20250721Comment_1.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR AN OWNERSHIP
INTEREST IN THE SOUTHWEST INTERTIE
PROJECT—NORTH 500-KV TRANSMISSION
LINE AND APPROVAL OF THE
UTILIZATION OF CAPACITY ON THE LINE
CASE NO. IPC-E-25-08
COMMENTS OF REPRESENTATIVE DAVID LEAVITT
Representative David Leavitt respectfully submits the following comments in the matter
of Idaho Power Company's request for a Certificate of Public Convenience and Necessity
(CPCN) and approval of capacity utilization related to the Southwest Intertie Project
North(SWIP-North). These comments are submitted on behalf of myself and the
ratepayers of Idaho who will be materially affected by the decisions in this docket.
Although this comment is submitted one day after the July 17, 2025 deadline, it addresses
substantial issues of public concern that directly affect Idaho ratepayers, landowners, and
the long-term energy sovereignty of the state. I respectfully request that the Commission
accept this late filing into the record pursuant to procedural fairness and the public
interest exception.
POSITION
I oppose the issuance of a CPCN for Idaho Power's proposed 250 MW ownership share
in SWIP-North and the approval of an additional 250 MW under the Capacity
Entitlement Agreement with GBT. This project is structurally risky,politically entangled,
and fails to meet the threshold of serving Idaho's long-term public convenience and
necessity.
CORPORATE PRIORITY OVER PUBLIC INTEREST
This project is being advanced primarily to benefit corporate stakeholders, including
Micron, and regional energy market participants. CAISO will own 77% of the SWIP-
North transmission line and control over 1,100 MW of southbound export capacity. The

claim that Idahoans are "only paying for northbound capacity" fails to acknowledge the
real-world consequences to Idaho landowners and communities who must host this
infrastructure—regardless of directionality.
PERMITTING AND ENVIRONMENTAL UNCERTAINTY
The project lacks critical federal permits, including the final BLM cultural review and the
Robinson Summit substation expansion. Advancing a CPCN without these approvals
exposes Idaho ratepayers to substantial risk of delay and stranded cost. The permitting
status is unresolved, and a prudent regulatory body should not issue a CPCN for a
transmission line that may not be legally completed.
IRP-BASED APPROVAL IGNORES MARKET VOLATILITY
The justification for this project hinges on Idaho Power's 2025 Integrated Resource Plan
(IRP), which relies on assumptions of consistent Desert Southwest capacity surplus and
market cooperation. These assumptions are speculative—especially following the
passage of the One Big Beautiful Bill Act(OBBBA), which eliminates tax incentives for
renewable energy and battery storage systems. That legislation fundamentally alters the
economics behind the Company's forecasts and undermines their case for a"least-cost,
least-risk" solution.
SOVEREIGNTY AND LAND USE IMPACTS
SWIP-North intertwines Idaho's energy infrastructure with out-of-state market operators
and undermines our sovereign ability to control transmission decisions within our
borders. It imposes long-term burdens on private landowners, farmers, and rural
communities, many of whom will never see a direct benefit from this project. A project
of this scale and complexity should not proceed without full public buy-in and complete
legal clearance.
CONCLUSION AND REQUEST
Given the unresolved permitting, speculative benefits, and growing public opposition, I
respectfully urge the Commission to:
1. Deny the Certificate of Public Convenience and Necessity and the Capacity
Entitlement Agreement, or at minimum;
2. Impose a statutory moratorium pending full permitting, cost-benefit reassessment
under post-OBBBA market conditions, and a thorough evaluation of long-term

sovereignty impacts to Idaho ratepayers.
Idaho must not become a passive corridor for out-of-state energy priorities. We must
defend our land, our people, and our authority over the future of our grid.
Respectfully submitted this 18th day of July, 2025.
Representative David Leavitt
Idaho House of Representatives
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT ON THIS 18TH DAY OF JULY 2025, I SERVED THE
FOREGOING COMMENTS OF REPRESENTATIVE DAVID LEAVITT IN CASE
NO. IPC-E-25-08 BY E-MAILING A COPY THEREOF TO THE FOLLOWING
PARTIES OF RECORD:
Idaho Power Company:
DONOVAN E. WALKER—[e-mail]
TIM TATUM—[e-mail]
Micron Technology, Inc.:
AUSTIN RUESCHHOFF—[e-mail]
THORVALD A. NELSON—[e-mail]
AUSTIN W. JENSEN—[e-mail]
KRISTINE A.K. ROACH—[e-mail]
Idaho Irrigation Pumpers Association, Inc.:
ERIC L. OLSEN—[e-mail]
LANCE KAUFMAN, PH.D. —[e-mail]