20260213Application for Intervenor Funding.pdf

Eric L. Olsen(ISB#4811)
ECHO HAWK& OLSEN, PLLC RECEIVED
505 Pershing Ave., Ste. 100 FEBRUARY 13, 2026
IDAHO PUBLIC
P.O. Box 6119
UTILITIES COMMISSION
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
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-25-29
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC IDAHO IRRIGATION PUMPERS
CONVENIENCE AND NECESSITY FOR ASSOCIATION,INC.'S
THE BENNETT GAS EXPANSION APPLICATION FOR INTERVENOR
PROJECT AND FOR FUNDING
AN ASSOCIATED ACCOUNTING ORDER
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.
Glosser") participated in Idaho Power Company's ("IPC" or "Company") Application for a
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 1
CASE NO.IPC-E-25-29

Certificate of Public Convenience and Necessity("CPCN")for the Bennett Gas Expansion Project
and for an Associated Accounting Order. Mr. Olsen, Dr. Kaufman and Dr. Glosser reviewed and
analyzed the Company's positions, prepared and served written discovery, and prepared written
comments.
Through this review, IIPA identified material deficiencies in the Company's showing of
necessity, including the failure to evaluate system capacity absent Additional Firm Load("AFL"),
the absence of any quantified analysis demonstrating coincident peak growth attributable to
existing customer classes, and the Company's reliance on a single, assumption-laden capacity
position that embeds AFL by default. Using Idaho Power's own data produced in discovery, IIPA
demonstrated that removal of even a single disclosed AFL driver eliminates the claimed 2028
capacity deficit, thereby clarifying that the asserted need for the project is driven by customer-
specific load rather than by system-wide requirements of existing customers. This analysis assisted
in developing a more complete and accurate evidentiary record regarding the true drivers of
capacity need in this proceeding.
(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 electronic solicitations 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
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 2
CASE NO.IPC-E-25-29

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) IIPA recommended that the Commission deny or defer the requested CPCN
because the Company failed to carry its burden of proof to demonstrate that the Bennett Gas
Expansion Project is necessary to serve the public. The Company admits it did not evaluate system
capacity absent AFL, did not perform sensitivity analyses excluding AFL, and did not quantify
coincident peak contributions by legacy customer classes. IIPA further recommended that the
Commission avoid prejudging cost causation and risk allocation by approving a long-lived, rate-
based resource where the alleged need is driven by speculative and customer-specific load growth,
key planning assumptions are acknowledged by the Company to be fluid, and no binding
mechanism exists to ensure that the customers causing the need will bear the associated costs and
risks. These recommendations materially differ from the recommendations of Commission Staff.
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CASE NO.IPC-E-25-29

(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 131h day of February, 2026.
ECHO HAWK& OLSEN
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 4
CASE NO.IPC-E-25-29

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of February, 2026, I served a true, correct and
complete copy of the foregoing to each of the following, via the method as indicated below:
Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail
Erika Melanson, Deputy Attorney General ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
P.O. Box 83720 ❑ Telecopy(Fax)
Boise, ID 83720-0074 ® Electronic Mail (Email)
[e-mail]
erika.melanson(i�puc.Idaho.gov
Lance Kaufman, Ph.D. ❑ U.S. Mail
2623 NW Bluebell Place ❑ Hand Delivered
Corvallis, OR 97330 ❑ Overnight Mail
lance@ae isg insi.hg t.com ❑ Telecopy(Fax)
® Electronic Mail (Email)
Donovan E. Walker ❑ U.S. Mail
Timothy Tatum ❑ Hand Delivered
1221 W. Idaho Street(83702) ❑ Overnight Mail
P.O. Box 70 ❑ Telecopy(Fax)
Boise, ID 83707 ® Electronic Mail (Email)
dwalker(&�idahopower.com
[e-mail]
com
ttatum(&b,iidahopower.com
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland& Hart, LLP
Micron Technology, Inc.
555 17th Street Suite 3200
Denver, CO 80202
darueschhoff(&,hollandhart.com
[e-mail]
awj ensen(d),hollandhart.com
[e-mail]
aclee(&,hollandhart.com
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.APPLICATION FOR INTERVENOR FUNDING—Page 5
CASE NO.IPC-E-25-29

EXHIBIT A
Expert Witnesses: Deborah Glosser and Lance Kaufman,Expenses:
1. Witness Fees: 28.16 Hours @ $275 = $ 7,744.00
Sub Total: $ 7,744.00
Legal Expenses:
1. Paralegal Fees: 5.9 Hours @ $155 = $ 914.50
2. Legal Fees Eric L. Olsen: 3.1 Hours @ $250 = $ 775.00
3. Soft Costs (Copies/Legal Research) $ 8.70
Sub Total: $ 1,698.20
Grand Total: $ 9,442.20
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