20251124Comment_1.pdf

From: Dan Sakura <[e-mail]>
Sent: Monday, November 24, 2025 11:34 AM
To: secretary<[e-mail]>;Walker, Donovan <[e-mail]>;
Tatum, Tim <[e-mail]>; [e-mail]
Cc: Dean Dimond <[e-mail]>; [e-mail]; Eric L. Olsen
<[e-mail]>
Subject: IPC-E-25-8
Dear Commission Secretary—Please find attached comments from Stop Lava Ridge
opposing Idaho Power's application in IPC-E-25-8. Thankyou for considering.
Dan Sakura
Sakura Conservation Strategies, LLC
------------------------------------------------------------------------------------------------------------------
1

November 24, 2025
Monica Barrios-Sanchez
Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
Sent electronically to: [e-mail]
Supplemental comments opposing Idaho Power's Application for a Certificate of Public
Convenience and Necessity for an ownership interest in the SWIP-N transmission line and
approval of the Utilization of the Capacity of the Line in IPC-E-25-08
Dear Secretary Barrios-Sanchez:
Stop Lava Ridge submits supplemental comments opposing Idaho Power's application in
this proceeding. I appreciate the Commission's decision to re-open the public comment period
and hold a Customer Hearing in Twin Falls. I ask the Commissioners to consider this new
information and deny Idaho Power's CPCN application, based on two negative scenarios for
SWIP-N:
Scenario 1 —Wind Buildout. The State of California is driving SWIP-N to shift the
negative externalities of wind projects from California to Idaho. Granting the CPCN would run
counter to the work of four Magic Valley counties working to promote the general welfare and
the public interest through local ordinances to restrict renewable energy projects. Unfortunately,
because of federal supremacy, the State of Idaho and counties are powerless to stop federal
decisions to permit wind projects, like Lava Ridge, on federal land.
Granting Idaho Power's application would lead to repeats of LS Power's Lava Ridge
debacle, which is described in the Twin Falls Times News editorial included at the end of this
letter. Moreover, Idaho Power seeks to mislead the public and the Commission by stating that
SWIP-N is not connected with Lava Ridge. Idaho Power has entered into two interconnection
agreements with Magic Valley Energy-LS Power to connect Lava Ridge to the grid.
Scenario 2 —No wind buildout. Under this scenario, no wind projects are constructed in
Idaho. _In the absence of wind projects, CAISO and California Load Serving Entities (LSEs)
would drain power out of Idaho to meet California's needs. Alternatively, the intense public
opposition to SWIP-N, coupled with FERC's decision to grant transmission rate incentives, will
lead LS Power to abandon SWIP-N and saddle ratepayers with 100% of the abandoned costs of
the line.
1

Scenario 1: Wind Buildout. By granting a CPCN,the Commission would enable Idaho Power to
provide the final piece of the funding puzzle to LS Power to construct the line.
California Public Utilities Commission 2026-2027 Transmission Planning Process.
Despite Idaho's opposition to utility-scale wind projects, the California Public Utilities
Commission (CPUC) continues to target Idaho for wind projects, which would have devastating
impacts on Hidden Valley and the entire Magic Valley. Through its Integrated Resource
Planning (IRP) and Procurement Process, CPUC is working to complete its 2026-2027
Transmission Planning Process (TPP).1 Despite the cancellation of the Lava Ridge wind project
in August 2025, the CPUC continues to include out-of-state wind from Idaho in its transmission
planning process. On November 12, 2025, the CPUC staff reiterated California's goal to access
1.1 gigawatts of wind energy from Idaho via SWIP-N and the Harry Allen substation in Southern
Nevada by 2031.2
Because of California's continued interest in Idaho wind and the proposed construction of
the SWIP-N, wind project developers will target federal land in the Magic Valley for wind
projects via power purchase agreements (PPA) with LSEs in Southern California. The map
below shows LS Power's Lava Ridge and Salmon Falls wind projects along with the Taurus
wind project, (depicted in blue) connecting to the SWIP-N transmission line.
1 CPUC, "Order Instituting Rulemaking to Continue Oversight of Electric Integrated Resource
Planning and Procurement Processes:Administrative Law Judge's Ruling Seeking Comments on
Portfolios for 2026 Transmission Planning Process and Need for Additional Reliability
Procurement in in Rulemaking 25-06-019," dated September 30, 2025.Available at:
582082526.PDF
2Energy Division Staff, California Public Utilities Commission, "IRP Proposed 26-27 CAISO
TPP Portfolios and Initial Busbar Mapping Results Webinar,"November 12, 2025. Slides 18, 84
and 96.Available at: cpuc_tpp-portfolios-and-busbar-webinar-slides_20251112.pdf
2

•OOODRIB •EMOEXONE w
•BLIt i
•0
0
1E"O 1 ON•QA
•rurnE Shoshone
Field Office
•XAOER YAN �� --.
•WEMDELL
• l V,161OEIVE•`�y
•BUHL •EDEN •NA M •PAUL
•PIER •TWIN FALLd
•NEVBUt
NIYBERLY
• •BURLEY
•CABTLEFORD •CL NANrN
• OVER I
•YtlRTAUOX
•BEROEP •.TRICNEN
� u • pCCREEF •'
�� • _ � •ARTEiIANLT'
•ROBENdOR1X
XOLLISTER •ISLAND
•TROUT
•AYigERDAY
I// •YARgN
•LOCUST
•OANLEY •BAdIN
ROOERION
car `
Construction of SWIP-N will enable LS Power and other companies to sign PPAs and secure
construction financing for wind projects on federal land and cause devastating impacts on
Southern Idaho. Despite the current federal moratorium on wind projects, LS Power continues to
pursue its Salmon Falls wind project in Twin Falls County.3 Wind project developers will
exploit loopholes in the Bureau of Land Management's outdated land use plans which lack
required Visual Resource Inventories, Visual Resource Management Classes and Scenic Quality
Rating Units.
Gooding, Twin Falls and Lincoln Counites have adopted county ordinances to protect
their jurisdictions from wind projects. In response to the Lava Ridge project, Lincoln County
finalized a renewable energy ordinance to limit wind projects in August 2025.4 Chapter 3 of the
Lincoln County ordinance requires conditional use permits for large-scale energy projects
defined as: "Projects capable of producing, as per nameplate capacity, 10 megawatts (MW) or
3 https://www.ma icg valleyeneray.com/proje? cts/
4 Lincoln County, Idaho, "Ordinance 2025- 01: Establishing Regulatory Standards for Siting
Energy Projects," adopted August 4, 2025. Available at:
h!Ltps://www.lincolncouniyid.gov/media/143 1.
3

more; or projects that encumber 5 or more acres of land; or structural improvements exceeding
60 feet in height that produce power via the harnessing of wind, solar, nuclear, fuels, digesters, or
other energy forms for transmission or storage; or in the case of a BESS nameplate capacity of
ninety-one (91) kilowatts (KW) or more."
Because of federal supremacy, Magic Valley communities will be powerless to block
future federal land use decisions to build utility-scale wind projects which will interconnect with
SWIP-N to meet California's renewable energy goals.
The SWIP-N goal is to export Idaho electricity to California. LS Power's studies show
the true purpose of SWIP-N: "SWIP North is the final link of a transmission project that would
create 1,000 MW of firm transmission rights from Idaho to California for CAISO."5 On Magic
Valley Energy's website, LS Power clearly states the purpose of SWIP-N is to export wind
energy from Idaho to neighboring states and California.6
5 Brattle Group, "SWIP-North Benefits Analysis: Presented for Great Basin Transmission," dated
February 2021, slide 1. Available at: https://www.brattle.com/wp-
content/uploads/2021/06/2143 8_swip-north_benefits_analysis.pdf
6 https://www.ma icg valleyeneray.com/
4

Wind +Transmission+ Buyers=A New Export Market for Idaho
WIND
Southern Idaho boasts strong,consistent wind that
will allow for a sustainable creation of energy.
I/ I
TRANSMISSION LINES
Multiple existing and planned transmission pathways
enable the delivery of wind energy to power markets
across the West.Battery storage can be used to extend
the supply during times when the wind isn't blowing.
Vfiff-Lq= BUYERS
The majority of western U.S.states have specific and
substantial clean energy goals to meet the regulatory,
kip utility,or consumer driven need to incorporate
renewable energy into their portfolios.
Source: LS Power, Magic Valley Energy website.
Scenario 2—No wind buildout and project abandonment. Under this scenario, no wind
projects are constructed in Idaho. _CAISO and California Load Serving Entities (LSEs) would
drain power out of Idaho to meet California's needs. Alternatively, the intense public opposition
to SWIP-N, coupled with FERC's decision to grant transmission rate incentives, will lead to
permitting delays rendering the line of little value to Idaho and increasing the risk that LS Power
to abandon SWIP-N and saddle ratepayers with 100% of the abandoned costs of the line.
SWIP-N does not comport with Idaho Land Use Law. Under Idaho State law, counties
have significant permitting and siting authority.' Idaho state law requires counties to include
' State of Idaho, Governor's Office on Energy and Mineral Resources (OEMR), "Permitting and
Siting Roles," available at: https://oemr.idaho. ovg /energy-infrastructure/permitting/. According
to OEMR, "A significant portion of siting authority rests with local units of government.
Accordingly, local jurisdictions are responsible for providing venues for public comment and
participation as it relates to local siting considerations. Under provisions of the [Idaho] Land
Use Planning Act, the county commissions or governing boards exercise specific functions
regarding the siting and permitting of transmission line corridors and infrastructure. Chapter 65,
Title 67 of Idaho Code extends authority to the counties to include transmission corridors in
5

transmission corridors in their comprehensive plans.8 After acquiring the right-of-way in the
early 2000s, Great Basin did not seek Jerome county approvals for SWIP-N towers until 2025.
This delay denied members of the public opportunities to have input into siting decisions. Also,
the Jerome County plan lacks the required transmission corridors.9 Accordingly,private
landowners were unaware of the SWIP-N right-of-way through or near their property.10 Local
residents also expressed concerns about Great Basin's sufficiency language enacted into law in
2010 which exempted the relocation from compliance with federal laws and judicial review.
Twin Falls Customer Hearing. At the Twin Falls Customer Hearing, many local
businesses, property owners and elected officials strongly opposed SWIP-N. This opposition
will translate into significant permitting risk and delays, which will likely push the start of
construction beyond the early 2029 construction start date, significantly reducing the project's
benefit to Idaho Power, which is seeking total SWIP capacity (SWIP-N and SWIP-S), from
Midpoint to Southern Nevada. According to Jared Ellsworth's direct testimony, if construction
does not start by early 2029, NV Energy may exercise its option to acquire the capacity of SWIP-
South significantly reducing Idaho Power's interest in acquiring an interest in the entire SWIP.
Jerome County Permitting and Zoning. On October 28, 2025, Jerome County
Commissioners remanded Great Basin's application for SWIP-N transmission tower special use
permits to the Jerome County Planning Zoning Commission for review. The Planning and
Zoning Commission is scheduled to meet on Monday, November 24, 2025 to consider the
amended application. Separately, Jerome County is considering a draft renewable energy
ordinance to protect the County from future wind projects.
High Risk of Abandonment. On October 31, 2025, the Federal Energy Regulatory
Commission (FERC) issued an order granting Great Basin-LS Power rate incentives for the
SWIP-N which could harm ratepayers.'1 FERC agreed to impose 100% of the abandoned costs
their comprehensive plans and provides ordinance authority and processes for granting
such permits."
$Idaho Code: 67-6508(h).
9 Jerome County Plan(2018), Chapter 10 Utilities.Available at:
https://www.j eromecountyj ail.org/DocumentCenterNiew/569/Appendix-B-Maps
10 KIVITV, "Jerome County delays decision on appeal to withdraw 30-year-old SWIP
energy transmission line permits; Residents challenge planning approval for Southwest Intertie
Project linking southern Idaho to Las Vegas, citing incomplete documentation and notification
issues," dated September 23, 2025. Available at: https://www.kivitv.com/jerome/jerome-count
delays-decision-on-appeal-to-withdraw-30-year-old-swig-energy-transmission-line-permits
11 Great Basin Transmission, 193 FERC ¶ 61,083 in Docket ER25-2025-002.
6

of the line on ratepayers, if the line is abandoned for reasons beyond the control of LS Power.
FERC's decision increases the likelihood that LS Power will abandon the line,potentially
exposing Idaho ratepayers to its share of abandoned costs. FERC also agreed to LS Power's
request to charge ratepayers for all of its precommercial expenses. It appears that LS Power
acquired the rights to the line in 2005, which would saddle ratepayers with over 20 years of
precommercial costs.
For these reasons, I respectfully request that the Commission deny the application.
Thank you for considering my views in this matter.
Respectfully submitted,
/S/
Dean Dimond
President
Stop Lava Ridge, Inc.
1454 Highway 25, Jerome, ID, 83338.
cc: Donovan Walker, Idaho Power, dwalkergidahopower.com
Tim Tatum, Idaho Power, ttatumgidahopower.com
Idaho Power, [e-mail]
Rep. David Leavitt
TWIN FALLS TIMES NEWS-EDITORIAL BOARD
Why a wind proiect approval has southern Idaho feeling betrayed
Dec 14, 2024 • ma icg valley.com
The decision last week by the Bureau of Land Management to give a green light to the Lava
Ridge Wind Project will leave a sour taste in its wake for thousands of Idahoans, as it should.
That's because the decision was a bad one, made in spite of strong opposition from lawmakers,
businesses and residents in southern and eastern Idaho.
The agency's decision clears the way for the company LS Power to move ahead on a scaled
down version of a plan that will stretch across more than 100,000 acres of public land north of
Twin Falls and include 241 wind turbines that climb up to 660 feet. To put that height in
perspective, these industrial behemoths would dwarf nearly every human-made structure in the
Magic Valley, fundamentally altering a landscape that has remained largely unchanged since the
days of the Oregon Trail.
That's not good for the region nor for its residents.
7

The proposal has never been very popular in Idaho—the state's entire Congressional delegation
opposes the venture as does the vast majority of Idahoans—and the end result will most likely be
a series of legal battles in court.
The level of opposition—especially locally—was and is huge. Ranchers, environmentalists,
tribal representatives and history preservationists found unusual common ground in resisting the
project.
At its heart, the Lava Ridge project is at the epicenter of competing priorities, between
promoting clean energy, safeguarding the environment and protecting historic sites such as the
Minidoka National Historic area. The project also raises key questions about land use in the
West, where federal decisions often clash with local interests and generations-old ways of life.
The Bureau of Land Management, of course, will take the brunt of the criticism, and there isn't
much doubt the federal agency made a bad decision on this one. The BLM, however, is an arm
of the federal government. The agency is issued its marching orders from policy makers—those
in Congress—and top administration officials. The BLM is just fulfilling its duty.
If there was one glaring error on the part of the BLM and its federal overlords, it was the
seeming lack of attention to the voices in opposition to the project. Many, many people from
across a wide spectrum of life in south-central Idaho voiced opposition to the project, including
an April 2023 rally in downtown Twin Falls that drew hundreds speaking out in opposition to the
project. The demonstration wasn't just another protest—it represented a cross-section of Idaho
society united in their concern for their community's future.
Yet the larger wheelbarrow load of blame should rest where it belongs—with the Biden
administration—as U.S. Sens. Jim Risch and Mike Crapo both pointed out when they criticized
the decision last week.
The administration developed priorities— such as a devotion to clean energy—from afar, without
taking into account the unintended consequences of its choices—not to mention the will of the
people who actually live here.
This disconnect between Washington's policy priorities and local realities has become an
increasingly familiar pattern across the West. That's not good news for the region nor for the
future.
The project's location near the Minidoka National Historic Site—just 9 miles away—also should
have triggered a pause among federal officials regarding the venture. Minidoka stands as a
solemn reminder of one of America's darkest chapters, where thousands of Japanese Americans
were unjustly incarcerated during World War II.
The site's power lies partly in its isolated setting,which helps visitors understand the desolation
faced by those imprisoned there. Industrial-scale wind development would forever alter this
historic context.
8

Those who support Lava Ridge consistently argue it will encourage energy independence and
help Idaho's economy. Advocates cite a huge amount of tax revenue—more than $200 million—
generated by the project for the state.
While that is a lot of money, deeper questions regarding who ultimately really benefits from the
project remain unanswered. The projected economic benefits must be weighed against potential
impacts on tourism, ranching and other traditional economic activities in the region.
The future of the project, though, isn't set in stone. Legal challenges have already been promised
by opponents of the project and no one in the Magic Valley should expect to see 600-foot towers
going up any time soon. Multiple conservation groups have announced their intention to
challenge the decision in court, citing violations of various federal environmental and historic
preservation laws.
Crapo said the timing of the decision"is par for the course for the Biden Administration"and
expressed his intention to work with "the incoming Trump Administration to have this project
reviewed thoughtfully and thoroughly."His statement reflects a growing frustration with federal
decision-making that seems increasingly detached from local concerns and realities.
The reality is that even well-intentioned priorities compete, and the voice of the people impacted
should be considered—not ignored. In the end, the Lava Ridge project is a classic study
regarding what occurs when officials grasp onto "feel-good" concepts— such as energy
independence—and then ram them down voters' throats.
Source: TIMES-NEWS EDITORIAL BOARD • Dec 14, 2024 • magicvalley.com
9