20260618CEO Answer to and Concurrence with IIPAs Motion for Technical Hearing.pdf

RECEIVED
June 18, 2026
IDAHO PUBLIC
Kelsey Jae (ISB No. 7899) UTILITIES COMMISSION
1652 S. Riverstone Ln. Apt. 302
Boise, Idaho 83706
[phone]
[e-mail]
Attorney for the Clean Energy Opportunities of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO )
POWER COMPANY'S PETITION )
TO EVALUATE CLASS ) CASE NO. IPC-E-26-07
COST-OF-SERVICE )
METHODOLOGY, CONSIDER ) CLEAN ENERGY OPPORTUNITIES
ALTERNATIVE CLASS ) FOR IDAHO'S ANSWER TO AND
COST-OF-SERVICE STUDIES,AND ) CONCURRENCE WITH IIPA'S
DETERMINE COST OF SERVICE ) MOTION FOR TECHNICAL
CONSIDERATIONS FOR NEW ) HEARING
LARGE-LOAD CUSTOMERS )
Clean Energy Opportunities for Idaho ("CEO"), by and through its counsel of record, and
pursuant to the Idaho Public Utilities Commission's Rules of Procedure, including Rule 57,
hereby answers and states concurrence with Idaho Irrigation Pumpers Association, Inc.
("IIPA")'s Motion for Technical Hearing as follows.
CEO supports IIPA in its request for a technical hearing in this case.
CEO has contended for years that generation technology, grid operations, transmission
access across regions, and vastly increased market purchases are fundamentally changed from
the utility structure reflected in the 1992 NARUC manual. Failure to recognize these changes
poses unacceptable risk to the fairness of cost allocation across classes. The presence of very
large load customers exacerbates the problem.
CEO Answer to and Concurrence with Motion - 1
IPC-E-26-07

Current conditions require adaptations to the traditional cost analysis methods, and to
implement those adaptations the Commission must make policy decisions. CEO raised the
concern from as early as the petition for intervenor status that CEO sees a very real risk that the
needed policy choices can "get buried in the math". Absent a technical hearing in which the
Commissioners would get an opportunity to ask questions of the parties on the important issues,
CEO fears a review of the large amount of information in the case record will not serve to focus
on the critical assumptions and policy issues that will guide how cost allocation evolves to more
fairly and efficiently serve public interest.
Granting a technical hearing is necessary to remedy this situation. CEO concurs with and
respectfully requests that the Commission grant IIPA's Motion for Technical Hearing.
DATED THIS JUNE 18, 2026
Respectfully submitted,
ow�vW
Kelsey Jae
Attorney for CEO
CEO Answer to and Concurrence with Motion - 2
IPC-E-26-07

CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of June, 20261 delivered true and correct copies of
the foregoing ANSWER AND CONCURRENCE to the following persons via the method of
service noted:
Electronic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
Monica Barrios-Sanchez
Commission Secretary
secretary0puc.idaho.gov
Idaho PUC Staff
Erika Melanson
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Lisa Lance
Timothy Tatum
Grant Anderson
[e-mail]
llance0idahopower.com
ttatumOidahopower.com
[e-mail]
dockets(a)idahopower.com
Bayer
Thomas J. Budge
Ethan Waltermire
Brian C. Collins
Greg Meyer
tj(@racineolson.com
ethan.waltermire0bayer.com
[e-mail]
meyer0consultbai.com
City of Boise
Ed Jewell
Katie O'Neil
ei ewell(a)ciiyofboise.org
[e-mail]
CEO Answer to and Concurrence with Motion - 3
IPC-E-26-07

[e-mail]
Federal Executive Agencies
Emily W. Medlyn
Jelani A. Freeman
Dwight Etheridge
emily.medl n0hq.doe.gov
j elani.freemanOhq.doe.gov
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman, Ph.D.
Deborah Glosser, Ph.D.
eloQechohawk.com
lance aegisinsight.com
[e-mail]
Industrial Customers of Idaho
Peter J. Richardson
peter0richardsonadams.com
Micron Technology
Austin Rueschhoff
Thorvald A. Nelson
Richard A. Arnett
[e-mail]
tnelson(a)hollandhart.com
raarnett(a)hollandhart.com
[e-mail]
aclee0hollandhart.com
Northwest Energy Coalition
Benjamin J. Otto
Lauren McCloy
Derek Goldman
ben@nwenerge�org
laurenOnwenerg_�org
derekOnwenerge�org
ow�vV
Kelsey Jae
Attorney for CEO
CEO Answer to and Concurrence with Motion -4
IPC-E-26-07