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Home My WebLink About20250606Reply Comments.pdf RECEIVED Eric L. Olsen(ISB#4811) June 6, 2025 ECHO HAWK& OLSEN, PLLC IDAHO PUBLIC 505 Pershing Ave., Ste. 100 UTILITIES COMMISSION 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 IDAHO POWER CASE NO. IPC-E-24-46 COMPANY'S APPLICATION FOR APPROVAL OF A POWER PURCHASE IDAHO IRRIGATION PUMPERS AGREEMENT WITH JAKALOPE WIND, ASSOCIATION, INC.'S REPLY LLC,AND A CERTIFICATE OF PUBLIC COMMENTS CONVENIENCE AND NECESSITY FOR THE JAKALOPE WIND PROJECT The Idaho Irrigation Pumpers, Inc. ("IIPA"), by and through counsel, hereby submits the following reply comments in response to Idaho Power Company's ("IPC") June 3, 2025, filing. While Idaho Power's reply comments alleviate a few of IIPA's minor concerns with the Jackelope project, IIPA continues to have deep concerns about the cost effectiveness of this resource and the prudence of IPC's decision to acquire the resource. Critical issues that IPC fails to address are: 1) The absence of any material capacity value from the project; 2) The appropriate ELCC to expect from the project; 3) The risk associated with PTC; and 4) Whether an alternative resource, such as a natural gas combined cycle, would provide a more economical solution to capacity and energy needs. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.REPLY COMMENTS—Page 1 CASE NO.IPC-E-24-46 IPC appears to acknowledge that Jackalope and Jim Bridger cannot simultaneously produce at full output. This means that Jackalope wind has little to no incremental capacity value for IPC. IPC emphasizes its ability to "flex" output from the Jim Bridger units to accommodate Jackalope wind generation within its 800 MW of transmission rights on the Bridger-West path. We do not dispute that such flexibility may be operationally feasible. However, IPC's analysis fails to address our core concern: both Jackalope and Bridger are being credited simultaneously for their full output potential within a fixed transmission constraint.Regardless of whether Bridger can ramp down, the physical limit remains: only 800 MW can flow west at any given time. This constraint means that ratepayers are effectively paying for two resources that cannot fully operate in parallel. The Company's modeling may show dispatchable accommodation of both projects, but from a system planning and ratepayer investment perspective, the same transmission headroom is being used twice; once to justify Jackalope's deliverability,and again to defend Bridger's ongoing value.This constitutes a form of double counting. Given the stakes and the magnitude of the capital investment, IIPA reiterates its urge to the Commission to consider a cost containment or curtailment penalty mechanism if Jackalope's ability to deliver is compromised by transmission limits or competing system needs. Regarding ELCC: While IPC argues that capacity factor, nameplate capacity, and ELCC are distinct metrics, this distinction does not resolve the underlying concern. The project was selected in large part to meet an urgent capacity need due to new large system loads. Yet most of Jackalope's output (while inexpensive energy) does not occur during peak hours, and therefore does not address the core capacity deficiency. Moreover, IPC offers no transparency into IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.REPLY COMMENTS—Page 2 CASE NO.IPC-E-24-46 Jackalope's marginal ELCC given its existing renewable portfolio. Without this, the Commission cannot assess whether the project provides meaningful incremental reliability value, or whether ratepayers are simply funding low-value redundancy. Staff s analysis clearly supports IIPA's position: the Jackalope Wind Project, despite its 600 MW nominal capacity, contributes only 95 MW toward the 2027 capacity deficit,which is a contribution of just 16%. This mismatch between cost and capacity value is significant and, in Staffs words, results in the Company "overpaying for the capacity deficit benefit". Regardless of the appropriate ELCC, any ELCC is meaningless in the face of the transmission constraints imposed by using the same path for both Bridger and Jackelope. Even if Jackelope had a 100% ELCC in theory, Bridger's total capacity contribution plus Jackelope is limited to the 800 MW transmission limit. Thus a hypothetical 100% ELCC Jackelope project offers no true incremental capacity to IPC, once Bridger's reduced dispatch is accounted for. IIPA echoes and amplifies Staffs concern that Jackalope's economic advantage is heavily dependent on PTCs, a benefit that is now politically uncertain. If those tax credits are rescinded, ratepayers would bear an unjust and unreasonable financial burden. IIPA is also greatly concerned by IPC's apparent lack of any attempt to update its analysis of resource planning as it acquired more market data and moved towards resource planning. IPC argues that a gas plant is higher cost and higher risk without offering any supporting evidence that this was the case at the time that it decided to approve the Jackelope project. Contrary to IPC's assertions, resource selection is not a static decision made early in the resource acquisition process. It is a decision that should be revisited throughout the resource selection process. IPC should have solicited bids for a variety of resource types,including a natural gas combustion turbine, and evaluated the least cost resource using a long term planning tool at IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.REPLY COMMENTS—Page 3 CASE NO.IPC-E-24-46 the time of final resource selection to confirm that wind remained the least cost resource. Instead IPC represents the resource selection process as cast in stone, and something that cannot be altered after the conclusion of an IRP process. This is clearly an imprudent approach to planning. Given these concerns,it is critical that the Commission clearly establish that,at a minimum, any CPCN issued for the Jackelope project offers no prejudice or implications for future prudency or cost recovery of the project. In addition to this critical recommendation,we also continue to recommend IPC should be prohibited from recovering any PTC-related revenue shortfall through rates, and a soft cap on capital cost recovery should be imposed to limit ratepayer exposure in the event of delays, curtailments, or policy shifts. DATED this 6th day of June, 2025. EC WK& OLSEN ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.REPLY COMMENTS—Page 4 CASE NO.IPC-E-24-46 CERTIFICATE OF SERVICE I HEREBY CERTIFIY that on this 6th day of June, 2025, I served a true, correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Reply 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 Tim Tatum ❑ U.S. Mail Donovan E. Walker ❑ Hand Delivered Idaho Power Company ❑ Overnight Mail 1221 W. Idaho Street (83702) ❑ Telecopy(Fax) P.O. Box 70 ® Electronic Mail (Email) Boise, ID 83707 ttatumgidahopower.com dwalkergidahopower.com dockets gidahopower.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) 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 petergrichardsonadams.com ❑ U.S. Mail ❑ Hand Delivered ❑ Overnight Mail ❑ Telecopy(Fax) ® Electronic Mail (Email) IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.REPLY COMMENTS—Page 5 CASE NO.IPC-E-24-46 Dr. Don Reading ❑ U.S. Mail Industrial Customer of Idaho Power ❑ Hand Delivered 280 S. Silverwood Way ❑ Overnight Mail Eagle, ID 83616 ❑ Telecopy(Fax) dreadin mindspring 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 karoachbhollandhart.com aclee@hollandhart.com ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.REPLY COMMENTS—Page 6 CASE NO.IPC-E-24-46