20250121Application for Intervenor Funding.pdf

RECEIVED
2025 January 21
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: [phone]
Facsimile: [phone]
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. PAC-E-24-04
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS RATES APPLICATION FOR INTERVENOR
AND CHARGES IN IDAHO AND FUNDING OF THE IDAHO
APPROVAL OF PROPOSED ELECTRIC IRRIGATION PUMPERS
SERVICE SCHEDULES AND ASSOCIATION,INC.
REGULATIONS
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators"), 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 Irrigators 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 Irrigators' Counsel, Eric L. Olsen of Echo Hawk & Olsen ("Mr. Olsen") and
Irrigators' witness Lance D. Kaufman, Ph.D ("Dr. Kaufman") participated in these proceedings.
Mr. Olsen and Dr. Kaufman prepared and served written discovery, reviewed and analyzed the
various parties' positions, and attended via video conference in the settlement/technical
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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CASE NO.PAC-E-24-04

conferences ("Settlement Conferences") held between the staff and intervenors and the staff,
intervenors and PacifiCorp on October 22 & 24, 2024 and November 19 & 21, 2024.
As a result of the Settlement Discussions, the parties entered into a Settlement Stipulation
which was filed with the Commission on December 6, 2024. Dr. Kaufman's efforts that were not
inclusive of Staff s efforts included the removal of the rate base and depreciation expense
associated with Labor Day Wildfire restoration,the removal of the amounts attributable to wildfire
injuries and legal damages awarded against PacifiCorp, and proposed changes to PacifiCorp's
capital structure. These adjustments would have resulted in a reduction in the Idaho revenue
requirement of approximately $11,796.399. As a signatory, IIPA believes that the Settlement
Stipulation and the resulting proposed revenue requirement and new rates are fair, just and
reasonable resolution to issues addressed therein.
(C) The expenses and costs incurred by the Irrigators set forth in Exhibit A are
reasonable in amount and were necessarily incurred. The expenses and costs were incurred in
participating in the Settlement Conferences, in the drafting and review discovery responses, and
negotiating the final terms of the Stipulation, and preparing brief testimony in support of the
Settlement Stipulation. Without incurring these expenses and costs, the Irrigators would not have
been able to fully participate in this matter.
(D) The costs described in Exhibit A constitute a financial hardship for the Irrigators.
The Irrigators are 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
Irrigators rely 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 Rocky Mountain Power service area), soliciting
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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CASE NO.PAC-E-24-04

annual dues. The Irrigators recommend 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 Irrigators 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 Irrigator officers and directors are elected annually and
serve without compensation.
It has been and continues to be a financial hardship for the Irrigators 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 Irrigators' financial constraints,participation in this case,
preparing to file testimony, and participating in the settlement negotiations has been focused and
prudent.
(E) Dr.Kaufinan's efforts that were not inclusive of Staff s efforts included the removal
of the rate base and depreciation expense associated with Labor Day Wildfire restoration, the
removal of the amounts attributable to wildfire injuries and legal damages awarded against
PacifiCorp, and proposed changes to PacifiCorp's capital structure. These adjustments materially
differed from those raised by Commission Staff and other parties and would have resulted in a
reduction in the Idaho revenue requirement of approximately $11,796.399.
(F) The Irrigators' participation addressed issues of concern to the general body of
users or consumers on Rocky Mountain Power's system in that the Irrigator adjustments adopted
in the Stipulation reduced the proposed rate increase for all customer classes.
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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CASE NO.PAC-E-24-04

(G) The Irrigators represent the irrigation class of customers under Schedule 10 on
Rocky Mountain Power's system.
Based on the foregoing, it is respectfully submitted that the Irrigators are 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 22nd day of January, 2025.
ECHO HAWK& OLSEN
ERIC L. OLSEN
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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CASE NO.PAC-E-24-04

CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 22nd day of January, 2025, 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)
Mark Alder ❑ U.S. Mail
Michael Snow ❑ Hand Delivered
Idaho Regulatory Affairs Manager ❑ Overnight Mail
PacificCorp/Rocky Mountain Power ❑ Telecopy(Fax)
1407 WN Temple Ste 330 ® Electronic Mail (Email)
Salt Lake City,UT 84116
mark.alderkpacificorp.com
michael.snowgpacificorp.com
Data Request Response Center ❑ U.S. Mail
PacifiCorp ❑ Hand Delivered
825 NE Multnomah, Ste 2000 ❑ Overnight Mail
Portland, OR 97232 ❑ Telecopy(Fax)
datarequestkl2acificorp.com ® Electronic Mail (Email)
Joseph Dallas (ISB #10330) ❑ U.S. Mail
Carla Scarsella ❑ Hand Delivered
PacificCorp/Rocky Mountain Power ❑ Overnight Mail
825 NE Multnomah, Suite 2000 ❑ Telecopy(Fax)
Portland, OR 97232 ® Electronic Mail (Email)
„joseph.dallas(i pacificorp.com
carla.scars ellagpacificorp.com
Adam Triplett ❑ U.S. Mail
Deputy Attorney General ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
P.O. Box 83720 ❑ Telecopy(Fax)
Boise, Idaho 83720-0074 ® Electronic Mail (Email)
[e-mail]
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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CASE NO.PAC-E-24-04

Lane Kaufman, Ph.D. ❑ U.S. Mail
Idaho Irrigation Pumpers Association, Inc. ❑ Hand Delivered
2623 NW Bluebell Place ❑ Overnight Mail
Corvallis, OR 97330 ❑ Telecopy(Fax)
lane@ae isg insi h� ® Electronic Mail (Email)
Mike Veile ❑ U.S. Mail
Bayer Corporation ❑ Hand Delivered
P4 Production, L.L.C. ❑ Overnight Mail
P.O. Box 816 ❑ Telecopy(Fax)
Soda Springs, ID 83276 ® Electronic Mail (Email)
mike.veile(&bayer.com
Thomas J. Budge ❑ U.S. Mail
Bayer Corporation ❑ Hand Delivered
Racine Olsen, PLLP ❑ Overnight Mail
P.O. Box 1391 ❑ Telecopy(Fax)
Pocatello, ID 83204-1391 ® Electronic Mail (Email)
ti(&,racineolson.com
Brian C. Collins ❑ U.S. Mail
Greg Meyer ❑ Hand Delivered
Bayer Corporation ❑ Overnight Mail
Brubaker&Associates ❑ Telecopy(Fax)
16690 Swingley Ridge Rd., #140 ® Electronic Mail (Email)
Chesterfield, MO 63017
bcollins(&,consultbai.com
[e-mail]
Kevin Higgins ❑ U.S. Mail
Neal Townsend ❑ Hand Delivered
Bayer Corporation ❑ Overnight Mail
Energy Strategies LLC ❑ Telecopy(Fax)
I I I East Broadway Suite 1200 ® Electronic Mail (Email)
Salt Lake City, UT 84111
[e-mail]
ntownsend(&,energystrat.com
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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CASE NO.PAC-E-24-04

Matthew Nykiel ❑ U.S. Mail
Attorney for Idaho Conservation League ❑ Hand Delivered
710 N. 61h St. ❑ Overnight Mail
Boise, ID 83702 ❑ Telecopy(Fax)
matthew.n, k elggmail.com ® Electronic Mail (Email)
Brad Heusinkveld ❑ U.S. Mail
Idaho Conservation League ❑ Hand Delivered
Regulatory Counsel ❑ Overnight Mail
710 N. 61h St. ❑ Telecopy(Fax)
Boise, ID 83702 ® Electronic Mail (Email)
bheusinkveldgidahoconservation.org
Ronald L. Williams ❑ U.S. Mail
Brandon Helgeson ❑ Hand Delivered
PacifiCorp Idaho Industrial Customers ❑ Overnight Mail
Hawley Troxell Ennis & Hawley LLP ❑ Telecopy(Fax)
P.O. Box 1617 ® Electronic Mail (Email)
Boise, ID 83701
rwilliams khawleytroxell.com
bhel eg songhawleytroxell.com
Bradley Mullins ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
MW Analytics ❑ Overnight Mail
Teitotie 2, Suite 208 ❑ Telecopy(Fax)
Oulunsalo Finland, FI-90460 ® Electronic Mail (Email)
brmullinsgmwanalytics.com
Val Steiner ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
Itafos Conda, LLC ❑ Overnight Mail
val.steiner(a�itafos.com ❑ Telecopy(Fax)
❑ Electronic Mail (Email)
Kyle Williams ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
BYU Idaho ❑ Overnight Mail
williamskA,byui.edu ❑ Telecopy(Fax)
® Electronic Mail (Email)
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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CASE NO.PAC-E-24-04

,� P�V�-
ERIC L. OLSEN
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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CASE NO.PAC-E-24-04

EXHIBIT A
Expert Witness,Lance Kaufman, Expenses:
1. Witness Fees: 53.75 Hours @ $250= $13,437.50
Legal Expenses:
1. Paralegal Fees: 14.2 Hours @ $155 = $ 2,201.01
2. Legal Fees Eric L. Olsen: 45.6 Hours @ $250 = $ 11,400.00
3. Soft Costs (Copies) $ 66.75
4. Hard Costs (Hotel for Hearing) $ 141.37
Sub Total: $ 13,809.13
Grand Total: S 27,246.63
APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.
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