20250529Comments.pdf

RECEIVED
Eric L. Olsen(ISB#4811) May 29, 2025
ECHO HAWK& OLSEN, PLLC IDAHO PUBLIC
505 Pershing Ave., Ste. 100 UTILITIES COMMISSION
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 IDAHO POWER CASE NO. IPC-E-25-03
COMPANY FOR APPROVAL OF THE
NORTH VALMY POWER PLANT IDAHO IRRIGATION PUMPERS
NATURAL GAS CONVERSION ASSOCIATION, INC.'S WRITTEN
AGREEMENT WITH NV ENERGY COMMENTS
I Idaho Irrigation Pumpers, Inc., by and through counsel, hereby submits its Written
2 Comments to Idaho Power Company's Application seeking a CPCN to repower the North Valmy
3 Power Plant,pursuant to Commission Rule 225, as follows:
4 Q. PLEASE STATE YOUR NAME,ADDRESS,AND EMPLOYMENT.
5 A. My name is Deborah Glosser. I am serving as a consultant for Lance Kaufman/Western
6 Economics, LLC at 2623 NW Bluebell Dr, Corvallis, Oregon, 97330.
7 Q. WOULD YOU BRIEFLY DESCRIBE YOUR EDUCATIONAL BACKGROUND
8 AND PROFESSIONAL EXPERIENCE?
9 A. I earned a PhD in Civil Engineering with a focus in Materials from Oregon State
10 University in 2020, an MS in Geophysics from the University of Pittsburgh in 2013, and
11 a JD from Duquesne University in 2005. Since 2020, I have been an Assistant Professor
12 at Western Washington University in Bellingham, with appointments in the Institute for
13 Energy Studies, Engineering and Design, and the Advanced Materials Science and
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page I
CASE NO.IPC-E-25-03

I Engineering Center. I was recently awarded tenure and will return next year as an
2 Associate Professor. My research group develops thermal energy storage materials for
3 solar thermal energy power. I teach courses at Western in the areas of energy storage
4 materials, mechanics of materials, energy policy, and thermodynamics of materials.
5 Previously, I was a member of the Staff of the Oregon Public Utilities Commission
6 (2016-2019), where I worked in both resource planning and rates. As a Senior Energy
7 Analyst at OPUC I analyzed utility integrated resource plans (IRP) and related filings to
8 ensure regulatory requirements were met, represented OPUC staff in hearings and public
9 meetings, and engaged with stakeholders to ensure the Commission's mission of
10 protecting ratepayers was met. Prior to my role at OPUC, I worked as a researcher at the
11 US Department of Energy's National Energy Technology Laboratory(2011-2016). At
12 NETL I worked on multiple research portfolios related to natural gas, coal, carbon
13 storage, and rare earth elements.
14 Q. ON WHOSE BEHALF ARE YOU COMMENTING?
15 A. I am commenting on behalf of the Idaho Irrigation Pumpers Association, Inc. ("IIPA").
16 Q. WHAT IS THE PURPOSE OF THE COMPANY'S APPLICATION IN THIS
17 CASE?
18 A. Idaho Power("the Company") is requesting a Certificate of Public Convenience and
19 Necessity (CPCN) from the Idaho Public Utilities Commission to approve its Natural Gas
20 Conversion Agreement with NV Energy for the North Valmy Power Plant. This
21 agreement would authorize the conversion of Valmy Units 1 and 2 from coal-fired to
22 natural gas-fired operation by the summer of 2026. The Company claims the conversion
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 2
CASE NO.IPC-E-25-03

I is necessary to ensure continued reliability and cost-effective service under its 2023
2 Integrated Resource Plan(IRP) and follow-up modeling analyses.
3 Q. FROM YOUR REVIEW OF THE FILING AND OTHER SOURCES,WHAT ARE
4 YOUR CONCLUSIONS AND RECOMMENDATION?
5 A. From my review of the Company's filings, models, and other resources, I am concerned
6 that the conversion of Valmy may not be the least cost, least risk resource to meet the
7 Company's needs. I am concerned that the Valmy repower was not fairly evaluated
8 against new and efficient simple cycle or combined cycle combustion turbines or other
9 shorter term potentially less expensive alternatives, and instead represents a last minute
10 resource acquisition secured to meet unexpected industrial load growth. If the
11 Commission does approve the Company's requests, I recommend that the Commission
12 should impose cost containment measures to protect ratepayers as I will describe and
13 justify in these comments.
14 Q. WHAT ARE SOME OF THE RISKS THAT THE RATEPAYERS WILL HAVE
15 TO BEAR IF THE COMPANY'S APPLICATION IS APPROVED AT THIS
16 TIME?
17 A. - Issues with modelling methodology
18 - Cost overruns/issues with capital and O&M cost modeling
19 - Lack of comparative scoring
20 - Stranded utilization risk
21 Q. WHAT ARE THE CONSEQUENCES OF THESE RISKS?
22 A. Taken together, these factors could result in significant ratepayer exposure. The actual
23 cost could be substantially higher than claimed by the Company if these risks materialize.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 3
CASE NO.IPC-E-25-03

1
2
3 Issues with modeling and methodolo2y
4 Q. HOW DID IDAHO POWER MODEL THE VALMY GAS CONVERSION
5 PROJECT IN ITS 2023 INTEGRATED RESOURCE PLAN (IRP)?
6 A. In the 2023 IRP, Idaho Power evaluated the Valmy gas conversion using the AURORA
7 model as part of portfolio-level scenario analysis. The Company developed several
8 portfolios, including one labeled"No Valmy,"to assess the reliability and cost
9 implications of different resource mixes. This modeling was functionally deterministic
10 and focused on meeting the 2026 LOLE thresholds l.
11 Q. HOW DOES THE B211 DELAY FACTOR INTO THE CAPACITY GAP?
12 A. The Company states that the need for the Valmy gas conversion in 2026 is primarily
13 driven by a delay in the Boardman-to-Hemingway(132H)transmission line,which was
14 originally expected to be in service in 2026 but is now projected for 20272. In Mr.
15 Ellsworth's testimony, the Company claims that without Valmy, the system would fail to
16 meet summer reliability thresholds under its deterministic LOLE screen for 2026.
17 Q. HAS THE COMPANY PRESENTED EVIDENCE THAT IT HAS CONSIDERED
18 ALTERNATIVE WAYS TO ADDRESS THE TEMPORARY CAPACITY GAP
19 BROUGHT ON BY A SUBSTANTIAL DEMAND INCREASE FROM A SINGLE
20 CUSTOMER?
21 A. The Company does not present evidence that it considered alternative ways to address the
22 temporary two-year capacity gap caused by the B2H delay. There is no modeling of
1 Ellsworth Direct Testimony.
2 Ellsworth Direct p. 15.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 4
CASE NO.IPC-E-25-03

I things like interim market purchases, demand response expansion, temporary mobile
2 generators, or efficient combined cycle generators to bridge the need. The modeling
3 process treats the presence of Valmy as a prerequisite for adequacy, rejecting the "No
4 Valmy"portfolio without re-optimizing around the constraint or considering hybrid
5 capacity strategies. This narrow framing suggests that the Valmy conversion is being
6 used as a default solution to a short-term transmission delay and resulting increase in
7 demand by a single large load rather than being selected through a robust least-cost, least-
8 risk resource planning process. Locking ratepayers into a multi-decade capital and fuel
9 obligation based on a temporary transmission shortfall and resulting in ability to service a
10 single large load raises serious concerns about prudency.
11 Q. WHAT METHODOLOGY DID THE COMPANY USE TO JUSTIFY THE
12 VALMY GAS CONVERSION?
13 A. Valmy Units 1 and 2 were not selected as a least cost resource in Idaho Power's most
14 recent IRP. Instead, these repowers were added as an uneconomic variant intended to
15 address short term reliability concerns. Idaho Power relies primarily on a LOLE analysis
16 to justify the Valmy gas conversion. The Company asserts that Valmy Units 1 and 2 are
17 necessary to meet reliability standards for summer 20263. This analysis assesses whether
18 the system meets a one-day-in-ten-years loss-of-load threshold using a static planning
19 reserve margin(PRM) model. Idaho Power has not appeared to consider alternatives,
20 such as short term market purchases, demand response expansion, or efficient combined
21 cycle generation as methods of addressing this reliability issue.
22 Q. DOES THE LOLE ANALYSIS PROVIDE SUFFICIENT BASIS TO JUSTIFY A
3 Ellsworth Direct Testimony,pp. 8-10.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 5
CASE NO.IPC-E-25-03

I LONG-LIVED, HIGH-COST INVESTMENT?
2 A. No. While LOLE is a stochastic metric, the Company appears to apply it in a narrow,
3 threshold-based fashion to justify Valmy, without 'incorporating the full probabilistic
4 context of cost,risk, and performance. Instead, the Company's LOLE analysis appears to
5 be limited to a deterministic, single-year snapshot that does not account for factors such
6 as utncertauuty in load growth, gas prices or generator performance; fixture renewable
7 energy availability, or fiill lifecycle costs or ratepayer exposure.A reliability study that
8 looks only at one moment in time cannot justify a multi-decade commitment of over_
9 — in fined capital and firm transport obligations', especially in the absence of
10 modeled dispatch or cost-effectiveness.
11 Q. ARE THERE ISSUES WITH IDAHO POWER'S USE OF THE LOLE
12 METHODOLOGY?
13 A. Yes. While the Company did model Valmy ur its 2023 IRP using AURORA, this
14 modeling focused on long-term portfolio-level economics and did not include the Vahmy
15 project m the competitive resource selection of the 2026 All Source RFP.
16 Q. WHAT OTHER CONCERNS DO YOU HAVE ABOUT IDAHO POWER'S
17 MODELING OF THE VALMY PROJECT?
18 A. The Company's econonuic modeling of Vahmy relies on updated cost assumptions and
19 Conversion Agreement terms that were introduced only after the 2023 IRP was
20 acknowledged5.As Mr. Ellsworth explains (pp. 12-14 of his testimony), these revisions
21 were retroactively incorporated, which suggests that the CPCN is being justified after the
22 fact rather than emerging from a neutral resource selection process.
a Company's confidential response to IIPA's request for production 1-4 Vahny 20 year forecast.
5 Ellsworth direct testimony.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.R'RTTTEN COMWENTS—Page 6
CASE NO.IPC-E-25-03

I Q. WAS VALMY TESTED IN AN OPEN-ENDED RESOURCE OPTIMIZATION
2 PROCESS?
3 A. No. In the AURORA model,Valmy was modeled as a binary "include or exclude"
4 assumption. It was not subjected to portfolio selection based on cost or risk-performance
5 against third-parry alternatives. In essence,Valmy was forced into select portfolios, which
6 prevents an impartial comparison of alternatives.
7 Q. DID THE COMPANY EVALUATE WHETHER OTHER PORTFOLIOS COULD
8 MEET RELIABILITY NEEDS MORE COST-EFFECTIVELY?
9 A. The Company claims that portfolios without Valmy failed to meet reliability
10 requirements, but Mr. Ellsworth does not disclose how that determination was made, or
11 whether those shortfalls could have been addressed by less expensive alternatives like
12 batteries, demand response, or market purchases. Table 3 of Mr. Ellsworth's testimony
13 (p. 16) shows that the "No Valmy"portfolio was not evaluated on equal footing (the "No
14 Valmy"portfolio is the only one marked as failing the LOLE screen, so it was excluded
15 based on a binary screen and seemingly not iterated as part of the optimization process).
16 Q. WAS THE MODELING PROCESS SUFFICIENTLY ROBUST TO ENSURE
17 PRUDENCY?
18 A. The Company modeling relied on a feedback loop between probabilistic (RCAT) and a
19 functionally deterministic (AURORA) tools. Mr. Ellsworth describes how the loss-of-
20 load risk feedback process was used to iterate between tools,but this introduces non-
21 transparent assumptions and synchronization risks that may significantly affect the
22 reliability designation for Valmy.
6 Ellsworth,p.9.
7 Ellsworth direct p. 6.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 7
CASE NO.IPC-E-25-03

I Q. HOW DOES IDAHO POWER'S USE OF MODELING AFFECT A FINDING OF
2 PRUDENCY?
3 A. The Company's use of a single-year, deterministic LOLE model to justify Valmy falls
4 short of a prudency standard. While meeting the PRM and LOLE threshold for 2026 is
5 important, the Company has not demonstrated that Valmy is the most economical or
6 lowest-risk way to achieve that reliability target.
7 Q. IN LIGHT OF THE RISKS ADDRESSED ABOVE,DO YOU RECOMMEND
8 ANY COST CONTAINMENT MEASURES IF THE CPCN IS GRANTED?
9 A. Yes. If the Commission decides to approve the CPCN, it should impose the following
10 cost containment measures to protect ratepayers: First, I recommend a capital cost cap on
11 total project costs above which a separate prudency review should be required. I
12 recommend using the figures provided in the Company's current models as a starting
13 point for the cost cap. Second, I suggest stranded cost safeguards in the event utilization
14 falls below a given threshold(e.g. below 10% of the capacity factor). And finally, in light
15 of the selection irregularities, I suggest that the Commission require the Company to file
16 annual reports showing dispatch hours and costs per MWh compared to shortlisted
17 resources. These provisions ensure that ratepayers are not left bearing the financial risk of
18 cost overruns, poor utilization, or uncompetitive operations over the life of the project.
19
20 Cost overruns and issues and regulatory exposure
21 Q. DO YOU HAVE ANY CONCERNS ABOUT COST OVERRUNS ASSOCIATED
22 WITH THE PROJECT?
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 8
CASE NO.IPC-E-25-03

I A. Yes,I have concerns regarding the potential for cost overruns as well as regulatory
2 exposure. The Company's own forecast shows- in capital costs in 2026 alone,
3 plus a-NOx control retrofit in 2029.Annual O&M and firm gas transportation
4 costs exceed-per year$. There is no evidence of probabilistic modeling of
5 capital risk or fuel price volatility in these specific figures (although the Company has
6 claimed that it has considered other fuel and carbon price volatility metrics,but any
7 changes from the IRP assumptions would not affect their conclusions).Without a cost
8 cap or contingency plan,ratepayers are exposed to significant overrun risk.
9 Q. DO THE O&M COSTS APPEAR TO BE REASONABLE?
10 A. The O&M costs appear to be flat and undifferentiated, and suffer from a lack of
11 transparency10. First,the firm gas transportation cost is forecast at per year
12 from 2027 onward, with no variation over time. This assumes an unrealistic degree of
13 stability in long-term gas transport pricing and ignores known volatility in fuel markets
14 and pipeline congestion risk. Second,non-fuel O&M begins at approximately
15 - and increases by only small, formulaic increments each year. The forecast lacks
16 detail about cost drivers for things such as staffing,maintenance cycles, emissions
17 compliance, or insurance. There is no justification provided for why these costs would
18 remain so stable or low over a 20-year period. Furthermore, there doesn't seem to be
19 sensitivity analysis for increases in natural gas price escalation,pipeline
20 capacity/congestion,or transport re-contracting, all of which raises concerns.
s Company response to IIPA's request for production 1-4,sheet 1 column E5.
9 Company response to EPA's request for production 1-8"Further,as described in Mr.Ellsworth's
testimony,Idaho Power analyzed the Valmy natural gas conversion under a broad array of carbon and natural
gas price expectations and,as part of the Company's request in this case,confirmed that
the results would remain materially unchanged given more recent assumptions for carbon
and natural gas prices".
10 Id.Columns G and H.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 9
CASE NO.IPC-E-25-03

I Q. WHAT ARE THE RISKS ASSOCIATED WITH THE ISSUES YOU'VE RAISED
2 WITH THE O&M COSTS?
3 A. Because the flat O&M forecast fails to account for potential cost drivers such as inflation,
4 equipment degradation, maintenance events, regulatory upgrades (e.g., emissions
5 compliance), or changes in gas transport tariffs, these forecasts likely understate true
6 lifecycle O&M costs.
7 Q. DO YOU SEE ANY ADDITIONAL RISKS WITH THE CAPITAL COST
8 FORECASTS?
9 A. The capital cost forecasts are structurally deferred and therefore risky. The
10 in capital outlay is forecast for 2026 (conversion+overhaul), and the NOx
11 control retrofit is deferred until 202911. Defer-ing critical emissions controls also raises
12 regulatory and financial exposure. The Company's capital cost forecast and regulatory
13 risk exposure for Valley is optimistic and incomplete, failing to reflect current market
14 uncertainty in construction and retrofit projects. The absence of contingency planning,
15 phased compliance retrofits, and lifecycle capital replacement undernines the claim that
16 this is a prudent or risk-adjusted investment.
17 Q. DO THE ISSUES YOU'VE RAISED WITH POTENTIAL COST OVERRUNS
18 IMPACT A FINDING OF PRUDENCY?
19 A. Yes, a fording of pridency is materially undermined in light of the issues I've raised.
20 Overall, these cost projections appear mechanically applied rather than based on detailed
21 engmeering, market data, or sensitivity analysis. Without a more robust, risk-adjusted
11 Id Cohwuis B and C.
IDAHO IRRIGATION PUA4IPERS ASSOCIATION,INC.WRITTEN CONBIENTS—Page 10
CASE NO.IPC-E-25-03

I cost framework, these forecasts likely understate the true cost to ratepayers and do not
2 support a finding of prudency.
3
4 Lack of comparative scoring
5 Q. HAS IDAHO POWER PROVIDED A DIRECT COST AND PERFORMANCE
6 COMPARISON BETWEEN VALMY AND SHORTLISTED BIDS EVALUATED
7 IN THE RFP PROCESS?
8 A. No. the Company has not submitted any analysis that compares the Valmy gas conversion
9 project to high-ranking bids from the 2026 All Source RFP in terms of net present value
10 (NPV), emissions performance, or dispatchability. Specifically, the Company's own
11 modeling12 includes levelized cost data for a single least-cost resource (solar PV), but no
12 comparable data for Valmy or other benchmark projects.Additional documents provided
13 by the Company13 contain a detailed"Summary Table" listing dozens of bids with
14 information on technology type, capacity, LCOE, capacity factor, fuel price, and other
15 metrics. However, the Valmy project is not included anywhere in that table, and no
16 comparative analysis is offered in any other model or filing. The absence of this
17 information prevents the Commission from evaluating whether the Valmy project is
18 prudent relative to feasible alternatives and reinforces concerns about a biased and
19 incomplete evaluation process. This omission deprives the Commission of the
20 information needed to assess whether Valmy represents a prudent investment compared to
"Company's Confidential Response to IIPA's Request for Production No. 1-3—Confidential Attachment 1
—UM 2000.xlsx.
13 Company's Confidential Response to IIPA's Request for Production No. 1-7—Confidential Attachment—
2026 RFP Financial Models—FINAL Model for FSL.xls.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 11
CASE NO.IPC-E-25-03

I viable alternatives, and also reinforces concerns about the objectivity and completeness
2 of the RFP process.
3
4 Q. HO« DOES <ALMY COMPARE TO LOWER-COST ALTERNATIVES BASED
5 ON THE DATA GATHERED IN THE RFP PROCESS?
6 A. According to the Company's avoided cost filings in UM 200014, solar PV has a total
7 levelized cost of- with no fiiel cost. In contrast,Valmy's fixed costs alone
8 exceed-up front,plus- annually in O&M and gas transport.As a
9 low-capacity-factor resource(a reasonable assumption would be a capacity factor
10 between 5% and 10% for a repowered peaking gas unit),Valmy's cost per delivered
11 NM is likely many times higher than solar,yet this comparison is not shown anywhere
12 in the Company's application.Assuming a 5%capacity factor, the LCOE would be
13 roughly-.. and for a 10%capacity factor it would be roughly�5.
14 Q. DO THE IRREGULARITIES IMPACT A FINDING OF PRUDENCE?
15 A. Yes, the lack of comparison in the Company's process undernines a finding of prudence.
16 Without a transparent comparison or a demonstration that Valmy outperforms market
17 alternatives, the record cannot support a Commission fording that this project is prudent.
18
19 Stranded capacity and utilization risk
is Company's confidential response to HPA's request for production 1-3 and Company response to IIPA's
request for production 1-4,sheet 1.
15 LCOE=Total lifecycle cost/total energy output(MWh),and assuming$115 million capital cost,$23
million O&M and gas transport, 15 year lifetime,7%discount rate, 124 MW capacity,and 8.760 hours per
year...step 1:discount 23 million annual fixed costs over 15 years using 7%discount rate=207 million. Step 2,
total lifecycle cost=capital cost plus discounted present value O&M=115 mill+207 mill=322 million. Step 3,
total energy output=annual MWh*hr/year*capacity factor* 15 years.And plug into LCOE formula.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS-Page 12
CASE NO.IPC-E-25-03

I Q. WHAT IS THE EXPECTED OPERATIONAL ROLE OF VALMY AFTER ITS
2 CONVERSION TO NATURAL GAS?
3 A. Valmy is expected to operate primarily as a peaking resource that is dispatched during
4 periods of high demand as opposed to a baseload or intermediate basis. This is consistent
witli how the Company characterizes the resource in its planning documents and is
6 implied by the absence of Vahny from the Final Shortlist portfolios,which favored more
7 frequently dispatched, flexible, and cost-effective resources16
8 Q. WHY DOES THIS OPERATIONAL ROLE POSE A RISK OF
9 UNDERUTILIZATION?
10 A. Peaking resources by definition operate at low capacity factors, often well below 10%.
11 When pained with very high fixed capital and O&M costs, low utilization significantly
12 increases the levelized cost per NM.According to the Company's forecast17 the 2026
13 capital investment is forecast at with in NOx control retrofit
14 in 2029,and an annual fixed conversion cost of about- (O&M).With limited
15 dispatch hours, this cost structure means the plant's output could be many times more
16 expensive than alternative resources like solar or storage, even when gas prices are stable.
17 Q. HAS IDAHO POWER PROVIDED A DISPATCH FORECAST OR
18 UTILIZATION ESTIMATE FOR VALMY?
19 A. No. In its CPCN application and discovery responses the Company has not provided any
20 modeled hourly or annual dispatch forecast for Valmy after conversion. There is no
16Company's response to IIPA's request for production No. 1-6,confidential attachment 1
17 Company's Response to HPA's Request for Production No. 1-4 Palmy Forecast(2024)
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS-Page 13
CASE NO.IPC-E-25-03

I estimate of how frequently the plant is expected to run, nor is there a sensitivity analysis
2 for high-renewable or low-load scenarios18.
3 Q. HOW DOES THIS AFFECT THE PRUDENCY OF THE INVESTMENT?
4 A. Without a dispatch forecast, the Commission is being asked to approve a high-capital,
5 long-lived asset with no operational profile. Given the rapid adoption of solar, wind, and
6 storage in the Company's own IRP and regional trends in decarbonization, there is a
7 strong risk that Valmy will not dispatch often enough to recover its fixed costs which can
8 result in a stranded cost burden on ratepayers.
9
10 Summary
11 Q. CAN YOU PLEASE SUMMARIZE YOUR TESTIMONY?
12 A. The Commission should find that the Company has not demonstrated that the Valmy gas
13 conversion represents a least-cost, least-risk resource when evaluated against available
14 alternatives. The Company has found itself in a position where due to the B211
15 transmission delays, it is scrambling to meet a short term capacity need due to new
16 demand from a small number of new large load customers. Rather than methodically
17 investigate viable short term alternatives, the Company relies on a narrow, threshold-
18 based LOLE justification for a multi-decade investment, without incorporating full
19 utilization or exposure modeling. The project bypassed the competitive evaluation
20 process used in the 2026 All Source RFP, was not selected in the final risk-adjusted
21 portfolios, and faces significant stranded cost risk due to high fixed capital and transport
" Response to IIPA's Request for Production No. 1-4 Valmy Forecast(2024): contains cost projections,
but no utilization forecast and 2026 RFP Financial Models FINAL Model for FSL.xlsx:does not include Valmy,so
no dispatchability metrics are available.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 14
CASE NO.IPC-E-25-03

I costs and uncertain dispatch. Without meaningful cost containment, transparency, or
2 comparative analysis, the proposed investment does not meet the standard of prudency
3 and should be rejected. In the event the Commission grants the CPCN, I recommend that
4 the Commission impose cost containment measures in the form of a capital cost cap;
5 stranded cost safeguards; and utilization reporting to protect ratepayers from cost
6 overruns or poor utilization.
7 Q. DOES THIS CONCLUDE YOUR COMMENTS?
8 A. Yes.
9
DATED this 29th day of May, 2025.
f
DEBORAH GLOSSER
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 15
CASE NO.IPC-E-25-03

CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 29th day of May, 2025, I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Written Comments to each of
the following, via the method indicated below:
Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail
Chris Burdin, Deputy Attorney General ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
P.O. Box 83720 ❑ Telecopy(Fax)
Boise, ID 83720-0074 ® Electronic Mail (Email)
secretM(iDj2uc.idaho.gov
chris.burdingpuc.idaho.gov
Donovan Walker ❑ U.S. Mail
Megan Goicoechea Allen ❑ Hand Delivered
Tim Tatum ❑ Overnight Mail
Idaho Power Company ❑ Telecopy(Fax)
1221 W. Idaho Street (83702) ® Electronic Mail (Email)
P.O. Box 70
Boise, ID 83707
dwalker(a,idahopower.com
mgoicoecheaallengidahopower.com
dockets(&idahopower.com
ttatumgidahopower.com
Lance Kaufman, Ph.D. ❑ U.S. Mail
2623 NW Bluebell Place ❑ Hand Delivered
Corvallis, OR 97330 ❑ Overnight Mail
lancegae isg insi h� ❑ Telecopy(Fax)
® Electronic Mail (Email)
Ed Jewell ❑ U.S. Mail
Jessica Harrison ❑ Hand Delivered
Deputy City Attorneys ❑ Overnight Mail
Boise City Attorney's Office ❑ Telecopy(Fax)
150 N. Capitol Blvd. ® Electronic Mail (Email)
Boise, ID 83701
BoiseCityAttorneygcityofboise.org
eiewell(aD,cityofboise.org
jharrisonncityofboise.org
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 16
CASE NO.IPC-E-25-03

Katie O'Neil ❑ U.S. Mail
Energy Program Manager ❑ Hand Delivered
Boise City Dept. of Public Works ❑ Overnight Mail
150 N. Capitol Blvd. ❑ Telecopy(Fax)
Boise, ID 83701 ® Electronic Mail (Email)
koneil(ir cityofboise.com
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(c�hollandhart.com
tnelsonkhollandhart.com
awj ensen(&hollandhart.com
karoachkhollandhart.com
acleekhollandhart.com
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 17
CASE NO.IPC-E-25-03