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Home My WebLink About20241216Application for Intervenor Funding.pdf RECEIVED Monday, December 16, 2024 Eric L. Olsen(ISB#4811) IDAHO PUBLIC ECHO HAWK& OLSEN, PLLC UTILITIES COMMISSION 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 Telephone: (208) 478-1624 Facsimile: (208)478-1670 Email: elo(a)echohawk.com Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION CASE NO. IPC-E-24-07 OF IDAHO POWER COMPANY TO INCREASE RATES FOR ELECTRIC APPLICATION FOR INTERVENOR SERVICE TO RECOVER COSTS FUNDING OF THE IDAHO ASSOCIATED WITH INCREMENTAL IRRIGATION PUMPERS CAPITAL INVESTMENTS AND CERTAIN ASSOCIATION,INC. ONGOING OPERATIONS AND MAINTENANCE EXPENSES COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("IIPA"), by and through counsel of record, Echo Hawk & Olsen, PLLC, and hereby respectfully makes application to the Idaho Public Utilities Commission ("Commission") for intervenor funding, pursuant to Idaho Code § 61-617A and IDAPA §§ 31.01.01.161 through .165, in this case, as follows: (A) A summary of the expenses that the IIPA request to recover broken down into legal fees, witness fees and other costs and expenses is set forth in Exhibit A attached hereto and incorporated by reference. (B) The IIPA's Counsel, Eric L. Olsen of Echo Hawk & Olsen ("Mr. Olsen") and its Expert witness Lance D. Kaufman, Ph.D. ("Dr. Kaufman") participated in Idaho Power Company's("IPC")rate case. Mr. Olsen and Dr. Kaufman prepared and served written discovery, reviewed and analyzed the various parties' positions, and attended and participated in person and via video conference in the various unsuccessful settlement conferences ("Settlement APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 1 CASE NO.IPC-E-24-07 Conferences") held on September 30th, October 1st, October 81h and personally attended and actively participated in the technical hearings ("Technical Hearings") just recently held on December 91h and December 10th, 2024. Dr.Kaufinan's review efforts focused on cost of service,rate spread,rate base, depreciation expense, labor expense and revenues. Dr. Kaufman recommended that the increase in rates IPC requests should be spread uniformly across all rate classes because of the imprecise nature of IPC's cost of service study, the fact that greater weight should be placed on IPC's winter demand, and that it appears that all customer classes are within plus or minus 5% of IPC suggested cost of service. IIPA also presented evidence at the technical hearing that at least 50%of the costs sought to be recovered were the direct result of increased demand for the residential and large customer classes. Thus, it is also reasonable to spread IPC's associated increase uniformly so that growth is more equitably borne by the growing classes. To follow the accounting principal of matching period revenues with period expenses, Dr. Kaufman recommended that a forecasted 2024 13-month average from December 2023 through December 2024 and adjusted rate base, depreciation and labor expense. Dr. Kaufman also recommended that IPC account for all based revenues and not just its incremental revenues associated with rate base and labor. IPC also adopted a portion of Dr. Kaufman's revenue adjustments in Matthew Larkin's rebuttal testimony. The total of Dr. Kaufman's adjustments reduced IPC's revenue deficiency from initially requested $99.3 million to approximately $40.3 million. (C) The expenses and costs incurred by the IIPA set forth in Exhibit A are reasonable in amount and were necessarily incurred. The expenses and costs were incurred in participating in APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 2 CASE NO.IPC-E-24-07 the technical hearings and settlement conferences. Without incurring these expenses and costs, IIPA would not have been able to fully participate in this matter. (D) The costs described in Exhibit A constitute a financial hardship for the IIPA. The IIPA is an Idaho nonprofit corporation qualified under I.R.C. § 501(c)(5) representing farm interests in electric utility rate matters affecting farmers in southern and central Idaho. The IIPA relies solely upon dues and contributions voluntarily paid by members, together with intervenor funding, to support its activities. Each year mailings are sent to approximately 7,000 Idaho Irrigators (approximately one-third in the IPC service area and the remainder in IPC's service area), soliciting annual dues. IIPA recommends members make voluntary contributions based on acres irrigated or horsepower per pump. Member contributions have been falling which is believed to be attributable to increased operating costs and declining commodity prices. From member contributions the IIPA must pay all expenses, which generally include mailing expenses, meeting expenses, post office box, in addition to the expenses relating to participation in matters before the Commission. The Executive Director, Amy McKoon, is the only part-time paid contractor, receiving a retainer plus expenses for office space, office equipment, and secretarial services. Other IIPA officers and directors are elected annually and serve without compensation. It has been and continues to be a financial hardship for the IIPA to fully participate in important cases such as this one due to the time and expense that must be incurred to fully participate in such a case. Because of the IIPA's financial constraints, participation in this case, preparing to file testimony, and participating in the settlement negotiations has been focused and prudent. APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 3 CASE NO.IPC-E-24-07 (E) IIPA's recommendation of a 2024 13-month average from December 2023 through December 2024 rate base and associated depreciation, labor expense, and revenue adjustments resulting in $40.3 million revenue deficiency materially differed from Staff s recommendations resulting in a recommended $8.9 deficiency. No other parry presented evidence at the technical hearing that at least 50% of the costs sought to be recovered were the direct result of increased demand for the residential and large customer classes. As such,the issues that the IIPA raised and urged to be adopted by the Commission in the Technical hearings materially differed from those addressed by the Staff and other parties. (F) The IIPA's participation addressed issues of concern to the general body of users or consumers on IPC's system in that the Irrigator adjustments adopted in the Stipulation reduced the proposed rate increase for all customer classes. (G) The IIPA represents the irrigation class of customers under Schedule 10 on IPC's system. Based on the foregoing, it is respectfully submitted that the IIPA is a qualifying intervenor and should be entitled to an award of costs of intervention in the maximum amount allowable pursuant to Idaho Code § 61-617A and IDAPA §§ 31.01.01.161 through .165. DATED this 16th day of December, 2024. ECHO K& OLSEN ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 4 CASE NO.IPC-E-24-07 CERTIFICATE OF SERVICE I HEREBY CERTIFIY that on this 16th day of December, 2024, I served a true, correct and complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to Intervene to each of the following, via U.S. Mail or private courier, email or hand delivery, as indicated below: Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail Idaho Public Utilities Commission ❑ Hand Delivered P.O. Box 83720 ❑ Overnight Mail Boise, ID 83720-0074 ❑ Telecopy(Fax) monica.barriossanchez(&puc.idaho.gov ® Electronic Mail (Email) Chris Burdin ❑ U.S. Mail Deputy Attorney General ❑ Hand Delivered Idaho Public Utilities Commission ❑ Overnight Mail P.O. Box 83720 ❑ Telecopy(Fax) Boise, ID 83720-0074 ® Electronic Mail (Email) chris.burdingpuc.Idaho.gov Lisa D. Norstrom ❑ U.S. Mail Donovan E. Walker ❑ Hand Delivered Megan Goicoechea Allen ❑ Overnight Mail Idaho Power Company ❑ Telecopy(Fax) 1221 W. Idaho Street(83702) ® Electronic Mail (Email) PO Box 70 Boise, ID 83707-0070 lnordstrom(a,idahopower.com dwalkergidahopower.com mgoicoecheaallen(a�idahopower.com dockets(c-r�,idahopower.com Tim Tatum ❑ U.S. Mail Connie Aschenbrenner ❑ Hand Delivered Matt Larkin ❑ Overnight Mail Idaho Power Company ❑ Telecopy(Fax) 1221 W. Idaho Street(83702) ® Electronic Mail (Email) PO Box 70 Boise, ID 83707-0070 ttatum(a,idahopower.com caschenbrennergidahopower.com mlarkin(a),idahopower.com APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 5 CASE NO.IPC-E-24-07 Lance Kaufman, Ph.D. ❑ U.S. Mail Idaho Irrigation Pumpers Association, Inc. ❑ Hand Delivered 2623 NW Bluebell Place ❑ Overnight Mail Corvallis, OR 97330 ❑ Telecopy(Fax) lance@ae isg insi hg t.com ® Electronic Mail (Email) Peter J. Richardson ❑ U.S. Mail Richardson, Adams, PLLC ❑ Hand Delivered Industrial Customer of Idaho Power ❑ Overnight Mail 515 N. 27th St. ❑ Telecopy(Fax) P.O. Box 7218 ® Electronic Mail (Email) Boise, ID 83702 12eter@richardsonadams.com Dr. Don Reading ❑ U.S. Mail Industrial Customer of Idaho Power ❑ Hand Delivered 280 S. Silverwood Way ❑ Overnight Mail Eagle, ID 83616 ❑ Telecopy(Fax) dreading(&mindspring com ® Electronic Mail (Email) Matthew Nykiel ❑ U.S. Mail Attorney for Idaho Conservation League ❑ Hand Delivered 710 N. 6th St. ❑ Overnight Mail Boise, ID 83702 ❑ Telecopy(Fax) matthew.pykiel@gmail.com ® Electronic Mail (Email) Adrian Gallo, Climate Manager ❑ U.S. Mail Brad Smith, Program Director ❑ Hand Delivered Idaho Conservation League ❑ Overnight Mail 710 N. 6th St. ❑ Telecopy(Fax) Boise, ID 83702 ® Electronic Mail (Email) aaagalloC&,idahoconservation.org bsmithh@idahoconservation.org Peter Meier ❑ U.S. Mail U.S. Department of Energy ❑ Hand Delivered 1000 Independence Ave., S.W. ❑ Overnight Mail Washington, D.C. 20585 ❑ Telecopy(Fax) peter.meier(c�r�,hd.doe.gov ® Electronic Mail (Email) APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 6 CASE NO.IPC-E-24-07 Emily W. Medlyn ❑ U.S. Mail U.S. Department of Energy ❑ Hand Delivered 1000 Independence Ave., S.W. ❑ Overnight Mail Washington, D.C. 20585 ❑ Telecopy(Fax) Emily.medlynghq.doe. og_v ® Electronic Mail (Email) Jim Swier ❑ U.S. Mail Micron Technology, Inc. ❑ Hand Delivered 8000 South Federal Way ❑ Overnight Mail Boise, ID 83707 ❑ Telecopy(Fax) jswiergmicron.com ® Electronic Mail (Email) Austin Rueschhoff ❑ U.S. Mail Thorvald A. Nelson ❑ Hand Delivered Austin W. Jensen ❑ Overnight Mail Kristine A.K. Roach ❑ Telecopy(Fax) Holland& Hart, LLP ® Electronic Mail (Email) Micron Technology, Inc. 555 17th Street Suite 3200 Denver, CO 80202 darueschhoff(a,hollandhart.com tnelson(a,hollandhart.com awj ensen(&hollandhart.com karoach&hollandhart.com aclee(a,hollandhart.com mamcillenkhollandhart.com Ed Jewell ❑ U.S. Mail Deputy City Attorney ❑ Hand Delivered Boise City Attorney's Office ❑ Overnight Mail 150 N. Capitol Blvd. ❑ Telecopy(Fax) PO Box 500 ® Electronic Mail (Email) Boise, ID 83701-0500 eiewell&cityofboise.org boisecityattomey(a,cityofboise.org Steven Hubble ❑ U.S. Mail Climate Action Senior Manager ❑ Hand Delivered Boise City Dept. of Public Works ❑ Overnight Mail 150 N. Capitol Blvd. ❑ Telecopy(Fax) P.O. Box 500 ❑ Electronic Mail (Email) Boise, ID 83701-0500 shubble(a),cityofboise.org APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 7 CASE NO.IPC-E-24-07 z2t�' �� ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 8 CASE NO.IPC-E-24-07 EXHIBIT A Expert Witness,Lance Kaufman, Expenses: 1. Witness Fees: 151.33 Hours @ $250= $37,833.33 2. Witness Travel Costs 11.67 Hours @ 125 = $ 1,458.33 3. Soft Costs (Airfare and Parking) $ 539.96 Sub Total: $39,831.62 Legal Expenses: 1. Paralegal Fees: 16.4 Hours @ $155 = $ 2,542.00 2. Legal Fees Eric L. Olsen: 84.6 Hours @ $250 = $21,150.00 3. Soft Costs (Copies/Postage/Hotel) $ 757.68 Sub Total: $24,449.68 Grand Total: $64,281.30 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. Page 9 CASE NO.IPC-E-24-07