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Home My WebLink About20251223Application for Intervenor Funding.pdf RECEIVED DECEMBER 23, 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-25-23 COMPANY'S 2025 INTERGRATED RESOURCE PLAN 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 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. APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 1 CASE NO.IPC-E-25-23 Glosser")participated in the review of Idaho Power Company's("IPC")Integrated Resource Plan ("2025 IPR"or"IRP") filing. Mr. Olsen,Dr. Kaufman and Dr. Glosser reviewed and analyzed the Company's positions, prepared and served written discovery, and prepared extensive written comments. IIPA, Mr. Olsen, Dr. Glosser and Dr. Kaufman reviewed the 2025 IRP and identified certain improvements the IRP's modeling needs and that can continue to be improved upon. One of the elements being how the Company's IRP models and assumptions result in summer-only customers bearing a disproportionate share of demand-related costs.The 2025 IRP,as filed,creates a misleading record by attributing reliability and transmission needs to summer peaks, when in fact,the data show that winter load growth and new load due to large customers are the true drivers. IIPA acknowledges that Idaho Power has made strides in addressing several of the core IRP requirements. (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 emails 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 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 2 CASE NO.IPC-E-25-23 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 recommended that the Commission make explicit findings to ensure that the IRP's resource plan is contingent on infeasible or outdated project assumptions,that transmission and capacity needs are driven by new industrial load growth and adequacy, not by summer only customers; and that the incremental costs of major transmission additions must be attributed to the customers and conditions that cause them. These findings are imperative to ensure a misallocation of transmission and capacity costs to legacy irrigation and seasonal customers and make sure that the future rate recovery will align with the actual system cost drivers.As such it materially differs from the recommendations of Commission Staff. (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. APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 3 CASE NO.IPC-E-25-23 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 23rd day of December, 2025. ECHO HAWK& OLSEN �ZRO�� ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 4 CASE NO.IPC-E-25-23 CERTIFICATE OF SERVICE I HEREBY CERTIFIY that on this 23rd 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 Jeff Loll, 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(&12uc.idaho.gov j eff.loll&puc.idaho.gov Megan Goicoechea Allen ❑ U.S. Mail Donovan E. Walker ❑ Hand Delivered Timothy Tatum ❑ Overnight Mail Riley Maloney ❑ Telecopy(Fax) Micah Babbitt ® Electronic Mail (Email) Idaho Power Company 1221 W. Idaho Street (83702) P.O. Box 70 Boise, ID 83707 mgoicoecheaallengidahopower.com dwalkergidahopower.com dockets(&idahopower.com ttatumkidahopower.com rmaloney(a,idahopower.com mbabbitt&idahopower.com Lance Kaufman, Ph.D. ❑ U.S. Mail 2623 NW Bluebell Place ❑ Hand Delivered Corvallis, OR 97330 ❑ Overnight Mail lanceA,ae isg insi hg t.com ❑ Telecopy(Fax) ® Electronic Mail (Email) APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 5 CASE NO.IPC-E-25-23 Austin Rueschhoff ❑ U.S. Mail Thorvald A. Nelson ❑ Hand Delivered Austin W. Jensen ❑ Overnight Mail Kristine A.K. Roach ❑ Telecopy(Fax) Holland&Hart, LLP ® Electronic Mail (Email) Micron Technology, Inc. 555 171h Street Suite 3200 Denver, CO 80202 darueschhoff(a�hollandhart.com tnelson(i�hollandhart.com awj ensenghollandhart.c om karoach(&hollandhart.com aclee(a,hollandhart.com tlfrieWhollandhart.com Benjamin J. Otto ❑ U.S. Mail Attorney for NWEC ❑ Hand Delivered Lauren McCloy ❑ Overnight Mail Derek Goldman ❑ Telecopy(Fax) Mike Goetz ® Electronic Mail (Email) Katie Chamberlin Kyle Unruh 1407 W. Cottonwood Court Boise, ID 83702 bengnwenergy.org lauren(&nwenergy.org derekgnwenergy.org mike(a�,renewablenw.org katherinegrenewablenw.org kyle(a),renewablenw.org Irion Sanger ❑ U.S. Mail Sanger Greene,P.C. ❑ Hand Delivered 4031 DE Hawthorne Blvd. ❑ Overnight Mail Portland, OR 97214 ❑ Telecopy(Fax) irion(asanger-law.com ® Electronic Mail (Email) die gogsanger-law.com dustin(a),ranger-law.com j ohnlgrecoalition.com ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 6 CASE NO.IPC-E-25-23 EXHIBIT A Expert Witnesses: Deborah Glosser and Lance Kaufman,Expenses: 1. Witness Fees: 51.4 Hours @ $250 = $ 12,850.00 Sub Total: $ 12,850.00 Legal Expenses: 1. Paralegal Fees: 5.0 Hours @ $155 = $ 775.00 2. Legal Fees Eric L. Olsen: 12 Hours @ $250 = $ 3,000.00 3. Soft Costs (Copies/Legal Research) $ 63.29 Sub Total: $ 3,838.29 Grand Total: $ 16,688.29 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 7 CASE NO.IPC-E-25-23