20251118Direct Gannon.pdf

RECEIVED
John Gannon Deborah Fease November 18, 2025
Rand Morris & Am Lorrance IDAHO PUBLIC
Y Y UTILITIES COMMISSION
Pro Se
1104 Johnson Street
Boise, Idaho 83705
208-343-1608
[e-mail]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS ) CASE NO. IPC E- 25-16
RATES AND CHARGES FOR )
ELECTRIC SERVICE IN THE STATE )
OF IDAHO )
DIRECT TESTIMONY OF JOHN GANNON
REGARDING SETTLEMENT
IDAHO PUBLIC UTILITIES COMMISSION
NOVEMBER 18, 2025
Q. Please state your name, address and describe your interest in this application.
A. My name is John Gannon and I live at 1104 Johnson Street, Boise Idaho. I am a
residential ratepayer of Idaho and I am appearing in this proceeding as an individual and
ratepayer. Separately, I am a legislature who has experience in legislation relating to electricity
and I am an attorney who has intervened in a Veolia rate increase case regarding brown water on
the Boise Bench. I haven't done a lot of work at the Commission.
My interest is to learn about the electrical issues Idaho faces, and to find ways to keep
Idaho's electric rates the lowest in the nation. Our low rates are something to be proud of.
Q. Why did you intervene in this case?
A. There is great community concern and opposition to the increasing utility rates. Rates are
CASE NO. IPC-E-25-16 GANNON 1

proposed or have increased by 10% or more for water, natural gas, and now electricity. Around
500 people have commented against the proposed increases and social media posts have
been uniformly against the increase. I have been concerned that our electric rates are under
tremendous pressure to accelerate almost to the point that they may cost more than a
homeowners property taxes. They have increased 7% in 2023 and 2024 and the settlement Idaho
Power proposes a 10%residential increase. I note that Idaho imports a significant amount of
energy we consume, and even though some of that is controlled by Idaho Power, there is an
implication that if rates in general around the nation rise, then Idaho's rates will rise.
The demand for power is skyrocketing. The national media and events in other states
have focused on a doubling of residential rates. A Harvard study found that data centers could
result in electric rates doubling. (Exhibit 1)
h!tps:Hfloodli ghtnews.org//power-for-data-centers-could-come-at-staggering-cost-to-
consumers/
Our local television station recently ran a story:
https://www.ktvb.com/article/news/nation-world/electricity-prices-surge-data-
centers/507-a31304bf-8 c93-4a98-a 147-6dc9dfda9597
The Governor Elect of New Jersey is calling for an electric rate freeze and has been
urged to prioritize development of electricity for use inside the state of New Jersey.
hops://njbi� a.org/pseg-ur eg_s-,governor-elect-to-prioritize-new-in-state-power-,generation
I am very concerned that Idaho take action to protect our low rates.
CONCERNS ABOUT THE CAPITAL INVESTMENTS
Q. The settlement of course is for a lesser amount than the $199 million request. At $110
million, is that satisfactory and helpful to address your concern?
A. There are filings which state that the $110 million increase is not for the benefit of any
particular user but it does appear that there is quite a bit of the raise that is allocated for
investment in the system. I note first that this increase continues in the future. This is really $1.1
CASE NO. IPC-E-25-16 GANNON 2

billion in 10 years. So I was curious as to how much is for growth. This is a slide from the
presentation by Idaho Power executives on July 31, 2025, at the Second Quarter Shareholders
meeting taken from the Idaho Power website and attached as Exhibit 2 to this testimony:
IdaCorp Second Quarter conference call Slides.pdf
This slide shows that anticipated growth in customers is 16,250 customers. If each customer is
a residential customer the total new megawatts needed is 25 megawatts using Idaho Powers
calculation of 650 homes per megawatt or 54 megawatts at a peak time (Exhibit 2)
16,250 customers divided by 650=25 megawatts
16,250 customers divided by 300 = 54 megawatts
Obviously, the actual amount is less for residential because some of these customers are in other
classes but this gives a general idea. Compared to the 3800 mw maximum system demand this
25 mw is less than 1 per cent of the total and 54 is about 1.4%.
I am concerned that there are larger users who are putting a demand upon the system
even in this rate case. Why?
Attached as Exhibit 4 is the Staff s Drivers of Request for the 2024 rate increase.
Attached as Exhibit 5 is the Staff s Drivers of Request for the 2025 rate increase. You can see
that each initial request contemplated the principal driver as a 1 billion increase in capital
expenditures. It doesn't seem like these kind of capital investment figures were present in the
past. I could be wrong, but rate increases have been very modest in the past which would imply
that capital expenditures were more modest too. Neither Exhibit 4 or 5 mention inflation.
Discussions by Idaho Power officials at the previously mentioned shareholders meeting
talked about the drivers for this rate increase:
Earnings call transcript: IDACORP beats Q2 2025 earnings forecast, raises
guidance
Investing com
CASE NO. IPC-E-25-16 GANNON 3

Transcripts
Published 07/31/2025, 07:48 PM
Brian Buckham, SVP, CFO and Treasurer,IDACORP: Hey. Thanks, Lisa.....
......................
"Lastly, for me, Lisa gave the highlights on our general rate case.
We're looking to add nearly a billion dollars of rate base through
the case,just reflecting the investments we've making we've made
in our system for reliability and to address economic growth."
Previously at the meeting Idaho officials said:
Opening Remarks:
Lisa Groh(sic): ........
"We're already working with the Micron team to determine how we'll
serve the expanded project.Valor C3 data centers also announced an
expansion at a second location in Boise and Tesla has energized six new
large electric vehicle fast charging stations throughout Idaho Power service
area.While growth is already robust,we continue to field and thoughtfully
process requests from businesses looking to locate and expand within our
service area. The pipeline of prospective customers on our list exceeds our all
time peak load of around 3,800 megawatts. While we don't expect all of those
customers to materialize in the near term,those prospective customers would
be incremental to the load growth rate that we included in our recently filed
IRP."
.............................
So this gives me concern that a substantial part of the rate increase each year over the next 10 years,
or even 50 years is being used for increased generation for a new demand outside of residential users. For
example the T5 Data Center in Nampa has just been approved and will use 2.5 mw initially and then 8.5
mg when finished. The ValorC3 data center
https:/iboisedev.com/news/2025/09/02/data-center-nampa-september-2025/
The ValorC3 data center is expected to go live by 2027 and will use 10 mw.
https://capacityglobal.com/news/valorc3-announces-new-1 Omw-ai-ready-data-centre-in-boise/
These two small data centers will use almost as much as a possible 10,000 homes.
STAFF BELIEVES THE CAPITAL INVESTMENTS ARE NOT
FOR PARTICULAR USERS
Q. What electric growth factors have you learned about from these proceedings?
CASE NO. IPC-E-25-16 GANNON 4

A. I found the Declaration of Mr.Suess to be helpful in understanding the growth situation. He
said the settlement proposal reduced the capital investment to $693 million. He said most of
the growth part of the capital investment is for baseline growth and attributed growth to
categories as follows:
"Q. Please discuss why you think baseline load growth
is a contributing factor.
A. The Company's baseline load growth is significant
and persistent. The 2023 IRP 20-year load forecast is 1.1
percent annual growth for residential loads, 0.8 percent
for commercial loads, and 1.3 percent for industrial
loads. This persistent dispersed growth has required—
and will require—continuous investment to upsize
distribution infrastructure, such as transformers,
switchgear, conductors, etc. Many of the 2025 growth-
related projects were for this purpose.
The persistent baseline growth has also required
several new resources to be added."
Q. What other significant factor did Mr.Seuss state was causing the incremental revenue
requirement in this settlement?
A. Mr.Seuss referenced inflation. He noted the increased costs of some basic electrical
materials. In fact he concluded his testimony by saying the incremental revenue increase
requested by Idaho Power is driven by many factors "including baseline load growth and
inflation."
Q. Doe this testimony seem to contradict the "drivers of the rate increase"presentation?
A. Yes, but I do think Mr. Seuss is right that there has been some inflation across the board
which is a factor.
CONCERNS ABOUT RATE SPREAD
Q. What concerns or conclusions did this information give to you?
A. Well, it seems like a huge capital investment but staff is convinced it is for baseline growth
and this would appear to be the obligation of all classes. The industrial class has the highest
projected demand, followed by the residential and then commercial. All seem to be around 1 per
CASE NO. IPC-E-25-16 GANNON 5

cent annual growth. I have to suggest that the two data centers previously mentioned would seem
to inordinately increase industrial demand, but maybe not. In any event, if one accepts that load
growth is going to be spread among several classes, then it would seem that one should expect
that these expenditures should be spread among all the classes at least equally.
Q. Are you questioning the uneven allocation of the increases?
A. I think that if you take the position that inflation is raising the cost of everything, that the
capital investments are attributable to all classes in general, that other expenses discussed
such as wildfire mitigation, basic operation costs, salaries, and even the airplane expense, are
not caused by a particular customer or class, then one would think the percentage increase in
each classes allocated financial obligation would be equal. In other words, each class has its
own rate and I am understanding there is quite a variable. So if the expenditures in this rate
increase are generally applicable, thenit would seem that all ratepayers would have an equal
percentage increase in rates, not the huge disparity present in Exhibit 6.
Q. What is your position on the settlement?
A. We are not signing on,but we are not going forward with questioning many of the
assumptions and facts. We are concerned because of the tremendous amount of public opposition
and the rate spread issue. We hope the commission will consider the rate spread in its analysis
and acceptance of the stipulation because that seems problematic. Energy conservation needs to
begin and hopefully in the future the commission will consider ways to encourage that in big
users and smaller users.
Q. Anything to add?
A. Thank you for the opportunity to participate in this very interesting process. Thank you for
all courtesies and for courtesies from the parties and especially staff. And a thank you to all
those citizens who participated in this process.
CASE NO. IPC-E-25-16 GANNON 6

Dated November 18, 2025
By /s/John Gannon
JOHN GANNON
CASE NO. IPC-E-25-16 GANNON 7

powersInvestigating the
Mission&Model Republish Us Impact Team Jobs Projects Newsletter CZ Sign in
DATA CENTERS
Power for data centers could come
at `staggering' cost to consumers
New report highlights how traditional ways of setting rates don't fit Big Tech's massive,
immediate demand for more electricity
AIIC► Pam Radtke/Floodlight
Mar 5, 2025—8 min read
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Deer are seen outside of a Google data center in Council Bluffs, Iowa. (Googl D t C n
Published by the Arkansas Advocate, Louisiana Illuminator, WWNO, ll,
Renewable Energy World, V tility Dive

This story was updated to include comment from The Data Center Coalition.
The explosive growth of data centers around the country—driven in large part by the
burgeoning use of artificial intelligence—could come at a "staggering" cost for average
residents with skyrocketing electricity bills.
A new report from Harvard's Electricity Law Initiative says unless something changes, all
U.S. consumers will pay billions of dollars to build new power plants to serve Big Tech.
Data centers are forecast to account for up to 12% of all U.S. electricity demand by 2028.
They currently use about 4% of all electricity.
Historically, costs for new power plants, powerlines and other infrastructure are paid for by
all customers under the belief that everyone benefits from those investments.
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"But the staggering power demands of data centers defy this assumption;"the report
argues.
"We're all paying for the energy costs of the world's wealthiest corporations;" said report
author Ari Peskoe, director of the initiative at the Harvard Law School Environmental and
Energy Law Program. He worked with co-author Eliza Martin to produce the report,
"Extracting Profits from the Public: How Utility Ratepayers are Paying for Big Tech's Power."
Lucas Fykes, director of energy policy for The Data Center Coalition, which advocates for
the industry, responded to Floodlight by email, saying, "State utility commissions have the
regulatory responsibility and authority, expertise, experience and processes in place to
ensure that cost allocation and rate design are fair and reasonable for all customers."
A spokesperson for Dominion, which serves one of the nation's largest data center loads in
Virginia, said establishing rates in the state is an "open and transparent" process.
Aaron Mitchell, vice president of pricing and planning at Georgia Power, testified to a
Georgia legislative committee that adding 3,300 megawatts (MW) of new generation for

customers' bills.
"The more that we are able to serve, the more that we can provide benefits to existing
customers, by virtue of those new customers coming online and paying their fair share of
the costs that we incur to serve those customers," Mitchell said.
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2024 United States Data Center Energy Usage Report, Lawrence Berkeley National Laboratory, December
2024.
Secrecy hides full picture of utility costs
But Martin and Peskoe examined nearly 50 regulatory proceedings around the country
between utilities and data centers to determine who pays the costs for electricity for data
centers.
In many cases, agreements between tech companies and utilities are confidential, limiting
the information that's available including how much electricity a data center will use and
how much it will pay for the power, according to the report.
In Louisiana, Entergy Louisiana is proposing to build 2,250 MW of new natural gas
generation for Meta, the tech company. But neither Meta nor its data center affiliate
Laidley, is involved in the proposal before the state's Public Service Commission.

Entergy Louisiana,LLC Public Redacted Version
Direct Testimony of Phillip R May
Docket No.U-
I Ill. OVERVIEW OF THE PROJECT
2 A. Description of the Project
3 Q16. PLEASE DESCRIBE TIIF CUSTOMER'S PROJECT AND ITS AGREEMENT
4 WITH ELL..
a A. 1 he Project is a new that the Customer is planning to construct
6 in Richland Parish, Louisiana. The proposed_has significant capacity and
7 energy requirements, and ELL and the Customer have worked closely to reach
A new report finds that the secrecy around proposed data centers can lead to higher costs for residential utility
consumers.In this document from Entergy Louisiana filed with the Louisiana Public Service Commission, the
name of the owner of a proposed data center in northern Louisiana is redacted. State officials have since
announced Meta's plans to build a $10 billion data center there.
Earthjustice, a nonprofit environmental law organization, is an intervenor in Entergy
Louisiana's request to build new gas plants to fuel the Meta data center. The group filed a
motion with the PSC seeking to force Meta, the parent company of Facebook, and Laidley
to disclose information including anticipated energy demand, justification for its request for
an expedited approval and verification of how many local jobs it will create.
Peskoe and Martin found that in some cases, utilities appear to have hidden how much
average residents pay to offset special rates or incentives given to other customers,
including data centers. The report cites a lawsuit against Duke Energy that alleges Duke
intentionally hid a $325 million discount provided to a large customer and, according to
internal documents, that Duke planned to "shift the cost" to other ratepayers.
"We should be skeptical of utility claims that data center energy costs are isolated from
other consumers' bills," the report says.
The potential costs aren't just in bill increases, the paper points out. If utilities can profit
from building new generation for data centers, they have no incentive to modernize their
systems by switching to renewable or more efficient power, which would provide longer
term benefits to customers and the climate.
Rather than adding cleaner, renewable sources, "utilities ... are instead offering to meet
data center demand with transmission (upgrades) and gas-fired power plants, which have
been the industry's bread-and-butter for decades;' according to the report. "Some utilities
are even propping up their oldest and dirtiest power plants to meet data center demand."

Daniel Tait is a research and communication director for the utility watchdog Energy and
Policy Institute. In February, Tait released an ply i-a about how the demand for data
center power has caused utilities, mostly in the South, to continue operating coal-fired
power plants— some of them on the verge of closure. Such a move would stall or reverse
efforts to decarbonize the electric sector, he wrote.
OUISIANA
CONOMIC
Electric utility Entergy Louisiana has filed hundreds of pages of documents with state regulators about the
development of a massive data center to be built by Meta on this state-owned site in Holly Ridge, La. (Louisiana
Economic Development)
Size of energy demand, benefits, hard to find
State utility regulators are often under pressure to approve data centers because of their
perceived benefits, the report says.
That dynamic is playing out in Louisiana, where the Public Service Commission agreed to
fast-track apc of $3.2 billion in new natural gas-fired generation to serve a $10 billion
Meta data center. The announcement had one normally skeptical commissioner labeling
the proposed development in economically impoverished North Louisiana a "godsend."
In its initial filing —in which key information was redacted — Entergy told the PSC the data
center would provide 300 to 500 jobs. But Entergy later said it couldn't provide evidence of
those jobs. Meta did not respond to a question about the number of jobs and whether they
would be located in Louisiana.
Entergy spokesman Brandon Scardigli confirmed that Meta has guaranteed it will pay the
costs for the new generation for 15 years. But, he said he couldn't comment on the specific

data center, he said, "represents a major investment in the state."
Tait questioned whether the promised jobs would ever come.
"Here's what's so sick about this, is that they are doing this in a deeply impoverished area
of Louisiana, with the presupposition that they're doing it to bring wealth and jobs to that
area of the state, right?" he said.
Using its access to the confidential agreements made with Entergy Louisiana, Earthjustice
is examining how costs may be spread to other customers in the state— and what
happens after the 15-year contract ends.
"Our argument is that the ratepayers don't actually benefit from the existence of this data
center in this spot," said Susan Miller, the lead Earthjustice attorney in the case. "They
should not be paying greatly increased utility rates just so that the data center can have a
business."
The Harvard report makes the same point, arguing that data centers don't need subsidized
rates if they are already receiving other incentives from a state to locate there. In 2023, for
instance, Virginia data centers were exempted from paying $1 billion in sales tax, the report
says.
In Louisiana, Meta will receive, among other things, a use and sales tax exemption on data
center equipment and software. The amount, which isn't specified, is contingent on the
data center creating 50 direct, permanent new in-state jobs and spending at least $200
million in new capital.
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needs of large data centers like this one are driving a projected increase in demand for electricity in the United
States after years of stagnant or declining demand.Photo taken Feb.10, 2024. (iStock photo/Getty Images)
Can ratepayers, taxpayers be protected?
To prevent a "race to the bottom;'the report recommends that U.S. public utility
commissions require the same terms and rates for all data centers.
The report said utility commissions also could establish "robust" guidelines, like those in
Kentucky. There, a utility can only provide a discounted rate for service when it already has
excess generation. It also requires that any special contract rate exceed the cost of
providing the power and that the discount extend for no more than five years.
Kent Chandler, former chairman of the Kentucky Public Service Commission, said the state
has handled special contracts that way for 35 years.
"We've laid out rules for the utilities, saying you should only offer these when these
circumstances exist and in this way," Chandler said. "And I think that that served the state
particularly well. Kentucky still has a robust manufacturing base.'
Chandler argues that a new regulatory regime isn't necessary to handle data center
demand, but"quality implementation"would go "a long way in alleviating a lot of the
concerns" raised in the Harvard paper.
He says one way to protect ratepayers is to allow data centers to contract directly with
independent electricity providers. The paper also envisions the creation of "energy parks"
where power is provided to a cluster of data centers. That park might not even be
connected to the grid, to "completely insulate ratepayers from data centers' energy costs."

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ARTIFICIAL INTELLIGENCE
t'
Artificial intelligence is one technology driving the number and size of data centers. President Donald Trump
announced"Stargate;'a $500 billion investment in Al,at the White House on Jan. 21, 2025.Speaking was Sam
Altman of Open Al,flanked by Larry Ellison from Oracle. Behind them is Masayoshi Son from SoftBank. (C-
SPAN)
The growth is occurring so quickly that regulators are grappling with the issue on the fly.
Louisiana Commissioner Davante Lewis said he welcomes the economic development Meta
could bring but still lacks a full understanding of the long-term repercussions of any deal.
Said Lewis: "I have to do extra due diligence to ensure the people of Louisiana don't get
stuck with a ginormous bill because we were promised a bunch of economic development
that happened in a very secret way that I don't think was good for the public."
Floodlight is a nonprofit newsroom that investigates the powerful interests stalling climate
action.
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Slides 11-25 of 100 WTVEP Update Reference Sheet
Power Terms
• Voltage (kilovolts [kV])—The pressure that moves a current of electricity. One kV equals
1,000 volts.
• Power(megawatts [MW])—Thc rate at which work is performed. One MW equals
1,000,000 watts.
/• One MW can power 650 homes on an average day, but only about 300 homes on a peak
day, which occurs in the heat of the summer.
• One MW can power one to two large box stores
• Energy(kilowatt-hours [kWh])—The amount of power used over time. A 100-watt light
bulb on for 10 hours will consume this much energy:
Energy= 100 W h 10 hours - 1,000 Wh - 1 kWh
• Capacity (MW)—The maximum amount of power an element of the power system can
handle or produce. For example, in a freeway analogy, capacity is represented by the number
of cars that can cross a line on a freeway at the same time, while energy is represented by the
number of vehicles that cross the line over time. Capacity constraints can be alleviated by the
following:
• Decreasing the power required during peak hours (demand response)
• Decreasing the power required with energy efficiency measures
• Adding transmission lines, substations, and generators
• Peak demand (MW)—The amount of power used during a peak day in summer or winter.
Unit Summary Table
Base Unit Typical Unit
Voltage Volt(V) kilovolt(kV)"
Power Watt(W) megawatt(MW)"
Capacity Watt(W) megawatt(MW)**
Energy Watt-hours(Wh) kilowatt-hours(kWh)
'kilo= 1,000
"mega= 1.000,000
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