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Home My WebLink About20250623Application for Intervenor Funding.pdf RECEIVED Eric L. Olsen(ISB#4811) June 23, 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-25-03 COMPANY FOR APPROVAL OF THE NORTH VALMY POWER PLANT APPLICATION FOR INTERVENOR NATURAL GAS CONVERSION FUNDING OF THE IDAHO AGREEMENT WITH NV ENERGY IRRIGATION PUMPERS ASSOCIATION,INC. COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("IIPA"), by and through counsel of record, Echo Hawk & Olsen, PLLC, and hereby respectfully makes application to the Idaho Public Utilities Commission ("Commission") for intervenor funding, pursuant to Idaho Code § 61-617A and IDAPA §§ 31.01.01.161 through .165, in this case, as follows: (A) A summary of the expenses that the IIPA request to recover broken down into legal fees, witness fees and other costs and expenses is set forth in Exhibit A attached hereto and incorporated by reference. The expenses and costs incurred by the IIPA set forth in Exhibit A are reasonable in amount and were necessarily incurred. The expenses and costs were incurred in participating in the case. Without incurring these expenses and costs, IIPA would not have been able to fully participate in this matter. (B) The IIPA's Counsel, Eric L. Olsen of Echo Hawk & Olsen ("Mr. Olsen") and its Expert witnesses Lance D. Kaufman, Ph.D. ("Dr. Kaufman") and Deborah Glosser, PhD. ("Dr. APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 1 CASE NO.IPC-E-25-03 Glosser")participated in Idaho Power Company's ("IPC")North Valmy Power Plant Natural Gas Conversion Agreement with NV Energy case("Valmy").Mr. Olsen,Dr.Kaufman and Dr. Glosser prepared and served written discovery; reviewed and analyzed the various parties' positions. Dr. Glosser's review in this case raised concerns that the Valmy repower may not be the least cost, least risk resource to meet IPC's needs because the project was not fairly evaluated against new and more efficient simple cycle or combined cycle combustion turbines or other shorter term and potentially less expensive alternatives. Dr. Glosser's review focused on: (1) the issues with IPC's modeling methodology; (2)the failure to properly account for possible cost overruns and static cost inputs with capital and O&M cost modeling; (3)the lack of comparative scoring with alternative projects; and(4)possibility of stranded utilization risk. These factors could result in significant ratepayer exposure to increased costs for this resource. As such, IIPA recommended that the CPCN for the Valmy repower should not be approved. In the event the Commission grants the CPCN, IIPA recommended that the Commission impose cost containment measures in the form of a capital cost cap; stranded cost safeguards; and utilization reporting to protect ratepayers from cost overruns or poor utilization. (C) The costs described in Exhibit A constitute a financial hardship for the IIPA. The IIPA is an Idaho nonprofit corporation qualified under I.R.C. § 501(c)(5) representing farm interests in electric utility rate matters affecting farmers in southern and central Idaho. The IIPA relies solely upon dues and contributions voluntarily paid by members, together with intervenor funding, to support its activities. Each year mailings are sent to approximately 7,000 Idaho Irrigators (approximately one-third in the IPC service area and the remainder in IPC's service area), soliciting annual dues. IIPA recommends members make voluntary contributions based on APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 2 CASE NO.IPC-E-25-03 acres irrigated or horsepower per pump. Member contributions have been falling which is believed to be attributable to increased operating costs and declining commodity prices. From member contributions the IIPA must pay all expenses, which generally include mailing expenses, meeting expenses, post office box, in addition to the expenses relating to participation in matters before the Commission. The Executive Director, Amy McKoon, is the only part-time paid contractor, receiving a retainer plus expenses for office space, office equipment, and secretarial services. Other IIPA officers and directors are elected annually and serve without compensation. It has been and continues to be a financial hardship for the IIPA to fully participate in important cases such as this one due to the time and expense that must be incurred to fully participate in such a case. Because of the IIPA's financial constraints, participation in this case, preparing to file testimony, and participating in the settlement negotiations has been focused and prudent. (D) IIPA's recommendations materially differed from Commission Staff s comments. The IIPA recommended that the Commission should not grant the CPCN for the Valmy repower project. The IIPA found that the Company failed to demonstrate that the project represents a least- cost, least-risk resource. The IIPA identified possible cost overruns and O&M cost modeling issues. The IIPA identified that IPC planned to utilize Valmy primarily to a peaking resource and that IPC did not model whether it would be dispatched enough to recover its fixed costs. The IIPA requested if approval is given that the Commission impose cost containment measures in the form of a capital cost cap, stranded cost safeguards, and utilization reporting to protect ratepayers from cost overruns and poor utilization. APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 3 CASE NO.IPC-E-25-03 (E) The IIPA's participation addressed issues of concern to the general body of users or consumers on IPC's system in the recommended cost containment measures would benefit all of IPC's customers. (F) The IIPA represents the irrigation class of customers under Schedule 10 on IPC's system. Based on the foregoing, it is respectfully submitted that the IIPA is a qualifying intervenor and should be entitled to an award of costs of intervention in the maximum amount allowable pursuant to Idaho Code § 61-617A and IDAPA §§ 31.01.01.161 through .165. DATED this 23rd day of June, 2025. EC WK& OLSEN ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 4 CASE NO.IPC-E-25-03 CERTIFICATE OF SERVICE I HEREBY CERTIFIY that on this 23rd day of June, 2025, I served a true, correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Application for Intervenor Funding 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(i cityofboise.org j harrisonncityofboise.org APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 5 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 tnelson(a,hollandhart.com awj ensen(&hollandhart.com karoachkhollandhart.com aclee(a,hollandhart.com ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 6 CASE NO.IPC-E-25-03 EXHIBIT A Expert Witnesses: Deborah Glosser and Lance Kaufman,Expenses: 1. Witness Fees: 23.35 Hours @ $250= $ 5,837.50 Sub Total: $ 5,837.50 Legal Expenses: 1. Paralegal Fees: 5 Hours @ $155 = $ 775.00 2. Legal Fees Eric L. Olsen: 6.2 Hours @ $250 = $ 1,550.00 3. Soft Costs (Copies/Legal Research) $ 10.35 Sub Total: $ 2,335.35 Grand Total: $ 8,172.85 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 7 CASE NO.IPC-E-25-03