20250717Comments.pdf

RECEIVED
Eric L. Olsen(ISB#4811) July 17, 2025
IDAHO PUBLIC
ECHO HAWK& OLSEN, PLLC UTILITIES COMMISSION
505 Pershing Ave., Ste. 100
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-25-08
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC IDAHO IRRIGATION PUMPERS
CONVENIENCE AND NECESSITY FOR ASSOCIATION,INC.'S WRITTEN
AN OWNERSHIP INTEREST IN THE COMMENTS
SOUTHWEST INTERTIE PROJECT—
NORTH 500-KV TRANSMISSION LINE
AND APPROVAL OF THE UTILIZATION
OF CAPACITY ON THE LINE.
1 Idaho Irrigation Pumpers, Inc., by and through counsel, hereby submits its written
2 comments to Idaho Power Company's Application for a Certificate of Public Convenience and
3 Necessity for an Ownership Interest in the Southwest Intertie Project-North 500-KV Transmission
4 Line and Approval of the Utilization of Capacity on the Line, pursuant to Commission Rule 225,
5 as follows:
6 Q. PLEASE STATE YOUR NAME,ADDRESS,AND EMPLOYMENT.
7 A. My name is Deborah Glosser. I am serving as a consultant for Western Economics, LLC
8 at 2623 NW Bluebell Dr, Corvallis, Oregon, 97330.
9 Q. WOULD YOU BRIEFLY DESCRIBE YOUR EDUCATIONAL BACKGROUND
10 AND PROFESSIONAL EXPERIENCE?
11 A. I earned a PhD in Civil Engineering with a focus in Materials from Oregon State
12 University in 2020, an MS in Geophysics from the University of Pittsburgh in 2013, and
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 1
CASE NO.IPC-E-25-08

I a JD from Duquesne University in 2005. Since 2020, I have been an Assistant Professor
2 at Western Washington University in Bellingham, with appointments in the Institute for
3 Energy Studies, Engineering and Design, and the Advanced Materials Science and
4 Engineering Center. I was recently awarded tenure and will return next year as an
5 Associate Professor. My research group develops thermal energy storage materials for
6 solar thermal energy power. I teach courses at Western in the areas of energy storage
7 materials, mechanics of materials, energy policy, and thermodynamics of materials.
8 Previously, I was a member of the Staff of the Oregon Public Utilities Commission
9 (2016-2019), where I worked in both resource planning and rates.As a Senior Energy
10 Analyst at OPUC I analyzed utility integrated resource plans (IRP) and related filings to
11 ensure regulatory requirements were met, represented OPUC staff in hearings and public
12 meetings, and engaged with stakeholders to ensure the Commission's mission of
13 protecting ratepayers was met. Prior to my role at OPUC, I worked as a researcher at the
14 US Department of Energy's National Energy Technology Laboratory(2011-2016).At
15 NETL I worked on multiple research portfolios related to natural gas, coal, carbon
16 storage, and rare earth elements.
17 Q. ON WHOSE BEHALF ARE YOU COMMENTING?
18 A. I am commenting on behalf of the Idaho Irrigation Pumpers Association ("IIPA").
19 Q. WHAT IS THE PURPOSE OF THE COMPANY'S APPLICATION IN THIS
20 CASE?
21 A. Idaho Power("the Company") is requesting: 1) a Certificate of Public Convenience and
22 Necessity ("CPCN") for its ownership interest in the Southwest Intertie Project North,
23 500 kilovolt("kW)transmission line ("SWIP-North" or" Project"), including the rights to
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 2
CASE NO.IPC-E-25-08

1 250 megawatts ("MW") of the northbound capacity; and 2) approval of the Company's
2 utilization of an additional 250 MW of GBT Northbound, LLC' s ("GBT Northbound")
3 rights to the northbound capacity, both via the SWIP-North agreements. In total, the
4 Company will gain 500 MW of south-to-north capacity on the total Southwest Intertie
5 Project's transmission line ("Total SWIP").
6 Q. FROM YOUR REVIEW OF THE FILING AND OTHER SOURCES,WHAT ARE
7 YOUR CONCLUSIONS AND RECOMMENDATION?
8 A. From my review of the Company's filings, models, and other resources, I recommend
9 that the Commission deny the Company's application for a CPCN and deny the approval
10 of the Company's utilization of the 250 MW GBT Northbound rights. If the Commission
11 does approve the Company's requests, I recommend that the Commission should ensure
12 that the Company's cost responsibility is limited to fully completed and operational
13 projects and to the costs claimed in the Company's current models, to protect ratepayers
14 from financial exposure.
15 Q. WHAT ARE SOME OF THE RISKS THAT THE RATEPAYERS WILL HAVE TO
16 BEAR IF THE COMPANY'S APPLICATION IS APPROVED AT THIS TIME?
17 - Cost overruns
18 - Stranded capacity and utilization risk
19 -Uncertain long term financial viability due to unaccounted for costs at decommissioning
20 and unreasonable assumptions about O&M and taxes
21 - Overreliance on CAISO as a single anchor tenant
22 - Effective capacity vs contracted capacity
23 Q. WHAT ARE THE CONSEQUENCES OF THESE RISKS?
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I A. Taken together, these factors could result in significant ratepayer exposure. The actual
2 cost could be substantially higher than claimed by the Company if these risks materialize.
3
4 Cost overruns and delays
5 Q. DO YOU HAVE ANY CONCERNS ABOUT COST OVERRUNS ASSOCIATED
6 WITH THE PROJECT?
7 A. Yes, I have concerns regarding the potential for cost overruns. While the Company states
8 that a reduced BTA fee will apply if construction costs exceed the budget or if the project
9 misses the in-service date, this measure is limited in scope'. The reduction in BTA fee
10 does not appear to fully cover the full extent of cost escalations,particularly if major
11 components (like transmission towers or battery systems) significantly increase in price
12 due to supply chain or tariff issues. In addition, the reduced fees may only partially
13 mitigate increased capital costs, which leaves ratepayers to carry the difference if the
14 actual costs substantially increase.
15 Q. ARE RATEPAYERS FULLY PROTECTED BY THE COMPANY'S CONTRACT
16 TERMS IF THE PROJECT IS NOT PLACED IN SERVICE?
17 A. No. The Company states that its cost responsibility only begins once the project is in
18 service 2. However, this does not fully protect ratepayers, as it overlooks costs incurred
19 due to project delays or partial completions. For example, environmental compliance
20 costs, interim planning expenses, and partial construction costs could still be passed on to
21 ratepayers if the project is delayed or ultimately fails.
22
1 Company's response to Staff s Request for Production No.2.
2 Id.
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I Q. WHAT ARE THE RISKS OF CAPACITY SHORTAGES OR EMERGENCY
2 RESOURCE COSTS IF THE PROJECT IS DELAYED OR FAILS?
3 A. If the SWIP-N project is delayed or fails to reach completion, the Company may face
4 capacity shortfalls, which would force it to purchase more expensive short-term capacity
5 or spot market power to meet its 2027 capacity deficit. This could expose ratepayers to
6 untold price volatility, particularly during peak demand periods or during extreme
7 weather events.Additionally, the reliance on a single large transmission project rather
8 than a diversified set of smaller capacity additions increases the risk of capacity shortages
9 if the project is compromised. Without adequate contingency planning, ratepayers could
10 also be responsible for costly emergency resources, such as mobile generation or
11 imported power at premium prices to prevent blackouts or other reliability issues.
12 Q. HOW IS A FINDING OF PRUDENCE AFFECTED BY THE COMPANY'S
13 TREATMENT OF COST OVERRUNS AND DELAYS?
14 A. A finding of prudency is undermined in light of ratepayer exposure to financial and
15 reliability risks if the project is delayed or fails.
16
17 Stranded capacity and utilization risk
18 Q. CAN YOU SUMMARIZE THE SHARED OWNERSHIP AND CAPACITY
19 ALLOCATION AS PRESENTED BY THE COMPANY?
20 A. Idaho Power will have an undivided ownership interest in approximately 11.4% of the
21 SWIP-North line, or 250 MW of capacity, while GBT will own approximately 11.4%
22 interest/250 MW These ownership interests are governed by the Definitive Agreements
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 5
CASE NO.IPC-E-25-08

I between Idaho Power and GBT, including the Participation and Joint Ownership
2 Agreement3.
3 Q. HOW DOES THE OWNERSHIP STRUCTURE OF THE SWIP-N PROJECT
4 CREATE POTENTIAL RISKS FOR RATEPAYERS?
5 A. The ownership structure of the SWIP-N project introduces significant risks to ratepayers.
6 The Company's ownership interest limits its operational control and priority access to
7 transmission capacity. In addition, this shared ownership model means that the Company
8 will have to coordinate with other owners for maintenance, scheduling, and capacity
9 allocation. If the other owners prioritize their own transmission needs or make
10 operational decisions that conflict with the Company's interests, ratepayers could face
11 higher costs or reduced reliability. This risk is particularly pronounced if GBT or other
12 majority owners reserve more capacity for their own use,potentially limiting the
13 Company's ability to fully utilize its reserved capacity.
14 Q. COULD TRANSMISSION PATH CONGESTION HINDER CAPACITY
15 UTILIZATION?
16 A. The SWIP-N line is part of a broader regional transmission network, meaning that
17 congestion on interconnected lines could further restrict the Company's ability to fully
18 utilize it's reservation. This could force Idaho Power to rely on more expensive, shorter-
19 term capacity resources to meet customer demand.
3 Company's Application in IPC-E-25-08 section 11: Once energized,the Definitive Agreements provide
for Idaho Power's undivided ownership interest in approximately 11.4 percent,or 250 MW,of SWIP-
North,fully funding the capital requirements of this portion of the Project.GBT will own the remaining
approximately 11.4 percent interest,or the remaining 250 MW,in SWIP-North,providing the asset to
Idaho Power to utilize via the Capacity Entitlement Agreement.The Company will be given the entitlement
right to utilize the approximately 250 MW of capacity for 40 years,at which time Idaho Power will have
the option to purchase the asset from GBT Northbound. The Company's rights associated with its
ownership interest and capacity entitlement interest in the Project are functionally equivalent.
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CASE NO.IPC-E-25-08

I Q. WAS THE DECISION TO PURSUE THE SWIP-N PROJECT A PRUDENT ONE
2 GIVEN THE SHARED OWNERSHIP AND CAPACITY STRUCTURE?
3 A. The shared ownership and capacity structure of the SWIP-N project raises significant
4 prudency concerns. The Company holds only a minority 250 MW ownership interest,
5 approximately 11.4% of the total SWIP-North capacity, while GBT and other parties
6 control the remaining majority. This ownership split limits the Company's operational
7 control and priority access to transmission capacity, exposing ratepayers to significant
8 financial and operational risks.
9
10 Uncertain long term financial viability due to unaccounted for costs at decommissioning
11 and unreasonable assumptions about O&M and taxes
12 Q. DO YOU HAVE ANY CONCERNS REGARDING FINANCIAL VIABILITY OF
13 THE PROJECT?
14 A. Yes, I have concerns regarding the financial viability of the project. Based on the
15 financial data provided by the Company4 the O&M, Property Tax, and Insurance costs
16 appear to be significantly underestimated, potentially exposing ratepayers to financial
17 risk. Similarly, decommissioning costs do not appear to be accounted for in the
18 Company's calculations.
19 Q. WHAT ISSUES DO YOU IDENTIFY WITH RESPECT TO THE O&M COSTS
20 PROJECTED BY THE COMPANY?
4 Response to Staff s confidential request for Production 11,confidential attachment.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 7
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1 A. The Company's model assumes average annual O&M costs of approximately � ,
2 with a narrow range of M to � per year. This is unrealistically low for a
3 high-voltage transmission project with a 55 year operational life. Transmission lines
4 require substantial ongoing maintenance, including inspections, component replacements,
5 emergency repairs, and system upgrades, all of which are likely to become more
6 expensive over time as the infrastructure ages.
7 Q. WHAT ISSUES DO YOU IDENTIFY WITH RESPECT TO THE PROPERTY TAX
8 AND INSURANCE COSTS PROJECTED BY THE COMPANY?
9 A. The annual average property tax and insurance costs are estimated at approximately
10 $1.94 million 6. This cost is likely underestimated given the high assessed value of the
11 SWIP-N infrastructure and the increasing costs of insurance premiums, particularly given
12 that the project is exposed to extreme weather and wildfire hazards across its multi-
13 decade lifespan.
14 Q. ARE DECOMMISSIONING COSTS INCLUDED IN IDAHO POWER'S
15 FINANCIAL PROJECTIONS FOR THE SWIP-N PROJECT?
16 A. Despite extensive cost modeling', there is no evidence that the Company has included
17 decommissioning costs in its financial projections for the SWIP-N project. This omission
18 is significant, as the costs associated with dismantling, removing, and restoring
19 transmission infrastructure at the end of their operational life can be substantial. The
20 financial models provided do not contain explicit line items for decommissioning
5 Average of O&M costs reported in cells D:14 to D:69 in Response to Staff s confidential request for
production 11,showing O&M costs from year 1-55.
6 Average of property tax and insurance costs reported in cells E:14 to E:69 reported in response to staff s
confidential request for production 11 showing property tax and insurance costs from years 1-55.
7 Company workpapers submitted in re: Staffs Production requests 4,6,11,12,16.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 8
CASE NO.IPC-E-25-08

I expenses, suggesting that these costs have been overlooked or deferred$. Excluding these
2 costs from the financial analysis creates a potentially misleading picture of the project's
3 long-term economics, as it fails to account for the full lifecycle costs of the transmission
4 line. This oversight exposes ratepayers to the risk of unexpected financial burdens
5 decades into the future, potentially requiring significant rate increases to cover
6 decommissioning expenses that were not included in the initial cost projections.
7 Q. DOES THE EXCLUSION OF DECOMMISSIONNING COSTS UNDERSTATE
8 RATEPAYER IMPACT?
9 A. Yes, by excluding decommissioning costs from their models, the impact to ratepayers is
10 understated. We can estimate these costs using a conservative estimate of 45% of the
11 project capital cost9.
12 Q. WHAT IS THE ESTIMATED DECOMMISSIONING COST BASED ON THIS
13 METHOD?
14 A. The Company estimates a capital cost of$135 million for its 11.4% ownership share of
15 SWIP-North.Applying the 45% factor, the decommissioning cost is $60.75 million10.
16 Q. WHAT IS THE PRESENT VALUE AND ANNUAL RATEPAYER IMPACT OF
17 THIS UNACCOUNTED FOR COST?
18 A. To estimate the ratepayer burden over time, I discounted the future $6.75 million
19 obligation using a 3% discount rate over an(assumed) 55 year asset life" to arrive at a
20 NPV of—$11.95 million. Expressed as an annual revenue requirement, I applied a capital
8 Id.
9 IPC's net salvage for transmission towers,poles,and conductors is-20,-75,and-40 respectively,an
average of-45 percent. Case No.IPC-E-21-18.IPC 2020 Depreciation Study page VI-8.
io Decom cost=0.45 * $1.35 mill=$60.75 mill.
ii NPV=60.75 mill/1.03A55= 11.95 mill.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 9
CASE NO.IPC-E-25-08

I recovery factor to arrive at an annualized cost of—$446,456 per year to ratepayers 12 that
2 is not accounted for by the Company's models in the application.
3 Q. HOW IS A FINDING OF PRUDENCY AFFECTED BY THE ISSUES YOU HAVE
4 RAISED REGARDING THE COMPANY'S FINANCIAL MODELING?
5 A. A finding of prudency is seriously undermined by the exclusion decommissioning costs
6 and underestimation of O&M costs, property tax and insurance costs. Underestimating
7 and/or excluding these costs from the Company's financial models exposes ratepayers to
8 the risk of additional and significant economic burdens, which could result in substantial
9 rate increases over the life of the project.
10
11 Overreliance on CAISO as a single anchor tenant
12 Q. HOW DOES IDAHO POWER'S RELIANCE ON CAISO AS AN ANCHOR
13 TENANT CREATE FINANCIAL RISKS FOR RATEPAYERS?
14 A. Idaho Power's reliance on the California Independent System Operator(CAISO) as an
15 anchor tenant for the SWIP-N project introduces significant financial and operational
16 risks. CAISO is expected to be a primary user of the SWIP-N line13,providing a critical
17 source of wheeling revenue that underlies the project's financial viability. However, this
18 reliance on a single major tenant creates several potential vulnerabilities.
19 Q. CAN YOU ELABORATE ON THE POTENTIAL VULNERABILITIES CAUSED
20 BY RELIANCE ON A SINGLE ANCHOR TENANT?
12 Annualized cost to ratepayers= 11.95 mill*0.03/(1-(1+0.03))^-55=446,456/year.
"Company's response to Staff s request for production 3 and Company's response to IIPA's request for
production 1-18,e.g."CAISO exiting the project would impact project viability and timeline,
though Idaho Power cannot speculate what the next steps would be in such a scenario.
The Company would however seek to acquire or contract with other resources,which
would be more costly,as evidenced by the results of the supplemental analysis presented
in Mr.Ellsworth's testimony."
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 10
CASE NO.IPC-E-25-08

I A. If CAISO reduces its usage or withdraws from the project, the Company could potentially
2 have issues recovering the fixed costs of the SWIP-N line, potentially leading to stranded
3 capacity and higher per-unit transmission costs for remaining ratepayers. There are also
4 endemic market and regulatory risks: CAISO operates within a dynamic regulatory
5 environment, so changes to market rules, transmission tariffs, or resource adequacy
6 requirements could significantly impact its need for SWIP-N capacity. This leads to
7 exposure for the Company to potentially volatile cash flows if CAISO's transmission
8 requirements change over time. Furthermore, if CAISO exits the project, the Company
9 would be forced to find replacement tenants at potentially lower rates or absorb the
10 financial impact itself, further increasing costs for ratepayers.
1 1 Q. IS A FINDING OF PRUDENCY JUSTIFIED IN LIGHT OF THE COMPANY'S
12 RELIANCE ON CAISO AS AN ANCHOR TENANT?
13 A. A finding of prudency is seriously undermined by the Company's reliance on CAISO as
14 an anchor tenant for the project. Together, the issues that I identified indicate that the
15 overreliance on CAISO as a critical revenue source may expose ratepayers to substantial
16 financial uncertainty,particularly if market conditions change or if CAISO reduces its
17 participation in the project.
18
19 Effective capacity is not contracted capacity
20 Q. HOW MUCH FIRM CAPACITY DOES THE COMPANY CLAIM TO RECEIVE
21 FROM SWIP-N?
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 11
CASE NO.IPC-E-25-08

I A. While Idaho Power has secured rights to 500 megawatts (MW) of northbound
2 transmission capacity on SWIP-North, the Company's own modeling attributes only 48
3 MW in 2028 and 86 MW in 2029 to actual system capacity needs 14
4 Q. IF THE COMPANY CONTRACTED FOR 500 MW WHY DOES THEIR MODEL
5 ONLY CREDIT 48 AND 86 MW FOR 2028 AND 2029?
6 A. That's a key concern. The 500 MW reservation reflects the total amount of transmission
7 capacity they have secured, but this capacity is only useful if it can be reliably filled with
8 generation and delivered during periods of peak need. The Company's data appears to
9 show that, in practice, less than 20% of that capacity will contribute to meeting peak
10 system demand 15. This suggests the remaining capacity is constrained, either due to lack
11 of firm upstream generation, transmission congestion, or other operational limits.
12 Q. DOES THE COMPANY CLAIM SEASONAL BENEFITS FROM SWIP-N
13 BEYOND THE 86 MW?
14 A. Yes. However, these additional claims rely on a modeling maneuver that shifts the system
15 risk around to accommodate a large increase in winter load, rather than actually
16 increasing the true year round deliverable capacity. Specifically, the Company argues that
17 SWIP-N allows them to meet increased load in the winter months 16, which allows the
18 model to be more aggressive, or"risk-tolerant" in the summer. In other words, rather
14 Company's supplement responses to Staff s second production request,table 2
15 Id
"Company's supplement responses to Staff s second production request:As seen in Tables 3 and 4,in
addition to an improved annual position, SWIP-North boosts the winter position.Recall,the Loss of Load
Expectation(LOLE)threshold is 0.1 event days per year and is presented as an annual value.Absent the
addition of SWIP-North,ere is high risk in both the summer and winter months,and therefore each of those
seasons are using some of the 0.1 LOLE budget from lower risk time periods.Following IP-North,the
winter risk is significantly reduced,and therefore the summer can be located more of the LOLE budget and
therefore the annual capacity position is reduced.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 12
CASE NO.IPC-E-25-08

I than showing that SWIP-N adds more capacity, they assume it lets them"borrow" from
2 the winter reliability budget to cover summer shortfalls.
3 Q. WHY IS THIS MODELING APPROACH MISLEADING?
4 A. This modeling approach gives the impression that SWIP-N contributes far more capacity
5 than it actually does. In reality, the only quantified contribution is the 48 MW and 86
6 MW cited in their annual capacity tables. The rest of the "benefit"comes from
7 reshuffling the loss-of-load expectation(LOLE) budget between seasons, a move that
8 relies on favorable assumptions rather than actual physical deliverability17. It's a bit like
9 claiming a new bridge solves a traffic problem because it lets you close an older road at
10 night. The logic may look clean on paper, but it doesn't change the fact that the system
11 still needs more firm, year round resources.
12 Q. WHAT OTHER EXPLANATION IS THERE FOR THIS RESOURCE
13 ACQUISITION IF NOT FOR SUMMER CAPACITY NEED?
14 A. This resource appears to be intended to address winter energy needs rather than summer
15 capacity needs. In fact, the total capacity of this resource, 500 MW, coincidentally
16 matches Micron's new 500 MW special contract, which has a substantial winter energy
17 need. Its possible that this is not a coincident and the transmission facility is a direct
18 consequence of the Micron contract.
19 Q. CAN YOU PLEASE SUMMARIZE YOUR TESTIMONY?
17 Note,tables 3 and 4 of Company's supplemental responses to Staff s second production request show
seasonal detail but don't appear to align with table 2 because the Company seems to have re-normalized
LOLE and shifts capacity margins across seasons in table 4 to argue that the reduced winter risk from
SWIP-N lets them reallocate LOLE budget to summer and claim the overall system is more reliable even if
the raw summer margins don't improve.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 13
CASE NO.IPC-E-25-08

I A. The Commission should deny Idaho Power's request for the issuance of a CPCN for its
2 ownership interest in the Southwest Intertie Project North, 500 kilovolt("kV")
3 transmission line including the rights to 250 MW of the northbound capacity; and 2) deny
4 the approval of the Company's utilization of an additional 250 MW of GBT Northbound,
5 LLC's rights to the northbound capacity, both via the SWIP-North agreements. My
6 testimony described the major issues with the Company's proposal and supporting
7 models, including risks associated with potential cost overruns; risks of stranded capacity
8 and utilization potential; issues with the Company's models and assumptions regarding
9 O&M and insurance and tax cost; and overreliance on CAISO as a single anchor tenant.
10 Together, these issues suggest that the SWIP-N project, as currently proposed, cannot
11 meet the standard for prudent utility management and could expose ratepayers to
12 substantial financial and operational risks over the long term. While the Company's
13 argument for granting of the CPCN relies on tenuous assertions regarding cost benefits, a
14 finding of prudency is not just about possible benefits to ratepayers,but also requires
15 minimization of risk for ratepayers. The potential downsides I have articulated in these
16 comments demonstrate that risks to ratepayers are poorly constrained, and a finding of
17 prudency cannot be supported. If the Commission does approve the Company's requests
18 it should ensure that Idaho Power's cost responsibility is limited to fully completed and
19 operational projects and to the costs claimed in the Company's workpapers supporting
20 this application, to protect ratepayers from financial exposure during partial or failed
21 project builds.
22 Q. DOES THIS CONCLUDE YOUR COMMENTS?
23 A. Yes.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 14
CASE NO.IPC-E-25-08

1
DATED this 171h day of July, 2025. /
DEBORAH GLOSSER
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 15
CASE NO.IPC-E-25-08

CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 17t'day of July, 2025, 1 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)
secretga&puc.Idaho.gov
chris.burdin(&,puc.Idaho.gov
Donovan Walker ❑ U.S. Mail
Tim Tatum ❑ Hand Delivered
Idaho Power Company ❑ Overnight Mail
1221 W. Idaho Street(83702) ❑ Telecopy (Fax)
P.O. Box 70 ® Electronic Mail (Email)
Boise, ID 83707
dwalker&idahopower.com
dockets(aidahopower.com
ttatumkidahopower.com
Lance Kaufinan, Ph.D. ❑ U.S. Mail
2623 NW Bluebell Place ❑ Hand Delivered
Corvallis, OR 97330 ❑ Overnight Mail
lance&ae isg insi hg t.com ❑ Telecopy (Fax)
® 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 17t' Street Suite 3200
Denver, CO 80202
darueschhoff khollandhart.com
tnelson(a,hollandhart.com
awj ensen(khollandhart.com
karoach(&,,hollandhart.com
acleekhollandhart.com
-
C
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 16
CASE NO.IPC-E-25-08