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Home My WebLink About20251229Application for Intervenor Funding.pdf RECEIVED DECEMBER 29, 2025 IDAHO PUBLIC UTILITIES COMMISSION Eric L. Olsen(ISB#4811) 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-24-44 COMPANY'S APPLICATION FOR APPROVAL OF A SPECIAL CONTRACT APPLICATION FOR INTERVENOR AND TARIFF SCHEDULE 28 TO PROVIDE FUNDING OF THE IDAHO ELECTRIC SERVICE TO MICRON IDAHO IRRIGATION PUMPERS SEMICONDUCTOR MANUFACTURING ASSOCIATION,INC. (TRITON) LLC 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 witnesses Lance D.Kaufman,Ph.D. ("Dr.Kaufman")participated extensively in the review APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 1 CASE NO.IPC-E-24-44 of Idaho Power Company's ("IPC") Application for Approval Micron's FAB Special Contract ("Micron ESA"). Mr. Olsen and Dr. Kaufman reviewed and analyzed the Company's positions, prepared and served extensive written discovery, prepared multiple rounds of written testimony and rebuttals, traveled to attend multiple hearings, and reviewed the technical hearing transcript and prepared a closing brief. A statement of IIPA's requested findings of Harm to IPC's non-large load customers and its requested modifications to the terms of the Micron ESA are found in IIPA's Closing Brief. IIPA's Closing Brief is incorporated herein by reference as if set forth in full. (C) The costs described in Exhibit A constitute a significant financial hardship for the IIPA as it is the highest costs it has ever incurred in participating in a single regulatory matter. 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 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 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 2 CASE NO.IPC-E-24-44 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 recommendations and positions materially differed from those offered by Commission Staff as shown by comparing Commission Staffs Post Hearing Brief with IIPA's Closing Brief. IIPA's Closing Brief and Staffs Post-Hearing Brief are incorporated herein by reference as if set forth in full. (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. 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_29t'day of December, 2025. ECHO HAWK& OLSEN ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 3 CASE NO.IPC-E-24-44 CERTIFICATE OF SERVICE I HEREBY CERTIFIY that on this 29th 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(&12uc.idaho.gov chris.burding]2uc.idaho.gov Megan Goicoechea Allen ❑ U.S. Mail Donovan E. Walker ❑ Hand Delivered Connie Aschenbrenner ❑ Overnight Mail Grant Anderson ❑ Telecopy(Fax) Idaho Power Company ® Electronic Mail (Email) 1221 W. Idaho Street (83702) P.O. Box 70 Boise, ID 83707 mgoicoecheaallengidahopower.com dwalkerO idahopower.com dockets gidahopower.com caschenbrennergidahop ower.com gandersongidahopower.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 4 CASE NO.IPC-E-24-44 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(ir hollandhart.com awj ensenghollandhart.com karoach(&hollandhart.c om aclee(a,hollandhart.com 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 peter _richardsonadams.com Dr. Don Reading ❑ U.S. Mail Industrial Customer of Idaho Power ❑ Hand Delivered 280 S. Silverwood Way ❑ Overnight Mail Eagle, ID 83616 ❑ Telecopy(Fax) dreadinggmindspring.com ® Electronic Mail (Email) Courtney White ❑ U.S. Mail Mike Heckler ❑ Hand Delivered Clean Energy Opportunities for Idaho ❑ Overnight Mail 3778 Plantation River Drive, Suite 102 ❑ Telecopy(Fax) Boise, ID 83703 ® Electronic Mail (Email) courtneygcleanenergopportunities.com mike(ab,cleanenergoEportunities.com Kelsey Jae (ISB No. 7899) ❑ U.S. Mail Clean Energy Opportunities for Idaho ❑ Hand Delivered 920 N. Clover Dr., Boise, ID 83703 ❑ Overnight Mail kelseygkelseyjae.com ❑ Telecopy(Fax) Z Electronic Mail (Email) ERIC L. OLSEN APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 5 CASE NO.IPC-E-24-44 EXHIBIT A Expert Witnesses: Deborah Glosser and Lance Kaufman,Expenses: 1. Witness Fees: 183.34 Hours @ $250= $ 45,835.00 Sub Total: $ 45,835.00 Legal Expenses: 1. Paralegal Fees: 30.4 Hours @ $155 = $ 4,712.00 2. Legal Fees Eric L. Olsen: 181.4 Hours @ $250 = $ 45,350.00 3. Soft Costs (Copies/Legal Research/Transcripts) $ 3,586.46 Sub Total: $ 53,648.46 Grand Total: $ 99,483.46 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.— Page 6 CASE NO.IPC-E-24-44