20250609Reply Comments.pdf

-�IQAFIO R.
DONOVAN WALKER 04%
Lead Counsel RECEIVED
dwalker(a)idahopower.com
June 09, 2025
June 9, 2025 IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-24-46
Application of Idaho Power Company for Approval of a Power Purchase
Agreement with Jackalope Wind, LLC, and for a Certificate of Public
Convenience and Necessity for the Jackalope Wind Project
Dear Commission Secretary:
Attached for electronic filing is Idaho Power Company's Objection to the Reply
Comments of the Idaho Irrigation Pumpers Association, Inc. in the above matter.
If you have any questions about any of the aforementioned documents, please do
not hesitate to contact me.
Very truly yours,
Donovan E. Walker
DEW:sg
Attachments
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalker(o-)idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-46
APPROVAL OF A POWER PURCHASE )
AGREEMENT WITH JACKALOPE WIND, ) IDAHO POWER COMPANY'S
LLC, AND A CERTIFICATE OF PUBLIC ) OBJECTION TO THE REPLY
CONVENIENCE AND NECESSITY FOR ) COMMENTS OF THE IDAHO
THE JACKALOPE WIND PROJECT. ) IRRIGATION PUMPERS
ASSOCIATION INC.
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and,
pursuant to Idaho Public Utilities Commission's ("Commission") Rules of Procedure
("RP") 201-204 and 265, hereby respectfully objects to the reply comments submitted by
the Idaho Irrigation Pumpers Association, Inc. ("IIPA") on June 6, 2025.
I. PROCEDURAL BACKGROUND
IIPA petitioned to intervene as a party in this matter on February 18, 2025. The
Commission granted IIPA's petition to intervene on March 5, 2025. On April 25, 2025,
IDAHO POWER COMPANY'S OBJECTION TO
IIPA REPLY COMMENTS - 1

the Commission issued Order No. 36563 which established the procedural schedule for
this case directing the use of Modified Procedure with a written comment deadline of May
13, 2025, and a June 3, 2025, deadline for Idaho Power to file any reply comments.
Commission Staff and IIPA each filed comments on May 13, 2025. Idaho Power filed
reply comments June 3, 2025. On June 6, 2025, IIPA filed reply comments "in response
to Idaho Power Company's ("IPC") June 3, 2025, filing." IIPA reply comments, p 1.
II. OBJECTION
Idaho Power hereby objects to the reply comments filed by IIPA on June 6, 2025,
as being outside of the procedural schedule and beyond the Commission's Order
directing Modified Procedure. RP 204 states, "When the Commission finds that it may
not be in the public interest to hold a hearing in a matter, notice of modified procedure will
be issued. It will: ... d. Establish the deadline for filing written protests or comments,
and a reply by the moving party." RP 204(d) (emphasis added). IIPA is not the moving
party and it has no authorization in the Commission's rules or orders to submit a reply to
Idaho Power's reply comments that were authorized by the Notice of Modified Procedure
in this matter. Order No. 36563.
The Commission's Order No. 36563 on Modified Procedure sets forth a comment
deadline of May 13 and a Company reply comment deadline of June 3, 2025. There is
no provision or authorization for IIPA to file reply comments to the reply comments of the
Company. IIPA is a sophisticated party that has intervened and obtained party status in
this matter. As a party to the case IIPA must follow the Commission's rules of procedure
and Orders. IIPA was advised of such in the Order granting its intervention and party
status: "IT IS FURTHER ORDERED that all parties comply with all rules of the
IDAHO POWER COMPANY'S OBJECTION TO
IIPA REPLY COMMENTS -2

Commission ..." Order No. 36493, p 1, (granting IIPA's petition to intervene). IIPA's
submission of reply comments to Idaho Power's reply comments is outside of the
Commission rules, Order 36563, and is improper.
III. CONCLUSION AND REQUEST FOR RELIEF
WHEREBY Idaho Power objects to IIPA's submission of reply comments as being
outside of the Commission's rules of procedure and contrary to the procedural schedule
ordered by the Commission in its Notice of Modified Procedure. Order No. 36563. Idaho
Power respectfully requests that IIPA's reply comments be stricken and/or not
accepted/considered by the Commission as part of this proceeding, and that the
Commission consider the record closed with the submission of Idaho Power's reply
comments on June 3, 2025, and render its final order on the merits and upon that
record.
Respectfully submitted this 9t" day of June 2025 at Boise, Idaho.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S OBJECTION TO
IIPA REPLY COMMENTS - 3

CERTIFICATE OF SERVICE
HEREBY CERTIFY that on the 9t" day of June, 2025, 1 served a true and correct
copy of Idaho Power Company's Objection to IIPA Reply Comments upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Chris Burdin U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email Chris.Burdin(a)puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Austin W. Jensen FAX
Holland & Hart LLP X Email darueschhoff(a)hollandhart.com
555 17th Street, Suite 3200 tnelson hol land hart.com
Denver, CO 80202 awiensen(a)hollandhart.com
aclee hollandhart.com
mamcmillen(c)hollandhart.com
Idaho Irrigation Pumpers Association, Inc. Hand Delivered
Eric L. Olsen U.S. Mail
ECHO HAWK & OLSEN, PLLC Overnight Mail
505 Pershing Avenue, Suite 100 FAX
P.O. Box 6119 X EMAIL elo(a)-echohawk.com
Pocatello, ID 83205
Lance Kaufman, Ph.D. Hand Delivered
2623 NW Bluebell Place U.S. Mail
Corvallis, OR 97330 Overnight Mail
FAX
X EMAIL lance aegisinsight.com
IDAHO POWER COMPANY'S OBJECTION TO
IIPA REPLY COMMENTS -4

Industrial Customers of Idaho Power Hand Delivered
Peter J. Richardson U.S. Mail
Richardson Adams, PLLC Overnight Mail
515 N. 271" Street FAX
Boise, ID 83702 X EMAIL peter richardsonadams.com
Dr. Don Reading Hand Delivered
280 S. Silverwood Way U.S. Mail
Eagle, ID 83716 Overnight Mail
FAX
X EMAIL dreading(a)mindspring.com
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S OBJECTION TO
IIPA REPLY COMMENTS - 5