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Home My WebLink About20260610Motion for Technical Hearing.pdf Eric L. Olsen(ISB#4811) ECHO HAWK& OLSEN, PLLC RECEIVED 505 Pershing Ave., Ste. 100 JUNE 10, 2026 P.O. Box 6119 IDAHO PUBLIC Pocatello, Idaho 83205 UTILITIES COMMISSION Telephone: (208) 478-1624 Facsimile: (208) 478-1670 Email: elo&echohawk.com Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE IDAHO POWER CASE NO. IPC-E-26-07 COMPANY'S PETITION TO EVALUATE CLASS COST-OF-SERVICE MOTION FOR TECHNICAL METHODOLOGY, CONSIDER HEARING ALTERNATIVE CLASS COST-OF- SERVICE STUDIES,AND DETERMINE COST OF SERVICE CONSIDERATIONS FOR NEW LARGE-LOAD CUSTOMERS Idaho Irrigation Pumpers Association, Inc. ("IIPA"), by and through its counsel of record, and pursuant to the Idaho Public Utilities Commission's Rules of Procedure, including Rules 202, 203, and 241, hereby respectfully moves the Commission for an Order setting this matter for a technical hearing. In support of this Motion, IIPA states as follows: INTRODUCTION 1. This proceeding presents complex and consequential issues regarding cost-of- service ("COS") methodologies, including how costs are allocated among customer classes and how the costs of new large load ("NLL") customers will be identified and assigned. These issues will directly affect rates paid by Idaho Power Company's customers for years to come. Accordingly, IIPA brings this Motion to ensure that the Commission has the benefit of a fully developed evidentiary record, including cross-examination of witness testimony,before resolving the unsettled issues in this docket. MOTION FOR TECHNICAL HEARING—Page 1 CASE NO.IPC-E-26-07 2. Staff of the Idaho Public Utilities Commission ("Staff'), represented by the Idaho Attorney General's Office, State General Counsel Division, has expressly recognized that parties seeking a technical hearing should file a motion for a hearing so it can be considered when the procedural schedule is presented to the Commission for approval. Accordingly, IIPA brings this Motion to ensure that the Commission has the benefit of a fully developed evidentiary record, including cross-examination of witness testimony, before resolving the unsettled issues in this docket. BACKGROUND 3. On March 31, 2026, Idaho Power Company filed its petition initiating this case, presenting multiple cost-of-service methodologies for Commission review. The Commission and Staff have emphasized that this proceeding is intended to produce a robust and complete evidentiary record sufficient to guide future ratemaking and cost allocation decisions. 4. Consistent with that objective, Staff has proposed a procedural schedule that includes workshops, comments, discovery, and final briefing, but leaves open the question of whether a technical hearing is necessary. The current schedule contemplates a discovery cutoff of November 11, 2026, final comments due December 16, 2026, and position briefs filed December 31, 2026. 5. Additionally, Staff has indicated that parties interested in a technical hearing should request one through motion practice so that the Commission may determine whether to include such a hearing in the procedural schedule. ARGUMENT A Technical Hearing Is Necessary to Develop a Complete Evidentiary Record 6. The Commission has already determined that this docket should result in a"robust record" capable of supporting future ratemaking decisions. The issues presented, including MOTION FOR TECHNICAL HEARING—Page 2 CASE NO.IPC-E-26-07 competing COS methodologies, embedded versus alternative approaches, and allocation principles, are highly technical and cannot be adequately resolved through written comments alone. A technical hearing will allow for the presentation of sworn testimony, cross-examination of witnesses,clarification of competing methodologies,and the development of a clear and testable evidentiary record. Without a hearing, the Commission would be required to resolve disputed factual and analytical issues based solely on written submissions, limiting the ability to fully vet the underlying assumptions. Significant Unresolved Issues Will Likely Warrant Cross-Examination 7. Numerous parties have identified complex issues that will benefit from hearing testimony because said issues will likely not be settled, including the appropriate treatment of new large load ("NLL") customers and which incremental costs they should bear; whether cost allocation should include generation,transmission,and locational cost components;how to address costs incurred before service begins and when NLL customers transition to existing customers; and how different COS methodologies affect inter-class cost shifts and resulting rate impacts. These issues involve likely involve disputed facts, modeling decisions, and policy judgments embedded within technical analyses, making cross-examination essential to test those competing positions. A Technical Hearing Fits Logically Within the Existing Schedule 8. IIPA proposes that the Commission schedule a technical hearing between December 1 and December 15, 2026. This window is appropriate because it follows the close of discovery on November 11, 2026, allows sufficient time for preparation of testimony and exhibits, and precedes final comments due on December 16, 2026, thereby enabling the parties to incorporate hearing evidence into the record. It also supports the filing of position briefs on MOTION FOR TECHNICAL HEARING—Page 3 CASE NO.IPC-E-26-07 unsettled issues on December 31, 2026. Thus, a hearing during this timeframe will enhance,rather than disrupt, the orderly progression of the case. 9. In addition, the current procedural schedule contemplates final comments due on December 16, 2026 and position briefs on December 31, 2026. In the event a technical hearing is scheduled in early to mid-December, these deadlines would not provide sufficient time for parties to review hearing transcripts,evaluate the evidentiary record, and prepare meaningful post-hearing submissions, particularly given typical scheduling constraints during the holiday period. Accordingly, a modest extension of the final comment deadline into mid-January 2027, and adjusting the target order date to mid-February 2027, is reasonable and necessary to ensure that the record developed through the technical hearing can be fully and effectively presented to the Commission. The Importance of the Issues Supports Holding a Hearing 10. This docket will establish guiding principles for future general rate cases, cost allocation among customer classes, and treatment of large load growth on Idaho Power's system. As Staff has recognized, the outcome of this proceeding is intended to position the Commission and parties for future ratemaking decisions. Given the magnitude and long-term implications of these issues, a technical hearing is both reasonable and necessary. Absent a technical hearing, the Commission will be required to resolve these complex and disputed issues without the benefit of testimony subject to cross-examination, which would be inconsistent with the Commission's goal of developing a complete and reliable evidentiary record. REQUESTED RELIEF 11. Idaho Irrigation Pumpers Association, Inc. respectfully requests that the Commission set this matter for a technical hearing to allow the parties sufficient opportunity to MOTION FOR TECHNICAL HEARING—Page 4 CASE NO.IPC-E-26-07 develop and present a complete evidentiary record, including through cross-examination of witness testimony. 12. The technical hearing is respectfully requested to occur between December 1 and December 15, 2026. 13. Further, it is requested that adjusting the procedural schedule is necessary to accommodate the technical hearing, including extending the deadline for final comments or closing briefs to mid-January 2027 and adjusting the target order date to mid-February 2027. DATED this 10th day of June 2026. ECHO HAWK& OLSEN ERIC L. OLSEN MOTION FOR TECHNICAL HEARING—Page 5 CASE NO.IPC-E-26-07 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this I01h day of June 2026, 1 served a true, correct and complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to Intervene to each of the following, via the method indicated below: Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail Idaho Public Utilities Commission ❑ Hand Delivered P.O. Box 83720, Boise, ID 83720-0074 ❑ Overnight Mail secretgUkpuc.idaho._og_v ❑ Telecopy(Fax) ® Electronic Mail (Email) Megan Goicoechea Allen ❑ U.S. Mail Lisa Lance ❑ Hand Delivered Timothy Tatum ❑ Overnight Mail Grant T. Anderson ❑ Telecopy (Fax) Idaho Power Company ® Electronic Mail (Email) 1221 W. Idaho Street(83702) P.O. Box 70, Boise, ID 83707 mgoicoecheaallen(cidahopower.com llancegidahopower.com dockets(&,idahopower.com ttatumgidahopower.com ganderson(d,idahopower.com Idaho Irrigation Pumpers Association ❑ U.S. Mail Lance Kaufman, Ph.D. ❑ Hand Delivered Deborah Glosser, Ph.D. ❑ Overnight Mail 2623 NW Bluebell Place. Corvallis, OR 97330 ❑ Telecopy(Fax) lance(d),ae isg insi hg t.com ® Electronic Mail (Email) deborah._log sser&gmail.com Erika Melanson, Commission Staff ❑ U.S. Mail Deputy Attorney General ❑ Hand Delivered Idaho Public Utilities Commission ❑ Overnight Mail 11331 W. Chinden Blvd., Bldg. No. 8, Suite 201-A (83714) ❑ Telecopy(Fax) PO Box 83720, Boise, ID 83702 ® Electronic Mail (Email) E-mail: erika.melanson&puc.idaho.gov Benjamin J. Otto (Northwest Energy Coalition) ❑ U.S. Mail 1407 W. Cottonwood Ct. Boise, ID 83702 ❑ Hand Delivered E-mail: ben(cnwenergy.org ❑ Overnight Mail Lauren McCloy, Utility& Regulatory Director ❑ Telecopy(Fax) E-mail: lauren(d),nwenergy.org ® Electronic Mail (Email) Derek Goldman, Policy Associate E-mail: derek(d),nwenergy.org MOTION FOR TECHNICAL HEARING—Page 6 CASE NO.IPC-E-26-07 Clean Energy Opportunities ❑ U.S. Mail Kelsey Jae ❑ Hand Delivered 521 E. 41 st St., #506, Garden City, ID 83714 ❑ Overnight Mail E-mail: kelsey&kelseyjae.com ❑ Telecopy(Fax) Mike Heckler ® Electronic Mail (Email) Courtney White Clean Energy Opportunities for Idaho 3778 Plantation River Dr., Ste. 102, Boise, ID 83703 E-mail: mike(c cleanenergyopportunities.com courtney&cleanenerg_yopportunities.com Ed Jewell ❑ U.S. Mail Deputy City Attorney ❑ Hand Delivered Boise City Attorney's Office 150 N. Capitol Blvd. ❑ Overnight Mail P.O. Box 500, Boise, ID 83701-0500 ❑ Telecopy (Fax) E-mail: eiewellkcityofboise.org ® Electronic Mail (Email) boiseci . attorney(kcityofboise.org Katie O'Neil Energy Program Manager Boise City Department of Public Works E-mail: koneilkcityofboise.org Industrial Customers of Idaho ❑ U.S. Mail Peter J. Richardson ❑ Hand Delivered Richardson Adams, PLLC ❑ Overnight Mail 515 N. 27th St., Boise, ID 83702 ❑ Telecopy (Fax) E-mail: peter(krichardsonadams.com ❑ Electronic Mail (Email) Micron Technology, Inc. ❑ U.S. Mail Austin Rueschhoff ❑ Hand Delivered Thorvald A. Nelson ❑ Overnight Mail Richard A. Arnett ❑ Telecopy (Fax) Holland& Hart, LLP ® Electronic Mail (Email) 555 17th St., Ste. 3200, Denver, Co 80202 E-mail: darueschhoff(a hollandhart.com tnelson&hollandhart.com raamett(&,,hollandhart.com tlfrielnhollandhart.com aclee(a,hollandhart.com Federal Executive Agencies, U.S. Department of Energy ❑ U.S. Mail Emily W. Medlyn ❑ Hand Delivered Jelani A. Freeman ❑ Overnight Mail 1000 Independence Ave., S.W., Washington, D.C. 20585 ❑ Telecopy(Fax) E-mail: emily.medly(d),hq.doe.gov ® Electronic Mail (Email) j elan.freeman(khq.doe.gov MOTION FOR TECHNICAL HEARING—Page 7 CASE NO.IPC-E-26-07 Dwight Etheridge ❑ U.S. Mail Exeter Associates, Inc. ❑ Hand Delivered 10480 Little Patuxent Parkway, Ste. 300, ❑ Overnight Mail Columbia, MD 21044 ❑ Telecopy(Fax) E-mail: detheridge(d),exeterassociates.com ® Electronic Mail (Email) Bayer ❑ U.S. Mail Thomas J. Budge ❑ Hand Delivered Racine Olson, PLLP ❑ Overnight Mail P.O. Box 1391, Pocatello, ID 83204-1391 ❑ Telecopy (Fax) E-mail: tj&racineolson.com ® Electronic Mail (Email) Ethan Waltermire P4 Production, L.L.0 P.O. Box 816, Soda Springs, ID 83276 E-mail: ethan.waltermire(kbayer.com Brian C. Collins Greg Meyer Brubaker&Associates 16690 Swingley Ridge Rd., #140, Chesterfield, MO 63017 E-mail: bcollins(kconsultbai.com gmeyer(&,,consultbai.com ERIC L. OLSEN MOTION FOR TECHNICAL HEARING—Page 8 CASE NO.IPC-E-26-07