20251031Application for Intervenor Funding.pdf

RECEIVED
OCTOBER 31, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Eric L. Olsen(ISB#4811)
ECHO HAWK& OLSEN, PLLC
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-25-10
COMPANY'S APPLICATION FOR
APPROVAL OF A POWER PURCHASE IDAHO IRRIGATION PUMPERS
AGREEMENT AND AN ENERGY ASSOCIATION,INC.'S
STORAGE AGREEMENT WITH APPLICATION FOR INTERVENOR
CRIMSON ORCHARD SOLAR LLC. FUNDING
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 requests 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.
(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") request for approval of a Power
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 1
CASE NO.IPC-E-25-10

Purchase Agreement ("PPA") and Energy Storage Agreement ("ESA") with Crimson Orchard
Solar LLC. Mr. Olsen, Dr. Kaufinan and Dr. Glosser reviewed and analyzed the Company's
positions,prepared and served written discovery, and prepared written comments.
Dr. Glosser's review uncovered significant financial and operational risks that the Project
would likely pose to ratepayers. Specifically, Dr. Glosser raised concerns that a lack of
performance guarantees in the ESA contract may result in large costs being passed on to rate payers
in the event of underperformance of the Project. Dr. Glosser also explains that there is a fire risk
that is not modeled therefore the current RCAT model is very misleading. Given all these risks,
IIPA recommended that the IPC's application of the Crimson Orchard ESA and PPA be denied,
and decline to acknowledge the lease accounting necessary to facilitate the transaction and the
resulting expenses as prudently incurred for ratemaking purposes.
(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
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 and electronic solicitations 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
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 2
CASE NO.IPC-E-25-10

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 concerns and ultimate recommendations materially differed from
Commission Staff s comments. The IIPA found the Company's filings failed to show that the PPA
and the ESA were the least cost, least risk resource and that the associated costs have been fully
and transparently evaluated. IPC's amendment to the PPA and ESA have not resolved these
shortcomings. IIPA recommends that if the Crimson Orchard PPA and ESA are approved, then
the Commission should impose soft caps on the recoverable costs to those found in IPC's financial
modeling assumptions.
(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.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 3
CASE NO.IPC-E-25-10

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 day of October, 2025.
ECHO HAWK & OLSEN
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 4
CASE NO.IPC-E-25-10

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this day of October, 2025, I served a true, correct and
complete copy of the foregoing to each of the following,via U.S. Mail or private courier, email or
hand delivery, as indicated below:
Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Hand Delivered
P.O. Box 83720 ❑ Overnight Mail
Boise, ID 83720-0074 ❑ Telecopy(Fax)
[e-mail] ® Electronic Mail (Email)
Donovan E. 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
dwalkernidahopower.com
dockets gidahopower.com
ttatum(k idahopower.com
Lance Kaufman, Ph.D. ❑ U.S. Mail
2623 NW Bluebell Place ❑ Hand Delivered
Corvallis, OR 97330 ❑ Overnight Mail
lance(kae is�.hg t.com ❑ Telecopy(Fax)
❑ Electronic Mail (Email)
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ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 5
CASE NO.IPC-E-25-10

EXHIBIT A
Expert Witnesses: Deborah Glosser and Lance Kaufman,Expenses:
1. Witness Fees: 33.75 Hours @ $250 = $ 8,437.50
Sub Total: $ 8,437.50
Legal Expenses:
1. Paralegal Fees: 5.5 Hours @ $155 = $ 852.50
2. Legal Fees Eric L. Olsen: 4.5 Hours @ $250 = $ 1,125.00
3. Soft Costs (Copies/Legal Research) $ 5.25
Sub Total: $ 1,982.75
Grand Total: $ 10,420.25
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 6
CASE NO.IPC-E-25-10