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Home My WebLink About20251126IPC Objection and Request to Submit.pdf HIQAHO POWER, DONOVAN WALKER RECEIVED Lead Counsel NOVEMBER 26, 2025 dwal ker(gj)_i da h o power.corn IDAHO PUBLIC UTILITIES COMMISSION November 26, 2025 VIA ELECTRONIC FILING Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-25-08 Idaho Power Company's Application for a Certificate of Public Convenience and Necessity for an Ownership Interest in the Southwest Intertie Project — North 500-KV Transmission Line and Approval of the Utilization of Capacity on the Line Dear Commission Secretary: Attached for electronic filing, please find Idaho Power Company's Objection and Request to Submit for Decision in the above-entitled matter. If you have any questions about the attached document, please do not hesitate to contact me. Very truly yours, Donovan E. Walker DEW:sg Attachment 1221 W. Idaho St(83702) P.O. Box 70 Boise, ID 83707 DONOVAN E. WALKER (ISB No. 5921) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 dwalker(o-)idahopower.com Attorney for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR A ) CASE NO. IPC-E-25-08 CERTIFICATE OF PUBLIC ) CONVENIENCE AND NECESSITY FOR ) IDAHO POWER COMPANY'S AN OWNERSHIP INTEREST IN THE ) OBJECTION AND REQUEST TO SOUTHWEST INTERTIE PROJECT - ) SUBMIT FOR DECISION NORTH 500-KV TRANSMISSION LINE ) AND APPROVAL OF THE UTILIZATION ) OF CAPACITY ON THE LINE. ) COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and, pursuant to Idaho Public Utilities Commission's ("Commission") Rules of Procedure 201- 204 and the Notice of Modified Procedure, Order No. 36630, hereby objects to the late- filed, supplemental comments filed by Stop Lava Ridge ("SLR") seeking to introduce "new information" and respectfully requests that this matter be submitted for the Commission's determination at its next available Decision Meeting (December 2, 2025) and that the Commission issue its final order on this matter on or prior to December 12, 2025. IDAHO POWER COMPANY'S OBJECTION AND REQUEST TO SUBMIT FOR DECISION - 1 Objection to Comments Askinq the Commission to Consider "New Information" Irrelevant to the Case. The initial Application for a Certificate of Public Convenience and Necessity ("CPCN") and approval of utilization of north-bound capacity for the Southwest Intertie Project North ("SWIP North") transmission line in this matter was filed on March 7, 2025. The Commission issued its Notice of the Application on April 15, 2025, and set a 21-day intervention deadline. Order No. 36541. The Commission issued its Notice of Modified Procedure on June 5, 2025, setting a comment deadline for interested persons of July 17, 2025, and a Company reply comment deadline of July 31, 2025. Order No. 36630. On October 9, 2025, the Commission issued, sua sponte, a Notice of Virtual Public Workshop for October 21, 2025, and a Notice of Customer Hearing for October 23, 2025. Order No. 36800. Now on November 24, 2025, SLR has filed additional supplemental comments asking the Commission to consider "new information" and again requesting the Commission deny Idaho Power's CPCN application. Idaho Power objects to SLR's additional and supplemental comments as not only being filed several months past the interested persons comment deadline but also because they continue to make arguments that are irrelevant to the Commission's determination in this matter. As their name suggests they are opposed to the development of the Lava Ridge Wind project and advance arguments that the Commission should deny Idaho Power's request for SWIP- North for this reason and also to prevent export of generation to California. As stated in the Company's Reply Comments, SWIP-North is a transmission-only project that is entirely independent of the Lava Ridge and Salmon Falls projects and therefore any correlation SLR makes between them for this case is false. As concluded IDAHO POWER COMPANY'S OBJECTION AND REQUEST TO SUBMIT FOR DECISION - 2 by Staff, the Company will obtain south-to-north capacity, enabling power to be imported to Idaho;' Idaho Power will not have north-to-south capacity entitlements. Additionally, Idaho Power has full control over the output of its Company owned and contracted resources, so suggesting that California is going to take those resources, presumably against the will of the Company, lacks any foundation or basis in reality. Idaho Power always has, and will continue to, maximize the value of its resources to the benefit of Idaho Power's retail customers. North-Bound Transmission Capacity with Substantial Financial Benefits to Serve Idaho Customers. Commission Staff in its comments found that, "The financial benefits of participating in SWIP-North to Idaho ratepayers are substantial, so Staff believes it is in the ratepayers' best financial interest to proceed." Staff Comments, p 9. Staff acknowledged that, "The Company's system faces a series of annual capacity deficits due to very rapid load growth and Staff believes that obtaining 500 megawatts of northbound capacity on the SWIP-North transmission line is a least-cost, least-risk solution that helps reduce the capacity deficits." Id., p 2. Staff performed an extensive review in this proceeding, evaluating the costs, unquantifiable benefits, and various risks associated with the Project. Staff agreed that Idaho Power's analysis of ten portfolio topologies both with SWIP-North and without SWIP-North "shows a substantial net present value ("NPV") savings" [emphasis added] citing both the analysis performed as part of the 2023 Integrated Resource Plan as well as an updated analysis performed at Staff's request which indicated savings in the billions. Id., p 4-5. As Staff noted, the cost- effectiveness of SWIP-North is even greater when considering the expenditures Staff Comments, p 8. IDAHO POWER COMPANY'S OBJECTION AND REQUEST TO SUBMIT FOR DECISION - 3 associated with the two capital projects that can be deferred once the Project is in-service and with the anticipated increase in wheeling revenues due to the sale of unutilized capacity. Id., p 5. Time Limited Opportunity that Benefits Customers. The SWIP-North agreements (see Exhibit No. 5 to Mr. Jared Ellsworth's direct testimony) contain provisions that provide for certain termination rights should the agreements not receive Commission approval within six-months of filing. With the Application filed on March 7, 2025, that time period expired in September but was extended for ninety-days pursuant to the agreements to December 12, 2025. Idaho Power requests that the Commission issue its final order on or before December 12, 2025, so as not to invoke these potential termination provisions. Prayer for Relief. Idaho Power respectfully objects to the late-filed supplemental comments offering "new information," and alternatively if allowed and considered by the Commission they should be given little weight as they address issues related to the unrelated Lava Ridge Wind project and exports to California that are irrelevant here. Additionally, with all Commission-noticed deadlines for public comment having passed, Idaho Power respectfully requests that this matter be submitted for the Commission's determination at its next available Decision Meeting (December 2, 2025) and that the Commission issue its final order on this matter on or prior to December 12, 2025, so as to preserve the substantial customer benefits that this CPCN and utilization of transmission capacity enables for Idaho Power's retail customers. IDAHO POWER COMPANY'S OBJECTION AND REQUEST TO SUBMIT FOR DECISION -4 Respectfully submitted at Boise, Idaho this 26t" day of November 2025. DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S OBJECTION AND REQUEST TO SUBMIT FOR DECISION - 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 26th day of November, 2025, 1 served a true and correct copy of Idaho Power Company's Objection and Request to Submit for Decision upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8 FTP Site Suite 201-A (83714) X Email Chris.Burdin(a�puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Kristine A.K. Roach X Email da ruesch hoff(a-).hol land ha rt.com Holland & Hart LLP tnelson(a)hol land hart.com 555 17th Street, Suite 3200 awjensen hollandhart.com Denver, CO 80202 aclee(a�hol land hart.com karoach hol land hart.com Idaho Irrigation Pumpers Association, Inc. Hand Delivered Eric L. Olsen U.S. Mail ECHO HAWK & OLSEN, PLLC Overnight Mail 505 Pershing Avenue, Suite 100 FAX P.O. Box 6119 X EMAIL elo echohawk.com Pocatello, ID 83205 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX X EMAIL Iance(a)aegisinsight.com Stacy Gust, Regulatory Administrative Assistant IDAHO POWER COMPANY'S OBJECTION AND REQUEST TO SUBMIT FOR DECISION - 6