20250731Reply Comments - Redacted.pdf

0-10AM POWER.
DONOVAN WALKER RECEIVED
Lead Counsel July 31, 2025
dwalker(ajidahopower.com IDAHO PUBLIC
UTILITIES COMMISSION
July 31, 2025
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-25-08
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
Dear Commission Secretary:
Attached for electronic filing, please find Idaho Power Company's Reply
Comments in the above-entitled matter.
In a separate encrypted email, I will send the confidential version to the parties
who sign the Protective Agreement.
If you have any questions about the attached 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 A ) CASE NO. IPC-E-25-08
CERTIFICATE OF PUBLIC )
CONVENIENCE AND NECESSITY FOR ) IDAHO POWER COMPANY'S
AN OWNERSHIP INTEREST IN THE ) REPLY COMMENTS
SOUTHWEST INTERTIE PROJECT - )
NORTH 500-KV TRANSMISSION LINE )
AND APPROVAL OF THE UTILIZATION )
OF CAPACITY ON THE LINE. )
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and,
pursuant to Idaho Public Utilities Commission's ("Commission") Rules of Procedure 201-
204 and the Notice of Modified Procedure, Order No. 36630, hereby respectfully submits
the following Reply Comments in response to Comments filed by Commission Staff
("Staff") and the Idaho Irrigation Pumpers Association, Inc. ("IIPA") on July 17, 2025. In
addition, the Company will respond to public comments submitted by Representative
David Leavitt ("Rep. Leavitt") and Stop Lava Ridge, Inc. ("SLR").
IDAHO POWER COMPANY'S REPLY COMMENTS - 1

I. BACKGROUND
1. The Southwest Intertie Project— North, 500-kilovolt (*V") transmission line
("SWIP-North" or "Project") is an approximately 285 mile, near shovel ready, 500-kV line
that will connect the Midpoint substation, near Shoshone, Idaho, to the Robinson Summit
substation, near Ely, Nevada. SWIP-North will connect to the existing Southwest Intertie
Project—South 500-kV line ("SWIP-South"), an existing 231 mile 500-kV line that extends
between the Robinson Summit Substation and the Harry Allen Substation, northeast of
Las Vegas. When combined, SWIP-North and SWIP-South form the Total SWIP.
2. The ownership and capacity entitlements associated with SWIP-South, as
well as SWIP-North and Total SWIP once completed, are all governed by the Second
Amended and Restated Transmission Use and Capacity Exchange Agreement by and
among Nevada Power Company, Sierra Pacific Power Company, Great Basin
Transmission South, LLC, and Great Basin Transmission, LLC, dated as of June 30, 2020
("TUX), which is included as Exhibit No. 2 to Mr. Jared Ellsworth's Direct Testimony.
SWIP-South, the first phase of the Project, has been providing NV Energy benefits over
the prior decade. SWIP-North is nearly construction ready and planned to be online in
2028. As such, Project developer Great Basin Transmission, LLC ("GBT") began
negotiations to contract the additional capacity entitlements gained along Total SWIP
once SWIP-North is energized, including dedicating all its capacity entitlements to
California Independent System Operator ("CAISO") except for 500 MW of south-to-north
capacity entitlements, which will be dedicated to Idaho Power.
3. The Company's participation in, and joint ownership of, SWIP-North has
been memorialized in the following agreements for which Idaho Power is requesting
IDAHO POWER COMPANY'S REPLY COMMENTS -2

approval in this case: (1) the Participation and Joint Ownership Agreement by and among
Great Basin Transmission, LLC, GBT Northbound, LLC and Idaho Power Company dated
as of February 13, 2025 ("Participation and Joint Ownership Agreement"), (2) the
Capacity Entitlement Agreement by and between GBT Northbound, LLC and Idaho Power
Company dated as of February 13, 2025 ("Capacity Entitlement Agreement"), (3) the
Purchase and Sale Agreement by and between GBT Northbound, LLC and Idaho Power
Company dated as of February 13, 2025, and (4) the Purchase Option Agreement by and
between GBT Northbound, LLC and Idaho Power Company dated as of February 13,
2025 (collectively, the "Definitive Agreements"). The Definitive Agreements are included
as Confidential Exhibit No. 5 to Mr. Jared Ellsworth's Direct Testimony.
4. 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.
5. In these Reply Comments, Idaho Power responds to the recommendation
of Staff and addresses IIPA's concerns with financial risk and prudency associated with
the Company's ownership interest and capacity entitlement interest in SWIP-North and
the proposed cost containment measures resulting from those concerns. Idaho Power will
IDAHO POWER COMPANY'S REPLY COMMENTS - 3

also respond to Rep. Leavitt and SLR's mischaracterization of the Company's
participation in the Project and the resulting recommendation that the Commission deny
Idaho Power's request in this proceeding. The Commission should accept Staff's proposal
granting the CPCN and approving the Company's utilization of an additional capacity
entitlement but reject the unfair and unwarranted (1) cost containment measures
recommended by IIPA, (2) statutory moratorium recommended by Rep. Leavitt, and (3)
conditions SLR proposes be imposed.
II. REPLY COMMENTS
A. The Commission Should Adopt Staff's Recommendation to Issue a CPCN for
an Ownership Interest in SWIP-North and Approve Utilization of Additional
Capacity on the Line.
6. Idaho Power first analyzed SWIP-North as part of the 2021 Integrated
Resource Plan ("IRP"), evaluating a hypothetical scenario that identified potential benefits
associated with the Project. The Company subsequently acquired sufficient information
from GBT to perform a thorough and detailed analysis coincident with the modeling of the
2023 IRP; SWIP-North was analyzed as providing a 500 MW resource equivalent
capacity, from the Desert Southwest ("DSW") market, in the winter months beginning in
2028. The best way to identify a transmission project's financial benefits is to consider the
optimal portfolio of transmission and generation projects (i.e., the least-cost and least-risk
portfolio) both with the transmission project and without the transmission project.
Therefore, Idaho Power analyzed ten portfolio topologies without SWIP-North and those
same ten portfolio topologies with SWIP-North, utilizing a November 2028 in-service date.
The results indicated that a portfolio inclusive of SWIP-North was lower cost than its
IDAHO POWER COMPANY'S REPLY COMMENTS -4

complementary portfolio that excluded SWIP, an estimated lower cost on a
net present value basis.
7. Idaho Power appreciates Staff's comprehensive analysis of the Company's
request in this case and their recommendation that the Commission (1) grant a CPCN for
ownership interest in the Project including the rights to approximately 11.4 percent of the
northbound capacity, and (2) approve the Company's utilization of an additional
approximately 11.4 percent of northbound capacity via the Capacity Entitlement
Agreement. Staff performed an extensive review in this proceeding, evaluating the costs,
unquantifiable benefits, and various risks associated with the Project. Staff agreed that
Idaho Power's analysis of ten portfolio topologies both with SWIP-North and without
SWIP-North "shows a substantial net present value ("NPV") savings [emphasis added]"
citing both the analysis performed as part of the 2023 IRP as well as an updated analysis
performed at Staff's request which indicated savings of more than �.' As Staff
noted, the cost-effectiveness of SWIP-North is even greater when considering the
expenditures associated with the two capital projects that can be deferred once the
Project is in-service and with the anticipated increase in wheeling revenues due to the
sale of unutilized capacity.2
8. In addition to acknowledging the cost-effectiveness of SWIP-North, Staff
highlights the unquantifiable benefits of the Project including "the alleviation of
transmission congestion, the high reliability of transmission lines as a resource, and the
increased access to diverse markets to offset regional price volatility,"3 agreeing that the
Staff Comments, page 4.
2 Id., page 5.
3 Id.
IDAHO POWER COMPANY'S REPLY COMMENTS - 5

benefits exist and are appropriately considered. Further, Staff agrees with the Company's
assessment that due to the Project's late stage in development the reduced risk is a
significant benefit when compared to resource alternatives.4 With major federal permits
secured, nearly all right-of-way easements secured, major materials secured, and a
construction contract in progress, Staff "considers the SWIP-North path to completion to
be a significant benefit"5 not a "substantial risk"6 as suggested by Rep. Leavitt. Finally,
while Staff identified potential risks associated with the availability of energy purchases
from the DSW market, obtaining the remaining permits, cost overruns, and CAISO
remaining a participant in the Project, but acknowledged the risks are reasonable and the
Company has appropriately considered such risks.'
9. Through their review, Staff concluded that Idaho Power met the
requirements of Idaho Code §61-526 showing the public convenience and necessity and
financial ability for ownership in the Project.$ Further, Staff concluded that based on the
net benefits associated with the additional northbound capacity on SWIP-North, the
Company's participation in utilization of that capacity via the Capacity Entitlement
Agreement should be approved.9The Commission should accept Staff's recommendation
to grant the CPCN and approve Idaho Power's utilization of additional northbound
capacity.
4 Id.
5 Id.
6 Rep. Leavitt Comments, page 2.
Staff Comments, pages 6-7.
8 Id., page 8.
9 Id.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6

B. The Company's Modeling of SWIP-North Appropriately Captured the Costs
and Benefits associated with the Project and Led to its Identification as a
Least-Cost, Least-Risk Resource.
10. In their Comments, IIPA, SLR, and Rep. Leavitt are critical of Idaho Power's
modeling of the SWIP-North costs and benefits. In response, the Company addresses
and provides clarification on the following: (1) Idaho Power considered the potential for
cost increases or cost overruns associated with SWIP-North and appropriately estimated
and modeled the Project costs, and (2) the modeling of the DSW market capacity was
reasonable.
L Idaho Power considered the potential for cost increases or cost
overruns associated with SWIP-North and appropriately estimated and
modeled the Project costs.
11. In their comments, both IIPA and SLR express concerns about the potential
cost increases or overruns, noting the resulting financial pressure Idaho customers could
experience with higher costs.10 Idaho Power is cognizant of the impact the Project will
have on customer rates but notes that the Company has an obligation to provide
adequate, efficient, just, and reasonable service on a nondiscriminatory basis to all those
that request it within its certificated service area. As explained in discovery," given the
current state of growth in southern Idaho, meeting reliability requirements necessitates
incremental projects, and SWIP-North is highly cost-effective when comparing a portfolio
with the project, to a reliable portfolio without the project.
10 IIPA Comments, page 4 and SLR Comments, page 26.
" See the Company's Response to Staff's Request for Production No. 2.
IDAHO POWER COMPANY'S REPLY COMMENTS - 7

12. SLR appears to misunderstand the impact a cost increase has on the
revenue requirement of the Project. A $140 million increase in project costs does not
equate to a $10 million a month impact to customers as suggested by SLR.12 Aside from
being responsible for only Idaho Power's share of the costs, which is based on the
Company's capacity entitlements, SWIP-North capital costs will be recovered over the life
of the asset, or 55 years, not one year as SLR indicates. IIPA also expressed concerns
about Project costs utilized for modeling of the resource indicating Idaho Power's estimate
of operations and maintenance expenses and property taxes are "significantly
underesti mated"13 yet provides no data to support the claim. As described in the Direct
Testimony of Mr. Jared Ellsworth, the Company calibrated the SWIP-North costs against
its most recent cost estimates for the Boardman-to-Hemingway line and found the
estimate to be both thorough and reasonable for a 500-kV transmission line.
13. IIPA also criticizes the exclusion of decommissioning costs from the
modeling of resources as part of the IRP but fails to recognize that none of the potential
resource additions modeled included decommissioning cost estimates. Had
decommissioning costs been considered, the cost of all resources would have increased,
and the results of the 2023 IRP portfolio analyses would likely be unchanged. Idaho
Power appropriately modeled SWIP-North costs, and with a portfolio inclusive of the
Project, quantified as an estimated lower cost on a net present value basis,
finding SWIP-North, when compared to alternative resources, is both a least-cost and
least-risk resource.
12 SLR Comments, page 26.
13 IIPA Comments, page 7.
IDAHO POWER COMPANY'S REPLY COMMENTS - 8

ii. Modeling of the DSW market capacity was reasonable.
14. Primarily considering the Project as providing non-summer benefits, the
Company modeled the DSW market connection as providing 500 MW of non-summer
resource adequacy capacity, for all months other than June through September, starting
November 1, 2028, through the remainder of the 20-year IRP planning horizon. Rep.
Leavitt suggests Idaho Power's "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.1114 Yet, Exhibit No. 7 to Mr. Ellsworth's
Direct Testimony presented the peak load data in the DSW, excluding California, noting
that the peak load in the summer season is over 80 percent higher than the maximum
winter peak, indicating the potential for excess capacity in the winter season from the
southwest markets to help meet future peak demand needs for Idaho Power during
winter.
15. Furthermore, because the data is based on historical data, the excess
capacity is a result of existing resources and therefore not subject to the OBBBA. In
addition, there is 8,500 MW more installed capacity of dispatchable natural gas resources
than forecast maximum winter load for the area.15 New generation is not required to
support the DSW market assumptions as suggested by SLR,16 existing generation
supports the modeling assumptions. The DSW market assumptions are not speculative,
rather they are based on actual peak load and generation data that is not impacted by
the elimination of tax incentives under the OBBBA.
14 Rep. Leavitt Comments, page 2.
15 Direct Testimony of Mr. Jared Ellsworth, page 55, lines 18-21.
16 SLR Comments, pages 20-21.
IDAHO POWER COMPANY'S REPLY COMMENTS - 9

C. Idaho Power's Clarification of SWIP-North Characteristics and Attributes.
16. In their Comments, IIPA, SLR, and Rep. Leavitt make a number of
statements regarding the Project that are incorrect or unsubstantiated. In response, the
Company addresses and provides clarification on the erroneous declarations and
mischaracterizations.
L The Project has obtained the majority of the necessary permits.
17. Both Rep. Leavitt and SLR discuss the remaining permits necessary for
construction of SWIP-North and suggest denial of Idaho Power's request in this case until
they are received.' While the Company believes the Project is significantly de-risked due
to its late stage in development, Idaho Power understands the concerns expressed.
However, because the Definitive Agreements contain provisions that transfer capacity
entitlements upon commercial operation, should permits not be received, commercial
operation will not occur. The granting of a CPCN and approval of the utilization of
additional capacity on the line does not need to be deferred until all necessary permits
are received as the contractual provisions limit the financial risk should permits not be
received.
ii. The Company Will Obtain 500 MIN of South-to-North Capacity
Entitlements on SWIP-North.
18. IIPA expresses concerns with Idaho Power's access to transmission
capacity on SWIP-North, suggesting the Company will have limited operational control
and priority access, indicating other majority owners may use the capacity for their own
use.18 These concerns are unfounded. As noted by IIPA, Idaho Power's ownership
" Rep. Leavitt Comments, page 2 and SLR Comments, page 2.
'$ IIPA Comments, page 6.
IDAHO POWER COMPANY'S REPLY COMMENTS - 10

interest and utilization of capacity entitlements are governed by the Definitive
Agreements.19 As defined in the Participation and Joint Ownership Agreement, upon
commercial operation, the Company will purchase an ownership interest in the Project,
including the rights to the northbound capacity entitlement. Similarly, under the Capacity
Entitlement Agreement, upon commercial operation, Idaho Power will obtain an additional
northbound capacity entitlement. At this point, transmission service will be governed by
the Company's Open Access Transmission Tariff and transmission service must be
requested for by a transmission customer prior to any use of the Company's capacity
entitlements. Idaho Power will have priority access of the transmission capacity as
defined by the Definitive Agreements.
iii. SW/P-North project mischaracterizations.
19. In their Comments, SLR discusses at length the Lava Ridge wind project,20
indicating a connection to SWIP-North. As noted in Mr. Jared Ellsworth's Direct
Testimony,21 LS Power Development is a major energy development company. Magic
Valley Energy, LLC, a subsidiary of LS Power, is developing the Lava Ridge and Salmon
Falls wind generation projects in southern Idaho. SWIP-North is a transmission-only
project that is entirely independent of the Lava Ridge and Salmon Falls projects therefore
any correlation SLR makes is false. As noted by Staff, the Company will obtain south-to-
north capacity, enabling power to be imported to Idaho;22 Idaho Power will not have north-
to-south capacity entitlements. Additionally, Idaho Power has full control over the output
of its Company owned and contracted resources, so suggesting that California is going
19 Id., page 5.
21 Id., pages 2, 5, 8-16, 19-20, and 24-25.
21 See footnote 2, page 8.
22 Staff Comments, page 8.
IDAHO POWER COMPANY'S REPLY COMMENTS - 11

to take those resources, presumably against the will of the Company, lacks any
foundation or basis in reality. Idaho Power always has, and will continue to, maximize the
value of its resources to the benefit of Idaho Power's retail customers.23
20. The Project is not structurally risky or politically entangled.24 SWIP-North is
nearly construction ready, planned to be online in 2028, and all capacity entitlements
gained along Total SWIP once the Project is constructed have been contracted for,
including the dedication of all its capacity entitlements to CAISO with the exception of the
500 MW of south-to-north capacity entitlements which will be dedicated to Idaho Power.
CAISO's participation however does not introduce significant financial and operational
risk as suggested by IIPA.25 If CAISO exits participation, the project viability and timeline
would likely be impacted, and because the Company will only incur costs associated with
SWIP-North if the project is ultimately placed in service, the financial risk is minimized.
III. CONCLUSION
21. Idaho Power acknowledges and appreciates the parties' review of the
Company's application and respectfully requests the Commission (1) accept Staff's
recommendation to (1) grant a CPCN for Idaho Power's ownership interest participation
in the SWIP-North 500-kV transmission line, including the rights to 250 MW of the
northbound capacity, (2) approve the Company's utilization of an additional 250 MW of
northbound capacity via the Capacity Entitlement Agreement, and (3) reject the (i) cost
containment measures recommended by IIPA, (ii) statutory moratorium recommended by
Rep. Leavitt, and (iii) conditions SLR proposes be imposed. SWIP-North, when compared
23 SLR Comments, page 24.
24 Rep. Leavitt Comments, page 1.
25 TTPA Comments,page 10.
IDAHO POWER COMPANY'S REPLY COMMENTS - 12

to alternative resources, is both a least-cost and least-risk resource, and a necessary
component of the Company's future resource portfolio.
DATED at Boise, Idaho this 31St day of July 2025.
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 13

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 31St day of July, 2025, 1 served a true and correct
copy of Idaho Power Company's 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
Kristine A.K. Roach X Email darueschhoff(a)hollandhart.com
Holland & Hart LLP tnelson hol land hart.com
555 17th Street, Suite 3200 awiensen(a)hollandhart.com
Denver, CO 80202 aclee hollandhart.com
karoach(a)hol land hart.corn
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 [e-mail]
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
Stacy Gust,
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 14