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Home My WebLink About20251216Application for Intervenor Funding.pdf RECEIVED DECEMBER 16, 2025 IDAHO PUBLIC Eric L. Olsen(ISB#4811) UTILITIES COMMISSION ECHO HAWK& OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 Telephone: (208) 478-1624 Facsimile: (208)478-1670 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-25-16 COMPANY'S APPLICATION FOR GENERAL RATE CASE APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC. 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 request 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 witness Lance D. Kaufman, Ph.D. ("Mr. Kaufman") participated in Idaho Power APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 1 CASE NO.IPC-E-25-16 Company's ("IPC") General Rate Case. Mr. Olsen and Dr. Kaufman reviewed and analyzed the Company's positions, prepared and served written discovery, prepared written testimony, and attended the technical hearing. Mr. Kaufman's review efforts focused on the review of the opening testimony and workpapers of all company witnesses, developing discovery on cost of capital, test year expenses, and cost of service, and the development of positions on appropriate adjustments to the Company's filed case. Prior to participation in settlement discussions IIPA identified and quantified potential adjustments related to the cost of capital, rate base, expenses, cost of service, rate spread, and rate design. Between settlement discussions, IIPA met with its members and other intervening parties to discuss issues in the case. IIPA proposed rate spread and rate design compromises that led to the Stipulation and Settlement and Request for Accounting Order associated Motion filed with the Commission on October 24,2025 (the"Proposed Settlement"). The IIPA's proposed findings and recommendations are captured in the Proposed Settlement. As a signatory, the IIPA believes that the Proposed Settlement and the resulting proposed revenue requirement and new rates are a fair, just and reasonable resolution to the issues addressed therein. (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 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 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 2 CASE NO.IPC-E-25-16 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 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) The majority of IIPA's concerns were addressed in the Proposed Settlement through changes to revenue requirement, rate spread and rate design, or indirectly through agreement for ongoing collaboration TOU rates for the irrigation class. IIPA proposed many of the compromises that led to the rate spread and rate design contained in the Proposed Settlement. As such, the issues that the IIPA raised and urged to be adopted by in the settlement discussions materially differed from those addressed by the Commission Staff and other parties. 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. (E) The IIPA represents the irrigation class of customers under Schedule 24 on IPC's system. APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 3 CASE NO.IPC-E-25-16 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 161h day of December 2025. ECHO HAWK& OLSEN ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 4 CASE NO.IPC-E-25-16 CERTIFICATE OF SERVICE I HEREBY CERTIFIY that on this 16th day of December 2025, I served a true, correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Application for Intervenor Funding to each of the following, via the method indicated below: Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail Chris Burdin, Deputy Attorney General ❑ Hand Delivered Idaho Public Utilities Commission ❑ Overnight Mail P.O. Box 83720 ❑ Telecopy(Fax) Boise, ID 83720-0074 ® Electronic Mail (Email) secretM(&j2uc.idaho.gov chris.burding]2uc.idaho.gov Megan Goicoechea Allen ❑ U.S. Mail Donovan E. Walker ❑ Hand Delivered Tim Tatum ❑ Overnight Mail Connie Aschenbrenner ❑ Telecopy(Fax) Matt Larkin ® Electronic Mail (Email) Idaho Power Company 1221 W. Idaho Street (83702) P.O. Box 70 Boise, ID 83707 mgoicoecheaallengidahopower.com dwalker(a,idahopower.com dockets gidahopower.com ttatum(c-r�,idahopower.com caschenbrenner(a,idahop ower.com mlarkin(ab,idahopower.com Lance Kaufman, Ph.D. ❑ U.S. Mail 2623 NW Bluebell Place ❑ Hand Delivered Corvallis, OR 97330 ❑ Overnight Mail lancegae isg insi h� ❑ Telecopy(Fax) ® Electronic Mail (Email) Michael Heckler ❑ U.S. Mail Courtney White ❑ Hand Delivered Clean Energy Opportunities for Idaho Inc. ❑ Overnight Mail 3778 Plantation River Dr., Ste 102 ❑ Telecopy(Fax) Boise, ID 83703 ® Electronic Mail (Email) mike(kcleanenergyopportunities.com Courtney( ,cleanenergyoupportunities.com Kelsey Jae ❑ U.S. Mail Law for Conscious Leadership ❑ Hand Delivered 920 N. Clover Dr. ❑ Overnight Mail APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 5 CASE NO.IPC-E-25-16 Boise, ID 83703 ❑ Telecopy(Fax) kelsey(ibkelseyjae.com ® Electronic Mail (Email) Ed Jewell ❑ U.S. Mail Deputy City Attorney ❑ Hand Delivered Boise City Attorney's Office ❑ Overnight Mail 150 N. Capitol Blvd. ❑ Telecopy(Fax) PO Box 500 ® Electronic Mail (Email) Boise, ID 83701-0500 ejewell(&cityofboise.org boisecityattorneyga,cityofboise.org Katie O'Neil ❑ U.S. Mail Energy Program Manager ❑ Hand Delivered Boise City Attorney's Office ❑ Overnight Mail 150 N. Capitol Blvd. ❑ Telecopy(Fax) PO Box 500 ® Electronic Mail (Email) Boise, ID 83701-0500 koneilgcityof boise.org Emily W Medlyn ❑ U.S. Mail Jelani A Freeman ❑ Hand Delivered U.S. Department of Energy ❑ Overnight Mail 1000 Independence Ave., S.W. ❑ Telecopy(Fax) Washington, D.C. 20585 ® Electronic Mail (Email) emily.medlyn(&hq.doe.gov j elani.freemanghq.doe.gov Dwight Etheridge ❑ U.S. Mail Exeter Associates, Inc. ❑ Hand Delivered 10480 Little Patuxent Parkway, Ste. 300 ❑ Overnight Mail Columbia, ME ❑ Telecopy(Fax) detheridgegexeterassociates.com ® Electronic Mail (Email) Peter J. Richardson ❑ U.S. Mail Richardson, Adams, PLLC ❑ Hand Delivered Industrial Customer of Idaho Power ❑ Overnight Mail 515 N. 27th St. ❑ Telecopy(Fax) P.O. Box 7218 ® Electronic Mail (Email) Boise, ID 83702 petergrichardsonadams.com Austin Rueschhoff ❑ U.S. Mail Thorvald A. Nelson ❑ Hand Delivered Austin W. Jensen ❑ Overnight Mail APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 6 CASE NO.IPC-E-25-16 Kristine A.K. Roach ❑ Telecopy(Fax) Holland&Hart, LLP ® Electronic Mail (Email) Micron Technology,Inc. 555 17th Street Suite 3200 Denver, CO 80202 darueschhoff(a�hollandhart.com tnelsonghollandhart.com awj ensen(&hollandhart.c om karoach(a,hollandhart.com aclee(a,hollandhart.com tlfriel(a,hollandhart.com IdaHydro ❑ U.S. Mail c/o C. Tom Arkoosh ❑ Hand Delivered Nicholas J. Erekson ❑ Overnight Mail Arkoosh Law Offices ❑ Telecopy(Fax) 913 W. River Street, Suite 450 ® Electronic Mail (Email) P.O. Box 2900 Boise, ID 83701 tom.arkooshO)arkoo sh.com nick.ereksongarkoosh.com erin.cecil@arkoosh.com Kurt J. Boehm, Esq. ❑ U.S. Mail Jody Kyler Cohn, Esq. ❑ Hand Delivered BOEHM, KURTZ & LOWRY ❑ Overnight Mail 425 Walnut Street, Suite 2400 ❑ Telecopy(Fax) Cincinnati, OH 45202 ® Electronic Mail (Email) KB oehm(a,BKLlawfirm.com JkylercohngBKLlawfirm.com Gannon, et al., pro se ❑ U.S. Mail John Gannon ❑ Hand Delivered Randy Morris ❑ Overnight Mail Deborah Fease and Amy Lorrance ❑ Telecopy(Fax) Johngannon200( gmail.com ® Electronic Mail (Email) occidentalpacific(a�,hotmail.com feased854kgmail.com Benjamin J. Otto ❑ U.S. Mail Attorney for NWEC ❑ Hand Delivered Lauren McCloy ❑ Overnight Mail Derek Goldman ❑ Telecopy(Fax) 1407 W. Cottonwood Court ❑ Electronic Mail (Email) APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 7 CASE NO.IPC-E-25-16 Boise, ID 83702 ben(&nwenergy.org laurenknwenergy.org derekknwenergy.org ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 8 CASE NO.IPC-E-25-16 EXHIBIT A Expert Witnesses: Deborah Glosser and Lance Kaufman,Expenses: 1. Witness Fees: 88.76 Hours @ $250 = $ 22,190.00 Sub Total: $ 22,190.00 Legal Expenses: 1. Paralegal Fees: 9.8 Hours @ $155 = $ 1,519.00 2. Legal Fees Eric L. Olsen: 47.2 Hours @ $250 = $ 11,800.00 3. Soft Costs (Copies/Legal Research) $ 128.99 Sub Total: $ 13,447.99 Grand Total: $ 35,637.99 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 9 CASE NO.IPC-E-25-16