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Home My WebLink About20260429Petition for Intervenor Funding.pdf RECEIVED Eric L. Olsen(ISB#4811) April 29, 2026 ECHO HAWK& OLSEN, PLLC IDAHO PUBLIC 505 Pershing Ave., Ste. 100 UTILITIES COMMISSION 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-26-03 COMPANY'S APPLICATION FOR APPROVAL OF THE 2032 ALL-SOURCE IDAHO IRRIGATION PUMPERS REQUEST FOR PROPOSALS TO MEET ASSOCIATION,INC.'S PETITION CAPACITY RESOURCE NEEDS IN AS FOR INTERVENOR FUNDING EARLY AS 2031. COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("IIPA"), by and through counsel of record, Echo Hawk & Olsen, PLLC, hereby respectfully petitions 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) Itemized List of Expenses 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. Itemized statements from IIPA's Counsel, Eric L. Olsen of Echo Hawk & Olsen and its Expert witness Deborah Glosser, PhD. are also included as Attachments 1 and 2 to Exhibit "A" in support of said summary and are incorporated by reference. B) Statement of Proposed Findings The IIPA recommended the Commission approve Idaho Power Company's 2032 All-Source Request for Proposals subject to targeted conditions requiring: (1) disclosure of final IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 1 CASE NO.IPC-E-26-03 shortlist bid rankings both with and without the application of imputed debt to third-party bids prior to Commission approval, so the Commission may assess whether that methodology materially affected resource selection; (2) real-time, concurrent audit oversight by Commission Staff with reporting obligations as a minimum substitute for the elimination of the independent evaluator,particularly where Idaho Power Company's internal bid competes with third-parry bids; and (3) preservation of disaggregated capacity-need modeling sufficient to distinguish capacity procured to serve Additional Firm Load from that serving existing customers, in order to maintain an adequate evidentiary record for the Commission's pending cost-of-service proceeding. C) Statement Showing Costs The IIPA is requesting $7,060.60 in intervenor funding for the expenses and costs described in Exhibit A. The expenses listed in this petition are reasonable, necessary, and directly related to meaningful participation in this proceeding. The costs reflect only those expenditures required to effectively review data and filings, prepare and submit data requests, prepare and submit written comments, and otherwise advocate on issues central to the intervenor's interests. All expenses are consistent with customary rates and practices for similar proceedings before the Commission and are proportionate to the scope and complexity of the issues addressed. The intervenor has exercised prudent judgment to minimize costs while ensuring effective representation. D) Explanation of Cost Statement The listed expenses 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 IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 2 CASE NO.IPC-E-26-03 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 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. E) Statement of Difference IIPA's position differed materially from that of Commission Staff in its recommended oversight and transparency conditions for approval of the 2032 All-Source RFP. While Staff supported approval with Staff review of the REP process and without mandatory reporting obligations, IIPA recommended conditional approval requiring parallel disclosure of bid results with and without the imputed debt adder and concurrent, real-time Staff audit oversight with binding reporting obligations if no independent evaluator were used. IIPA also sought preservation IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 3 CASE NO.IPC-E-26-03 of disaggregated modeling outputs for use in the pending cost-of-service proceeding to ensure that cost causers are ultimately paying for the burdens they place on the system, a requirement not included in Staff s recommendations. F) Statement of Recommendation IIPA's participation addressed issues of concern to the general body of utility users by recommending transparency and oversight measures that promote least-cost procurement, protect customers from unnecessary cost increases, and preserve the record needed to ensure just and reasonable rates for all Idaho Power customers. G) Statement Identifying Customer Class 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 29th day of April, 2026. ECHO HAWK& OLSEN ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 4 CASE NO.IPC-E-26-03 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 29th day of April, 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 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) secretga@Xuc.idaho.gov j eff.loll(&puc.Idaho.ggv Donovan E. Walker ❑ U.S. Mail Timothy Tatum ❑ Hand Delivered Connie Aschenbrenner ❑ Overnight Mail Idaho Power Company ❑ Telecopy(Fax) 1221 W. Idaho Street(83702) ® Electronic Mail (Email) P.O. Box 70 Boise, ID 83707 dwalkergidahopower.com dockets kidahopower.com ttatum(cr�,idaho power.com caschenbrennergidahopower.com Lance Kaufman, Ph.D. ❑ U.S. Mail Deborah Glosser, Ph.D. ❑ Hand Delivered 2623 NW Bluebell Place ❑ Overnight Mail Corvallis, OR 97330 ❑ Telecopy(Fax) lance(a),ae isg insi hg t.com ® Electronic Mail (Email) deborah. log sser(c�gmail.com Spencer Gray ❑ U.S. Mail Northwest&Intermountain Power Producers ❑ Hand Delivered Coalition ❑ Overnight Mail P.O. Box 504 ❑ Telecopy(Fax) Mercer Island, WA 98040 ® Electronic Mail (Email) sgrqy(�i),nippc.org Gregory M. Adams ❑ U.S. Mail Richardson Adams, PLLC ❑ Hand Delivered 515 N. 27th Street ❑ Overnight Mail Boise, Idaho 83702 ❑ Telecopy(Fax) greg(&xichardsonadams.com ® Electronic Mail (Email) IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 5 CASE NO.IPC-E-26-03 Irion Sanger ❑ U.S. Mail Sanger Greene, PC ❑ Hand Delivered 4031 SE Hawthorne Blvd. ❑ Overnight Mail Portland, OR 97214 ❑ Telecopy(Fax) irion(a�sanger-law.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) P. O. Box 500 ® Electronic Mail (Email) Boise, Idaho 83701- 0500 boisecityattomey(c,cityofboise.org ei ewellkcityofboise.org Katie O'Neil ❑ U.S. Mail Energy Program Manager ❑ Hand Delivered BOISE CITY DEPT. OF PUBLIC WORKS ❑ Overnight Mail 150 N. Capitol Blvd. ❑ Telecopy(Fax) P. O. Box 500 ® Electronic Mail (Email) Boise, Idaho 83701- 0500 konielkcityofboise.org Austin Rueschhoff ❑ U.S. Mail Thorvald A. Nelson ❑ Hand Delivered Richard A. Arnett ❑ Overnight Mail Holland & Hart LLP ❑ Telecopy(Fax) 555 17th Street, Suite 3200 ® Electronic Mail (Email) Denver, CO 80202 darueschho ff khollandhart.com tnelson(a,hollandhart.com raarnettkhollandhart.com aclee(a-,hollandhart.com tlfriel(a,hollandhart.com ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 6 CASE NO.IPC-E-26-03 EXHIBIT A Expert Witnesses: Deborah Glosser, Expenses: 1. Witness Fees: 19.42 Hours @ $275 = $ 5,340.50 Sub Total: $ 5,340.50 Legal Expenses: 1. Paralegal Fees: 5.1 Hours @ $155 = $ 892.25 2. Legal Fees Eric L. Olsen: 3.3 Hours @ $250 = $ 825.00 3. Soft Costs (Copies/Legal Research) $ 2.85 Sub Total: $ 1,720.10 Grand Total: $ 7,060.60 IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 7 CASE NO.IPC-E-26-03 ATTACHMENT 1 Date Fee Type Cost Amount Total Description 2/26/2026 Witness $275.00 1.5 $412.50 Meetings, misc emails 3/17/2026 Witness $275.00 1.25 $343.75 Draft data requests 3/25/2026 Witness $275.00 3.75 $1,031.25 Comment outline and begin draft 3/26/2026 Witness $275.00 6.75 $1,856.25 Comments drafting 3/27/2026 Witness $275.00 1 $275.00 Meeting with NIPPC and Staff 4/3/2026 Witness $275.00 3 $825.00 Modeling and analysis of discovery materials 4/5/2026 Witness $275.00 1.17 $321.75 Review of discovery materials 4/7/2026 Witness $275.00 1 $275.00 Final drafting of comments 19.42 $5,340.50 ATTACHMENT 2 Date Fee Type Cost Amount Total Description Draft petition for intervenor funding and update calendar with 2/25/2026 Paralegal $175.00 0.3 $52.50 dates;file petition with IPUC and update file 3/17/2026 Paralegal $175.00 0.4 $70.00 Calendar dates and update docket with order Edit and upload protective agreement for ELO, Lance and Debb to 3/23/2026 Paralegal $175.00 0.3 $52.50 sign for case and email on status 3/23/2026 Paralegal $175.00 0.7 $122.50 Draft data requests in case 3/25/2026 Paralegal $175.00 0.2 $35.00 Email back the fully signed protective agreement Finish DR's and file with the IPUC and update docket and file with 3/27/2026 Paralegal $175.00 0.6 $105.00 filings 4/7/2026 Paralegal $175.00 1.7 $297.50 Draft written comments in IIPA; revise with ELO updates Finish written comments forfiling and file with the IPUC; update 4/8/2026 Paralegal $175.00 0.7 $122.50 docket/file and calendar deadlines 4/15/20261 Paralegal $175.00 0.2 $35.00 Email on funding deadline and time entries 5.1 $892.50 2/25/2026 Legal $250.00 0.2 $50.00 See that Petition to Intervene is prepared for 2032 RFP case 3/2/2026 Legal $250.00 0.2 $50.00 Review and respond to emails re:scheduling in the RFP case Review NIPPC's discovery and email to Deborah Glosser for review; 3/3/2026 Legal $250.00 0.8 $200.00 TCW Greg Adams about possible issues with the RFP case and AFL Review application for the 2032 IRP and email same to Lance and Deborah for review;See that Petition to Intervene is prepare and 3/20/2026 Legal $250.00 1 $250.00 Ifiled Review Protective Agreement for 2032 RFP case and see same is 3/23/2026 Legal $250.00 0.4 $100.00 sent to Lance and Deborah for signing 3/24/2026 Legal $250.00 0.6 $150.00 Review and revise Data Requests for 2032 RFP case Email Deborah Glosser re: participating in intervenor and staff call 3/31/2026 Legal 1 $250.00 1 0.1 $25.00 Ion RFP 3.3 $825.00 2/27/2026 Soft EUL 5 14 $2.10 3/31/2026 Soft 5 5 $0.75 $2.85