20250829Comment_1.pdf

From:W. Alan Schroeder<[e-mail]>
Sent: Friday, August 29, 2025 2:02 PM
To: secretary<[e-mail]>
Cc: [e-mail]; Skip Owen <[e-mail]>; John Arkoosh
<[e-mail]>; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail];
dan@sakura con servationstrategies.com; Elaine Anderson <[e-mail]>
Subject: IDAHO POWER COMPANY--APPLICATION DATED MARCH 7, 2025, Case Number
I PC-E-25-08.
Monica Barrios-Sanchez, Commission Secretary, Idaho Public Utilities Commission:
Please find attached public comments to the Application dated March 7, 2025. The
commenters requested that our office submit them to you via email.
Please call or email with any questions. Otherwise, we would appreciate your
acknowledgement of receipt of this email. If you also require another form of service
beyond email, please also advise.
Thank you,
Alan Schroeder
Schroeder Law
Tulip S Building, Suite 110
1449 South David Lane
Boise, Idaho 83705-3174
Telephone: [phone]
Direct Line: 208-384-0825
Email: alan schroederlaw.net
Website: www.schroederLaw.net
Linkedin: https://www.Linkedin.com/in/w-alan-schroeder-b4a82732

SHEEPHOOK CATTLE GRAZING ASSOCIATION, TUNUPA GRAZING ASSOCIATION, LLC
LLC Attn: John Arkoosh
Attn: Skip Owen 2388 East 1775 South
1959 S.E. Ross Road Gooding, Idaho 83330
Glenns Ferry, Idaho 83623
WILLIAMARKOOSH BLACK BUTTE HILLS LLC
ESTATE OF WILLIAMARKOOSH CAMAS CREEK CATTLE ASSOCIATION LLC
2005 U.S. Hwy Attn: Rod Gonsales
Gooding, Idaho 83330 P.O. Box 333
Fairfield, Idaho 83327
August 29, 2025
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Re: IDAHO POWER COMPANY--APPLICATION DATED MARCH 7, 2025, FOR A
CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR AN
OWNERSHIP INTEREST IN THE SOUTHWEST 1NTERTIE PROJECT -NORTH
500-KV TRANSMISSION LINE AND APPROVAL OF THE UTILIZATION OF
CAPACITY ON THE LINE, Case Number IPC-E-25-08. See Case Details - IPUC
(hotlink last checked 8/29/2025 @ 11:49 A.M.).
Dear Commission Secretary:
We are aware of the Application dated March 7, 2025, in Case Number IPC-E-25-08, as
referenced above (hereinafter referred to as "Idaho Power Application"). We write/comment in
opposition to the Idaho Power Application.
We respectfully request that the Commission include these comments in the record of this
proceeding, as they include new policy developments and information relating to the harmful
impacts that the SWIP-N line would have on public lands grazing.
We also respectfully request that the Commission amend its Notice of Modified
Procedure (Order 36630) in this proceeding to reopen the public comment period through
December 15, 2025. We are full-time ranchers who have been working to protect their
livelihoods from harmful federal wind project permits for both the Lava Ridge and Taurus
projects. This request is based in part on the Federal Energy Regulatory Commission("FERC")
August 19, 2025 Letter of Deficiency sent to Great Basin Transmission requesting it submit
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additional information to FERC within 30 days (September 18, 2025) regarding congestion and
reliability analysis for SWIP-N in light of the DOI cancellation of Lava Ridge and relating to
south-to-north transmission from Nevada. FERC will have 60 days from the date Great Basin's
amended application to issue an order regarding rate incentives. The congestion and reliability
information and FERC order on rate incentives will assist the Commission in its consideration of
the Idaho Power Application in this proceeding.
COMMENTERS:
We are a group of individuals/entities that own and operate yearlong livestock
operations within Lincoln County and Jerome County, State of Idaho, which is dependent by use
upon, among others, the public lands in the Star Lake, Antelope, Sand Butte, Quail, Short Line,
River, Lava Pot, Long Gulch, Fairfield, Piney, Mill Canyon, Springdale, Hash Springs, Schooler
Creek, Seven Mile, Gunnery, Rough Creek, Sheep Point, and McHan Creek, Allotments, which
are all within the administrative boundary of the Shoshone Field Office, Twin Falls District,
Idaho, Bureau of Land Management, U.S. Department of the Interior(`BLM"). See Attachment
#1 (which is a Map of the general area of the above-named Allotments).
Some of these operations can trace their existence back to over 100 years. This group is
hereinafter referred to as "Permittees". Based upon such dependency by use, the Permittees
separately own base property (in the form of private land)upon which Grazing Preferences and
Permitted Use Animal Unit Months ("AUMs")within the above-named Allotment are attached
and through which the BLM has issued Grazing Permits to the Permittees which annually
authorize each of them to graze livestock upon the public lands within the above-named
Allotments. Some of these Permittees also hold Idaho State Grazing Leases that permit them to
graze livestock upon the unfenced, intermingled Idaho State Land within some of the above-
named Allotments.
Beyond the permitted use status of the Permittees, the Permittees also enjoy and cherish
the custom & culture associated with livestock ranching upon and adjacent to the public lands
within the above-named Allotments; enjoy and cherish the solitude of such public lands within
the above-named Allotments; and enjoy and use the public lands within and adjacent to the
above-named Allotments for a multitude of other purposes like hiking, horseback riding,bird-
watching, camping, and other types of recreation.
Given the foregoing, the Permittees hold interests upon and adjacent to the public lands
within the above-named Allotments which will be significantly impacted by the Idaho Power
Application.
The Permittees have separately been a commentor to the recently cancelled Right-of-way
Grant, IDID10584803 (commonly known as Lava Ridge Wind Project or Magic Valley Energy,
LLC Wind Project). See Decision dated August 4, 2025, issued by Katharine Sinclair
MacGregor, Deputy Secretary of the Interior, U.S. Department of the Interior. We were
supportive of such Decision dated August 4, 2025.
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In addition, the Permittees have separately been an appellant to three (3) different
Decisions issued by the BLM as related to Right-of-way Grant IDI-39380 (commonly known as
Taurus Wind MET Project). See Decisions dated July 6, 2023, dated September 18, 2024, and
October 18, 2024, which are subject to appeals before the Board of Land Appeals of the Office
of Hearings and Appeals, U.S. Department of the Interior, IBLA-2023-0196, IBLA-2025-0024,
IBLA-2025-0074. We are opposing such Decisions.
COMMENTS:
We find no public convenience and necessity for an ownership interest in the southwest
intertie project-north 500-KV transmission line and in the approval of the utilization of capacity
of such line. This finding is due to any of the following.
We are supportive of the comments submitted by Stop Lava Ridge, Inc. dated July 17,
2025. See 20250717Comment_I.pdf(hotlink last checked 8/29/2025 @ 11:48 A.M.).
We are supportive of the supplemental comments submitted by Stop Lava Ridge, Inc.
dated August 13, 2025. See 20250818Comment—l.pdf(hotlink last checked 8/29/2025 @ 11:48
A.M.).
Beyond such comments and supplemental comments submitted by Stop Lava Ridge, Inc.,
we are compelled to share our independent opposition to the Idaho Power Application due to the
unintended consequences of granting the Idaho Power Application. A significant, adverse impact
of granting the Idaho Power Application is the explicit or implied license it will provide Idaho
Power and other Wind, Solar, or Geothermal Electrical Power interests to apply to exploit any
wind, solar, and geothermal power resources upon the public lands within the above-named
Allotments. In other words, without sideboards or conditions, the granting of the Idaho Power
Application will incentivize the wind, solar, and geothermal electrical power interests to apply
for wind, solar, and geothermal developments upon such public lands. We oppose such potential
and we oppose the development of any wind, solar, and geothermal electrical power resources on
the public lands within the above-named Allotments, as providing the potential, among other
things, of converting the now multiple-uses of such public lands to single-uses of such public
lands by wind, solar, and geothermal interests. We thus ask and expect that should the
Commission grant the Idaho Power Application, the application be explicitly conditioned upon
the expectation that any new line/opportunities associated with the Application will not be used
to transport or facilitate the transportation of electricity developed from any wind, solar, and
geothermal resources from or upon the public lands (and even Idaho State lands)within the
above-named Allotments.
We are hopeful that these comments are informative to you. If you have any questions,
please write. Otherwise, we welcome the opportunity of conferring with you as to any next steps.
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Very truly yours,
SHEEPHOOK CATTLE GRAZING TUNUPA GRAZING ASSOCIATION, LLC
ASSOCIATION, LLC
Sheephook Ca Me GraiingAssociation, LLC T pa Grazing Association, LLC
WILLIAMARKOOSH BLACK BUTTE HILLS LLC
ESTATE OF WILLIAMARKOOSH CAMAS CREEK CATTLE ASSOCIATION
LLC
J ram Arkoos t/ s ate of William Arkoosh
Rod Gon es
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ATTACHMENT #1
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