The URL can be used to link to this page

Home My WebLink About20250814Application for Intervenor Funding.pdf RECEIVED August 14, 2025 IDAHO PUBLIC Eric L. Olsen(ISB#4811) UTILITIES COMMISSION ECHO HAWK& OLSEN, PLLC 505 Pershing Ave., Ste. 100 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-25-08 COMPANY'S APPLICATION FOR A CERTIFICATE OF PUBLIC APPLICATION FOR INTERVENOR CONVENIENCE AND NECESSITY FOR FUNDING OF THE IDAHO AN OWNERSHIP INTEREST IN THE IRRIGATION PUMPERS SOUTHWEST INTERTIE PROJECT— ASSOCIATION,INC. NORTH 500-KV TRANSMISSION LINE AND APPROVAL OF THE UTILIZATION OF CAPACITY ON THE LINE. 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. APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 1 CASE NO.IPC-E-25-08 (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. Glosser") participated in Idaho Power Company's ("IPC") Certificate of Public Convenience ("CPCN") and Necessity for an Ownership Interest in the Southwest Intertie Project—North 500- Kv Transmission Line ("SWIP-North" or" Project") and Approval of the Utilization of Capacity on the Line case. Mr. Olsen, Dr. Kaufman and Dr. Glosser reviewed and analyzed the Company's positions,prepared and served written discovery, and prepared written comments. Dr. Glosser's review uncovered critical risks that the Project faces that would likely result in higher Project costs than IPC's forecast. Specifically, Dr. Glosser raised concerns that cost escalations due to potential delays for the in-service date and supply chain or tariff issues that would not be offset by reduced BTA fees payable upon delay. If the Project is not completed, Dr. Glosser pointed out that IPC's ratepayers would still be on the hook for all of IPC's sunk costs and would be exposed to capacity shortfalls and higher costs associated with higher cost substitutes. Given IPC's 11.2% ownership of northbound capacity, means that IPC does not have operational control of the transmission line and could take a backseat other owners' transmission needs and maintenance schedule. Dr. Glosser also pointed out that IPC's analysis of the Project underestimated O&M, Property Tax, Insurance Costs and decommissioning costs and it also is heavily reliant on its anchor tenant, CAISO. Given all these risks, IIPA recommended that the IPC's application be denied or, if approved, that the Commission limit ratepayers' cost responsibility to actually completed and operational projects in accordance with the costs claimed in IPC's current models. (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 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 2 CASE NO.IPC-E-25-08 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 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 found the modeling maneuver used would shift system risk to accommodate a large increase in winter load, rather than true year round capacity. That total capacity of resource is 50OMW which coincidentally matches Micron's new 50OMW special contract that has a substantial winter need. IIPA found that the IPC failed to demonstrate that the SWIP-N meets the APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 3 CASE NO.IPC-E-25-08 standard for prudent utility management and could expose ratepayers to substantial increased costs and unaccounted for operation risks. The IIPA requested if approval is given that the Commission should ensure that IPC's cost responsibility is limited to fully completed and operational projects and to the costs claimed in the Company's workpapers supporting this application, to protect ratepayers from financial exposure during partial or failed project builds. (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 24 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 14`h day of August, 2025. ECHO HAWK& OLSEN ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 4 CASE NO.IPC-E-25-08 CERTIFICATE OF SERVICE I HEREBY CERTIFIY that on this 14th day of August, 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(&j2uc.idaho.gov chris.burding]2uc.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 dwalkera idahopower.com dockets gidahopower.com ttatum(c�r�,idahopower.com Lance Kaufman, Ph.D. ❑ U.S. Mail 2623 NW Bluebell Place ❑ Hand Delivered Corvallis, OR 97330 ❑ Overnight Mail lancea,a,aegisinsi 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 17th Street Suite 3200 Denver, CO 80202 darueschhoff(ci,hollandhart.com tnelson(&,hollandhart.com awj ensen(ab,hollandhart.com karoach(a,hollandhart.com aclee(&,hollandhart.com ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 5 CASE NO.IPC-E-25-08 EXHIBIT A Expert Witnesses: Deborah Glosser and Lance Kaufman,Expenses: 1. Witness Fees: 49.96 Hours @ $250 = $ 12,490.00 Sub Total: $ 12,490.00 Legal Expenses: 1. Paralegal Fees: 4.5 Hours @ $155 = $ 697.50 2. Legal Fees Eric L. Olsen: 5.3 Hours @ $250 = $ 1,325.00 3. Soft Costs (Copies/Legal Research) $ 13.20 Sub Total: $ 2,035.70 Grand Total: $ 14,525.70 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 6 CASE NO.IPC-E-25-08