Mail Stop 3561
May 23, 2006
Mr. Jan B. Packwood
President and Chief Executive Officer
IDACORP, Inc.
1221 W. Idaho Street
Boise, Idaho 83702-5627
RE: IDACORP, Inc.
Form 10-K for Fiscal Year Ended December 31, 2005
Form 10-Q for Fiscal Quarter Ended March 31, 2006
File No. 1-14465
Idaho Power Company
Form 10-K for Fiscal Year Ended December 31, 2005
Form 10-Q for Fiscal Quarter Ended March 31, 2006
File No. 1-3198
Dear Mr. Packwood:
We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents. Where indicated, we think you should
revise your disclosures in future filings in response to these
comments. If you disagree, we will consider your explanation as
to
why our comment is inapplicable or a revision is unnecessary.
Please
be as detailed as necessary in your explanation. In some of our
comments, we may ask you to provide us with information so we may
better understand your disclosure. After reviewing this
information,
we may raise additional comments.
Please understand that the purpose of our review process
is
to assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Form 10-K for Fiscal Year Ended December 31, 2005
General
1. In future filings, please paginate all of your filed documents.
Please refer to General Instruction B to Form 10-K and Exchange
Act
Rule 17 CFR 240.0-3.
Item 6. Selected Financial Data
2. In future filings, please revise to provide footnotes which
explain how each of the ratios you have presented under the
caption
Financial Statistics are computed.
Item 7. Management`s Discussion and Analysis
3. In future filings, please revise to provide a discussion of the
other operating revenues and expenses of the unregulated
businesses
and the other segment.
Financial Statements
Consolidated Statement of Operations
4. In future filings, please disclose the components of other non-
operating income and expenses in the notes to your financial
statements.
Note 1. Summary of Significant Accounting Policies
Principles of Consolidation
5. Please tell us why the CSPP facilities and all four Ida West
plants that sell 100% of their generation to IPC are not
consolidated
under FIN 46(R). It appears that only one of the Ida West plants
has
been consolidated. Please refer to the criteria for determining
whether these entities are variable interest entities and whether
you
are the primary beneficiary in preparing your response. If you
are
not consolidating these entities because of the condition in
paragraph 4(g) of FIN 46(R), whereby you are unable to obtain the
information required to apply this Interpretation after exhaustive
efforts, please provide in your response and disclose in future
filings all of the additional disclosures required related to VIEs
not consolidated.
Earnings Per Share
6. In future filings, please provide a reconciliation of the
numerators and the denominators of the basic and diluted per-share
computations for each period for which a statement of operations
has
been provided. Please disclose how restricted shares are treated
in
computing earnings per share. Refer to FAS 128, paragraph 40.
Note 10. Benefit Plans
7. Please explain to us how you calculate the market related value
of
plan assets as that term is defined in SFAS 87. Since there is an
alternative to how you can calculate this item, and it has a
direct
effect on pension expense, we believe you should disclose in
future
filings how you determine this amount in accordance with paragraph
12
of APB 22.
Note 12. Segment Information
8. Please tell us and disclose in future filings the operating
segments that are aggregated in the other segment. Please tell us
why you believe aggregation of these segments is appropriate.
Refer
to the guidance in EITF 4-10.
Note 16. Investments
9. It appears that your investment in Bridger Coal Company is
material to your results of operations. In future filings, please
present summarized financial information required by paragraph
20(d)
of APB 18 or tell us why presentation of summarized financial
information is not necessary.
Schedule II Consolidated Valuation and Qualifying Accounts
10. Please tell us and disclose in future filings how the credits
to
the provision for uncollectible accounts reflected in your
Consolidated Statements of Cash Flows have been treated in
Schedule
II.
Form 10-Q for the Quarterly Period Ended March 31, 2006
11. The comments above should be addressed in future filings on
Form
10-Q to the extent applicable.
As appropriate, please respond to these comments within
10
business days, or tell us when you will provide us with a
response.
Please key your responses to our comments and provide any
requested
information. Detailed letters greatly facilitate our review.
Please
understand that we may have additional comments after reviewing
your
responses to our comments.
We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision. Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.
In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.
You may contact Sondra Snyder at (202) 551-3332, or in
her
absence, William Thompson at (202) 551-3344 if you have questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 551-3843 with any other questions.
Sincerely,
George F. Ohsiek, Jr.
Branch Chief
Mr. Jan Packwood
IDACORP, Inc.
May 23, 2006
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