20250616Answer to Objection.pdf

RECEIVED
Eric L. Olsen(ISB#4811) June 16, 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-24-46
COMPANY'S APPLICATION FOR
APPROVAL OF A POWER PURCHASE IDAHO IRRIGATION PUMPERS
AGREEMENT WITH JACKALOPE WIND, ASSOCIATION, INC.'S ANSWER
LLC,AND A CERTIFICATE OF PUBLIC TO IDAHO POWER COMPANY'S
CONVENIENCE AND NECESSITY FOR OBJECTION TO THE REPLY
THE JACKALOPE WIND PROJECT COMMENTS OF THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION INC.
Idaho Irrigation Pumpers Association,Inc. ("IIPA"),by and through counsel,and,pursuant
to Idaho Public Utilities Commission's (Commission") Rules of Procedure ("RP") 201-204 and
265, hereby responds to the objection of Idaho Power Company ("Idaho Power" or "IPC") to
IIPA's reply comment filed on June 3, 2025.
BACKGROUND
IPC filed an application with the Commission 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 on December 27, 2024. IIPA petitioned to intervene as a party to
IPC's application on February 18, 2025. IIPA's petition was granted by the Commission on
March 5, 2025. The Commission issued Order No. 36563 on April 25, 2025, which set the
comment deadlines of May 13, 2025, for the intervenors, and June 3, 2025, for the applicants.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.ANSWER TO OBJECTION—Page I
CASE NO.IPC-E-24-46

IIPA filed their comment on May 13, 2025, and Idaho Power filed their reply comment on June
3, 2025. In response to Idaho Power's comment, IIPA filed a reply comment on June 6, 2025.
ANSWER TO OBJECTION
Idaho Power objected to the reply comments filed by IIPA asserting that the reply
comment was outside of the procedural schedule and beyond the Commission's Order No.
36563. Idaho Power correctly concluded that there is no provision in the IDAPA that concerns
replying to another applicant or intervenor's comment. It is also correct that IIPA must follow
the Commission's rule of procedure and Orders, yet IIPA has not violated any rule of procedure
or Order. Idaho Power has merely pointed out that there is no provision concerning replying to
another party's comment.
The Commission, as a state administrative agency, has authority to promulgate rules and
regulations concerning its adjudicative processes given generally through the Public Utilities
Law, Chapters 1 through 7, Title 61, Idaho Code. Chapters 8 through 10, 13, 15 through 17, Title
61, Idaho Code; Chapters 3 and 4, Title 62, Idaho Code; the Telecommunications Act of 1988, as
amended, Chapter 6, Title 62; Chapters 12 and 13, Title 62, Idaho Code. Therefore, as the
promulgator of its own rules and regulations, the Commission has the authority to allow parties
to reply to another party's reply comment. Accordingly, the timeframe of the procedural
schedule should additionally allow the other party with time to draft a response and file it with
the Commission.
Alternatively, if the Commission finds that the procedural rules do not allow IIPA to
reply to IPC's comment, the Commission may treat IIPA's reply comment as a public comment
and give it the appropriate weight.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.ANSWER TO OBJECTION—Page 2
CASE NO.IPC-E-24-46

CONCLUSION
In conclusion, IIPA asks the Commission to take into consideration the IIPA's reply
comment when determining whether to grant Idaho Power's application 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. Idaho Power has not been prejudiced by the filing but
the record as whole is benefited by having the IIPA's brief reply comment.
DATED this 161h day of June, 2025.
EC WK& OLSEN
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.ANSWER TO OBJECTION—Page 3
CASE NO.IPC-E-24-46

CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 16th 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.ANSWER TO OBJECTION—Page 4
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 [e-mail]
karoachbhollandhart.com
[e-mail]
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.ANSWER TO OBJECTION—Page 5
CASE NO.IPC-E-24-46