could choose to challenge or replace the federal regulations or bolster or undermine environmental compliance and enforcement efforts at the local level. Therefore, as of the date of this report, and except as specifically described in this MD&A, Idaho Power is uncertain whether and to what extent the orders, any new or future executive orders, and the implementation of these and any future executive orders could affect its business, results of operations, and financial condition. Idaho Power will continue to monitor actions associated with or resulting from executive orders and new or revised legislation or regulation.
Idaho Wildfire Standard of Care Act
In April 2025, Idaho enacted the Wildfire Standard of Care Act (Idaho Code § 61-1801 through 1808), which will become effective on July 1, 2025. The Act requires Idaho electric public utilities to prepare wildfire mitigation plans annually to mitigate wildfire risk, submit the plans to the IPUC for review and approval, and implement the plans upon IPUC approval. An electric utility's wildfire mitigation plan approved by the IPUC establishes the utility's duty to its shareholders and the public with respect to wildfire risk. For any civil action where wildfire-related damages are being sought against an electric utility, the Act establishes a rebuttable presumption that the utility acted without negligence if, with respect to the cause of the wildfire, the utility reasonably implemented an IPUC-approved wildfire mitigation plan. The rebuttable presumption extends to any act or omission taken in reasonable accordance with the approved wildfire mitigation plan in effect at the time the fire ignited, regardless of the content of any prior wildfire mitigation plans. The Act provides that, with certain exceptions, the remedies set out in the Act are the exclusive civil remedies available against an electric utility for damages resulting from any act or omission related to an IPUC-approved wildfire mitigation plan. The Act also permits electric utilities, upon certain conditions, to access privately-owned land or easements or rights-of-way on land owned by the state, a federal agency, or a tribal government for purposes of performing work in accordance with their approved wildfire mitigation plans. In addition, electric utilities may inspect, repair, or upgrade their assets, infrastructure, or facilities on such land and are protected from liability with respect to such access, subject to limitations set forth in the Act. Idaho Power intends to prepare an Idaho-specific WMP that integrates the requirements of the Act and to file the Idaho WMP with the IPUC after the Act becomes effective. The Act provides up to six months for the IPUC to review and approve a WMP after it is filed.
Critical Accounting Policies and Estimates
IDACORP's and Idaho Power's discussion and analysis of their financial condition and results of operations are based upon their condensed consolidated financial statements, which have been prepared in accordance with GAAP. The preparation of these financial statements requires IDACORP and Idaho Power to make estimates and judgments that affect the reported amounts of assets, liabilities, revenues, and expenses and related disclosure of contingent assets and liabilities. On an ongoing basis, IDACORP and Idaho Power evaluate these estimates, including those estimates related to rate regulation, retirement benefits, contingencies, asset impairment, income taxes, unbilled revenues, and the allowance for uncollectible accounts. These estimates are based on historical experience and on other assumptions and factors that are believed to be reasonable under the circumstances and are the basis for making judgments about the carrying values of assets and liabilities that are not readily apparent from other sources. IDACORP and Idaho Power, based on their ongoing reviews, make adjustments when facts and circumstances dictate.
IDACORP’s and Idaho Power’s critical accounting policies are reviewed by the audit committees of the boards of directors. These policies have not changed materially from the discussion of those policies included under "Critical Accounting Policies and Estimates" in the 2024 Annual Report.
Recently Issued Accounting Pronouncements
For discussion of new and recently adopted accounting pronouncements, see Note 1 - "Summary of Significant Accounting Policies" to the condensed consolidated financial statements included in this report.
The text of this filing, as the company filed it with the SEC, without its images or exhibits. This is not investment advice.