20250502Motion to Vacate and Reset Comment Deadlines.pdf

RECEIVED
May 2,2025
IDAHO PUBLIC
ADAM TRIPLETT UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR A ) CASE NO. IPC-E-24-45
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR TWO BATTERY ) MOTION TO VACATE AND
STORAGE FACILITIES ) RESET COMMENT DEADLINES
Staff of the Idaho Public Utilities Commission ("Staff'), by and through its attorney of
record, Adam Triplett, Deputy Attorney General, pursuant to Commission Rules of Procedure
("Rule") 056, 123, 256, and 322 IDAPA 31.01.01 et seq., does hereby move for an Order: 1)
vacating the existing May 7, 2025, public comment deadline and May 28, 2025, company reply
deadline established in Order No. 36569; and 2)resetting them to June 11,2025, and July 2, 2025,
respectively.
BACKGROUND
On December 27, 2024, Idaho Power Company applied for a Certificate of Public
Convenience and Necessity ("CPCN") for two dispatchable battery facilities providing a total of
100 megawatts ("MW") of operating capacity.
On February 3, 2025, the Commission issued a Notice of Application and Notice of
Intervention Deadline, setting a deadline for interested parties to intervene. Order No. 36454. The
MOTION TO VACATE AND
RESET COMMENT DEADLINES 1 May 2, 2025

Industrial Customers of Idaho Power, Idaho Irrigation Pumpers Association, Inc., and Micron
Technology, Inc. intervened. Order Nos. 36485 & 36492.
On April 23, 2025, the Commission issued a Notice of Modified Procedure, establishing a
May 7, 2025,public comment deadline and a May 28, 2025, Company reply deadline.
MOTION TO VACATE AND RESET COMMENT DEADLINES
On May 1, 2025, the Company informed Staff that recent increases in U.S. government
tariffs on goods imported from China will affect the cost of the battery facilities involved in this
case. Currently, goods imported into the United States from China are subject to a 145% rate of
duty. See Exec. Order No. 14266, 90 Fed. Reg. 15625 (April 9,2025). Because components of the
Company's proposed battery facilities will be imported from China, the increased tariff will affect
the final cost of these facilities. Moreover, according to the Company's estimates,the final cost of
these facilities will be substantially higher if the current tariff remains in place. Staff cannot
evaluate and provide meaningful comments on the impact of this estimated cost increase by the
current May 7, 2025, deadline for its comments. Accordingly, Staff respectfully requests that the
Commission vacate that comment deadline and reset it for June 11, 2025. Staff believes this will
provide sufficient time to conduct discovery, thoroughly examine the tariff issue, and submit
informed comments on the anticipated cost increase associated with the proposed battery facilities.
If the Commission grants Staff s request to vacate and reset the public comment deadline,
Staffs comments would come after the Company's current reply comment deadline of May 28,
2025. To give the Company an opportunity to reply to Staff and public comments, Staff requests
that the Commission vacate the existing Company reply comment deadline and reset it for July 2,
2025. This will provide the Company with the same 21-day response period established by the
current comment deadlines.
Staff provided actual notice of the substance of this Motion to the Company by email on
May 2, 2025. Due to the looming May 7, 2025, public comment deadline, immediate review of
this motion is warranted. Accordingly, factual circumstances enable the Commission to consider
this Motion and offer the relief requested on fewer than 14 days'notice. Rule of Procedure 256.03,
IDAPA 31.01.01.256.03. Additionally, because this motion seeks only procedural relief, it is not
necessary to wait two days for the parties to state their positions on this motion.Accordingly, Staff
request that the Commission consider this motion during its May 6, 2025, decision meeting.
MOTION TO VACATE AND
RESET COMMENT DEADLINES 2 May 2, 2025

CONCLUSION
Staff respectfully request that the Commission issue an Order 1)vacating the existing May
7, 2025, public comment and May 28, 2025, company reply deadlines established in Order No.
36569; and 2)resetting them to June 11, 2025, and July 2, 2025, respectively.
DATED at Boise, Idaho, this 2nd day of May 2025.
Adam Triplett
Deputy Attorney General
MOTION TO VACATE AND
RESET COMMENT DEADLINES 3 May 2, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE ON THIS 2ND DAY OF MAY 2025, SERVED THE
FOREGOING MOTION TO VACATE AND RESET COMMENT DEADLINES, IN CASE
NO. IPC-E-24-45, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
Donovan E. Walker Tim Tatum
Idaho Power Company Idaho Power Company
PO Box 70 PO Box 70
Boise, ID 83707-0070 Boise, ID 83707-0070
dwalker(c�r�,idahopower.com ttatum(c�r�,idahopower.com
dockets a,idahopower.com
Peter J. Richardson Dr. Don Reading
Richardson Adams, PLLC 280 S. Silverwood Way
515 N. 27th St. Eagle, ID 83716
Boise, ID 83702 [e-mail]
peter(krichardsonadams.com
Austin Rueschhoff Eric L. Olsen
Thorvald A. Nelson Echo Hawk& Olsen, PLLC
Austin W. Jensen P.O. Box 6119
Kristine A.K. Roach 505 Pershing Ave., Ste. 100
Holland& Hart, LLP Pocatello, ID 83205
555 17�' St., Ste. 3200 [e-mail]
Denver, CO 80202
darueschhoff(a hollandhart.com Lance Kaufman, Ph.D.
tnelson(a,hollandhart.com 2623 NW Bluebell Place
[e-mail] Corvallis, OR 97330
karoach(a),hollandhart.com lance(a),ae isg insi hg t.com
[e-mail]
Keri J. Ha ker
Assistant to Adam Triplett
L LegahELECTRICUPC-E-24-45_CPCN�CE2445_Mtn atdoex
MOTION TO VACATE AND
RESET COMMENT DEADLINES 4 May 2, 2025