20260821Staff Comments.pdf

RECEIVED
August 21, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
KELSEA E. ROSS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO STATE BAR NO. 12050
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY AND PACIFICORP D/B/A ) CASE NOS. IPC-E-26-09
ROCKY MOUNTAIN POWER'S JOINT ) PAC-E-26-06
APPLICATION FOR CERTIFICATES OF )
PUBLIC CONVENIENCE AND NECESSITY )
FOR SEGMENT E-8 OF THE GATEWAY ) COMMENTS OF THE
WEST 500-KV TRANSMISSION LINE ) COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"),by and through its attorney of record, Kelsea E. Ross,Deputy Attorney General,
submits the following comments.
BACKGROUND
On April 3, 2026, Idaho Power Company ("IPC") and PacifiCorp d/b/a Rocky Mountain
Power("PAC")(collectively the"Companies")applied to the Commission requesting a Certificate
of Public Convenience and Necessity("CPCN") for each company permitting the commencement
of construction for Segment E-8 of the Gateway West ("GWW") 500-kilovolt ("kV") line
("Segment E-8"), which will provide an additional 2,000 megawatts ("MW") in transmission
capacity, no later than October 31, 2026 ("Application"). Application at 2.
On April 20, 2026, the Commission issued a Notice of Application and Notice of
Intervention Deadline, setting a deadline for interested parties to file a petition to intervene. Order
No. 37010. The Commission granted intervention to Idaho Irrigation Pumpers Association, Inc.
and Micron Technology, Inc. Order Nos. 37008 and 37045.
STAFF COMMENTS 1 AUGUST 21, 2026

STAFF ANALYSIS
The Companies have requested a CPCN giving them authorization to start construction of
Segment E-8 of GWW, which will provide 2,000 MW of transmission capacity. Application at 2.
Staff evaluated the Application and each company's request for a CPCN using two criteria: (1)
whether IPC and PAC are able to sufficiently justify that the project is needed in accordance with
Idaho Code §§ 61-526 and-528 and Commission Rules of Procedure 112 (IDAPA 31.01.01.112);
and (2) that the specific project is the least-cost and least-risk ("LC-LR") option compared to
feasible alternatives that can also meet IPC and PAC's need for the project.
Based on its review, Staff believes that IPC has demonstrated a capacity-based need, and
PAC has demonstrated a strategic-based need for Segment E-8, satisfying the regulatory
requirements for a CPCN. Regarding whether the project is the LC-LR option, Staff believes: (1)
IPC has presented compelling evidence that alternatives to the project are severely limited; and(2)
that PAC's need to demonstrate that the project is the LC-LR option is irrelevant due to its need
being strategic in nature and its miniscule cost share of the project.
Based on Staff s overall assessment under these criteria, Staff recommends the
Commission grant a CPCN to the Companies. However, Staff has three major concerns:
I. Segment E-8 exceeds the necessary capacity of the current forecasted load and has been
sized with an assumption of significant future load,which has implications for the cost-
effectiveness of this project and the future allocation of costs when IPC seeks recovery;
2. There is a significant risk of project delay that Staff believes IPC should proactively
mitigate, especially if IPC is contemplating the addition of new large loads ("NLL")as
defined in Idaho Code §61-335; and
3. There is a lack of meaningful cost-restraint on the project and therefore Staff
recommends that IPC provide additional details on its current project budget that the
Commission can review during its prudence determination when IPC seeks recovery in
a future case.
Staff has organized its comments according to the two regulatory criteria described above
and added a third section addressing binding rate-making treatment. Details of Staffs review,
concerns, and recommendations are provided in those sections.
STAFF COMMENTS 2 AUGUST 21, 2026

Justification of Need
Under Idaho Code §§ 61-526 and -528, IPC and PAC must show financial ability, good
faith, and the necessity of additional service in the community to receive a CPCN. Additionally,
to obtain a CPCN, the Companies must follow Commission Rule of Procedure 112 (IDAPA
31.01.01.112). Through discovery and review of the Companies' Application and supporting
documentation, Staff believes that both IPC and PAC have met the necessary regulatory
requirements for a CPCN. Staff s rationale and justifications for its conclusions are described
separately below.
IPC's Need for Segment E-8
Staff reviewed IPC Witness Ellsworth's("Ellsworth")testimony and believes that IPC has
a legitimate need to acquire Segment E-8 to support regional objectives,to provide likely economic
benefits to ratepayers, and to provide a power delivery path for new resources sited east of the
Treasure Valley.
First, Ellsworth explained that the relevant regional transmission planning authority,
NorthemGrid, has consistently identified GWW as an essential transmission line since 2007.
Ellsworth Direct at 8-9. Furthermore, "the 2024-2025 Regional Transmission Plan identifjied]
Segment E-8 of Gateway West as a key component of the plan." Id. at 9. Staff agrees that this
evidence supports the importance and necessity of the project to the Northwest region.
Second, Ellsworth explained that modeling of GWW in IPC's 2023 Integrated Resource
Plan ("IRP") showed that portfolios with GWW transmission lines were more economic than
portfolios without GWW. Id. at 16. Moreover, the various portfolios showed that the more
segments of GWW that were placed in service between Midpoint and Hemingway,the less costly
the portfolio became for IPC's ratepayers. Id. at 16; Id. at Table 2. Staff believes the portfolio
cost reductions occurred because the increased transmission capacity enabled access to new
resources and cost-effective market power. If Staffs premises are correct, Staff believes the
economic value of GWW transmission lines should increase as Treasure Valley loads increase.
Third,Ellsworth stated that"[w]hen developing the 2025 IRP portfolios,it had also become
clear that developing a portfolio without Segment E-8 ... was not a possibility." Id. at 18. His
explanation is as follows:
[IPC's] 2025 IRP portfolios included 2,695 MW of new gas, wind, and solar
generation resource additions. Based on recent permitting experiences and changes
STAFF COMMENTS 3 AUGUST 21, 2026

in laws, [IPC] does not believe it is realistic to assume nearly 3,000 MW of new
resources could all be sited with the Treasure Valley area. The limited capacity
available between the Magic Valley and Treasure Valley area necessitates a
transmission capacity upgrade east of the Treasure Valley to support the increased
generation.
Id. Given this perspective, IPC modeled Segment E-8 as a baseline assumption for the 2025 IRP.
Id. Staff believes that IPC's assertion that sufficient new resources cannot be sited in the Treasure
Valley is foundational to the justification for Segment E-8. Staff therefore evaluated IPC's
evidence for this assertion and believes that it is a reasonable determination. Specifically, Staff
agrees that "most of the resource proposals submitted in response to the [Request for Proposals]
have been east of the Treasure Valley." Id. Also, a proposed new resource planned for the
Treasure Valley was "stalled when developers were denied Conditional Use Permits." Id. at 22.
Given these facts, Staff believes there is strong evidence that additional transmission between the
Magic Valley and Treasure Valley is necessary.
PAC's Need for Segment E-8
Staff believes that PAC has a long-term strategic interest in the entire GWW transmission
line and therefore should maintain a small ownership stake in Segment E-8. Staff s belief is based
on the following statement from PAC:
By participating in Segment E-8 at a one percent ownership level, [PAC] maintains
joint ownership status in the larger Energy Gateway West suite of projects,
facilitating further participation in additional segments if and when those segments
are determined to be necessary and beneficial for [PAC] customers.
PAC Response to Staff Production Request No. 28.
Staff believes PAC has demonstrated its ownership commitment by taking the lead on
permitting and easement acquisition. See PAC's Response to Staff Production Request No. 14.
Also, PAC Witness Vail stated that "Segment E-8 is necessary for [PAC] to meet its customers'
short- and long-term energy demand, and will strengthen the overall reliability of the existing
transmission system." Vail Direct at 3.
For each of these reasons, Staff believes that PAC's proposed one percent ownership of
Segment E-8 is commensurate with its need for the project.
STAFF COMMENTS 4 AUGUST 21, 2026

The Least-Cost and Least-Risk Alternative
In addition to justification for need, Staff believes that the Commission's decision to issue
a CPCN needs to include a determination of whether the project is the LC-LR alternative among
the available feasible alternatives. After a project has been completed and IPC seeks recovery,
Staff believes it is extremely difficult to determine whether the lowest cost alternative was selected.
Furthermore, if the project is later determined not to have been the LC-LR alternative,determining
an adjustment to the amount of recovery is difficult and creates unnecessary financial risk to IPC.
Thus, Staff believes that the proper time to determine the prudence of the decision regarding which
resource alternative is the LC-LR option is prior to the start of construction. Staff discusses its
analysis of the cost-effectiveness and risk of the project separately below.
Cost Effectiveness of Segment E-8
Staff believes that the cost-effectiveness of Segment E-8 is complicated to assess because
of three related issues:
1. Competing alternatives are limited;
2. Segment E-8 is oversized for the current need; and
3. Segment E-8 provides additional benefits that are difficult to quantify.
Due to these issues, Staff believes that the least-cost determination for Segment E-8 hinges
on the presence of yet-undeclared new system load, presumably one or more NLL customers. If
near-term NLL is likely, Staff encourages IPC to provide transparency of NLL details in its Reply
Comments to remove this uncertainty. Also, Staff recommends that the Commission direct IPC
to ensure all costs associated with Segment E-8 are fully captured and distinctly tagged in its
records for future allocation according to NLL allocation methods being determined in Case No.
IPC-E-26-07.
Limited Alternatives. Staff believes the cost-effectiveness of Segment E-8 is difficult to
assess because alternatives to the project are limited. Normally, the IRP provides a means of
comparing the cost-effectiveness of a resource by calculating the 20-year net present value
("NPV") of portfolios with and without the resource. However, IPC's decision to make Segment
E-8 a baseline assumption in the 2025 IRP meant that the cost of Segment E-8 was not included
in any portfolio NPV because "it was not a differentiating element between portfolios." IPC
STAFF COMMENTS 5 AUGUST 21, 2026

Response to Staff Production Request No. 25. The 2023 IRP,therefore, is the most recent analysis
that provides GWW differentiation, and its analysis showed that the inclusion of Segment E-8 in
a resource portfolio is more cost-effective than a portfolio without it. Ellsworth Direct at 15-16.
Ellsworth proposed two hypothetical alternatives to Segment E-8 to evaluate cost-
effectiveness. The first alternative was to provide equivalent transmission capacity between
Midpoint and Mayfield via multiple 230-kV lines instead of Segment E-8. Id. at 29. Staff agrees
with the six reasons given by Ellsworth that the 230-kV lines would be costlier and riskier. Id.
However, this alternative assumed that approximately four 230-kV lines would be needed to
replicate the full capacity of Segment E-8. Id. Staff believes that this may not be an appropriate
assumption and discusses it in the next subsection.
The second alternative was to upgrade the Hemingway substation and build additional 230-
kV lines from Hemingway into the Treasure Valley. Id. at 30. Ellsworth dismissed this option
because the routing and permitting of multiple 230-kV lines in the heavily populated Treasure
Valley would be risky and time-consuming. Id. Staff agrees with this reasoning given the historic
difficulties of siting transmission projects in rural areas, let alone in urban areas.
Sized for Additional Future Load. Staff believes the analysis of the cost-effectiveness
of Segment E-8 is further complicated by the likelihood that Segment E-8 is oversized for the
assumed load—as defined by the 2025 IRP—and is sized instead for future undeclared load. Staff
draws its conclusion from an analysis of Figure Nos. 2 and 3 in Ellsworth's testimony. Id. at 24-
25. For convenience, these are replicated below.
Figure 2 . Projected Midpoint West ATC.
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Figure No. 2 depicts the available transmission capacity("ATC")along the Midpoint West
path over time. Id. at 24. According to Ellsworth:
STAFF COMMENTS 6 AUGUST 21, 2026

The red dots indicate hours that transfers across Midpoint West exceed the Total
Transfer Capability("TTC") of the path and may cause facility overloads, whereas
the blue dots indicate hours the projected transfers are below the Midpoint West
TTC and are not expected to cause overloads.
Id. Therefore, according to Figure No. 2, transmission overloads (red dots) are forecast to
first occur in 2028 and increase in frequency and magnitude every year thereafter.
Figure 3. Projected Midpoint hest ATC with Segment E-S.
Figure No. 3 depicts the ATC along the Midpoint West path with Segment E-8. Id. at 25.
Staff interprets Figure No. 3 to show that when the final phase of Segment E-8 is brought online
in 2030, the ATC deficit (red dots) is changed to an ATC surplus. By visual inspection of Figure
No. 3, Staff estimates this surplus to be approximately 1,300 MW, which is more than half of
Segment E-8's 2,000 MW capacity. Because of the magnitude of the surplus, Staff believes that
Segment E-8 is oversized for the 2025 IRP load forecast.
When asked for an explanation, IPC explained that "[fJuture load and corresponding
resource additions will utilize the remaining available capacity across the transmission path." IPC
Response to Staff Production Request No. 2. Staff notes that routine growth from existing
customer classes has already been accounted for because the 2025 IRP load forecast included an
average 2.3 percent annual growth. 2025 IRP at 87. Therefore, Staff concludes that the significant
oversizing of Segment E-8 can only be justified by undeclared new load from one or more NLL
customers not included in IPC's forecast.
Assuming Segment E-8 is oversized, Staff identified two important observations. First, if
Segment E-8 has been oversized without justification, it would be erroneous to similarly oversize
any alternative for cost comparison purposes. In other words, if the full 2,000 MW capability of
Segment E-8 was not justified, then only one— or possibly two—230-kV lines should have been
assumed as the alternative instead of multiple 230-kV lines. In the case of only one new 230-kV
line, Staff believes it would be the least-cost solution.
STAFF COMMENTS 7 AUGUST 21, 2026

Staff s second observation is that if undeclared new load is known and imminent, it would
be more cost-effective to right-size the transmission line for the fully forecasted load. Based on
IPC's Response to Staff Production Request No. 2, Staff believes IPC is appropriately sizing
Segment E-8 for one or more undeclared NLL customers. However, this also means that a
substantial portion of Segment E-8 is attributable to these NLL customers and must be allocated
accordingly. Staff believes more clarification is needed from IPC to address Staffs observations
of Segment E-8.
Additional Benefits. The final complicating factor regarding Segment E-8's cost-
effectiveness is the many system benefits it will provide that are not easily financially quantifiable.
Collectively, IPC identified five types of benefits that are significant but difficult to quantify.
Ellsworth described four types of benefits, including increased transmission import
capability (from the east, the northwest, and the southwest), the ability to interconnect new
generation resources east of the Treasure Valley, additional operational flexibility, and a reduced
risk of automatic generation curtailment. Ellsworth Direct. at 19. Staff agrees that all of these are
valuable benefits.
Wheeling revenue is a fifth benefit identified through discovery. IPC Response to Staff
Production Request No. 3. IPC described four west-to-east transmission service agreements
("TSA")that would be activated once Segment E-8 is online,as well as the potential for substantial
east-to-west TSAs. Id. Staff believes that wheeling revenue has the potential to significantly offset
the overall cost of Segment E-8.
Project Risks of Segment E-8
Staff analyzed the details of the project, including its scope, schedule, and cost. Staff has
concerns about the risks of schedule delays and cost overruns, as discussed below.
Risk of Delay. Based on experience with similar transmission projects such as Boardman-
to-Hemingway(`B2H"), Staff is concerned that the Companies may face permitting and easement
STAFF COMMENTS 8 AUGUST 21, 2026

delays,1,2 ultimately delaying the construction of the proposed transmission line. The Companies
have planned for a three-month buffer between permitting and construction. IPC Response to Staff
Production Request No. 17 - Attachment. However, Staff believes that the buffer may not be
adequate to accommodate potential permitting delays, as discussed below.
Under the Project Development Agreement,both Companies are required to jointly support
the regulatory processes associated with obtaining necessary permits for Segment E-8 and other
project development work. Vail Direct at 8. To date, PAC has received a Final Supplemental
Environmental Impact Statement Record of Decision in January 2017, a Right-of-Way grant from
the Bureau of Land Management (`BLM") in July 2017, and an Environmental Assessment
Finding of No New Significant Impact in March 2018 as part of the National Environmental Policy
Act process. PAC's Response to Staff Production Request No. 15.
However, additional permits are still required. PAC provided a table of all Federal, State,
and local permits that are still required, and asserted that most of them will be obtained in 2027.
PAC Response to Staff Production Request No. 14 -Attachment. Among the critical permits still
needed are the BLM Plan of Development for the Morley Nelson Snake River Birds of Prey
National Conservation Area ("NCA"), conditional use permits, and special use permits. Vail
Direct at 14; PAC Response to Staff Production Request No. 13. Each of these must be obtained
before the Companies may begin construction. Id. Given Staff's understanding of the frequent
public resistance to transmission lines and the environmental sensitivity of the NCA, Staff believes
that delays for construction of the proposed transmission line are likely.
In addition to the permits, the Companies must also obtain real estate easements for siting
and access. PAC stated that the Companies must obtain easements from 89 different landowners.
PAC Response to Staff Production Request No. 16. To date, the Companies have acquired five
easements, leaving 84 easements outstanding. Id.
In summary, Staff believes the potential for delay is significant. A single permit delay
could keep the project from starting, and a single easement delay could prevent the transmission
line from being completed.
1 NewsData, Construction Begins on Boardman to Hemingway Transmission Line,
https://www.newsdata.com/clearingun/clearingtiit un/construction-begins-on-boardman-to-heminiway-
transmission-line/article c418dc8a-4707-45f8-adb8-847b59fe2696.htm1(last visited July 30,2026).
2 NewsData,Mining Company Sues Idaho Power Over B2H Transmission Project,
hLtps://www.newsdata.com/clearing Lip/courts_and commissions/mining-company-sues-idaho-power-over-b2h-
transmission-project/article_3bf91491-lafc-4eb8-b5e5-afdcba4cf396.htm1(last visited July 30,2026).
STAFF COMMENTS 9 AUGUST 21, 2026

Given this delay risk and the necessity of Segment E-8 to serve additional NLL, Staff
suggests that IPC delay signing additional NLL Energy Service Agreements until the situation
stabilizes. Otherwise, if IPC commits to serve NLL in the near-term, but Segment E-8 is delayed,
Staff believes that IPC will have very limited fallback options. This recommendation is
conceptually similar to what the North American Electric Reliability Corporation ("NERC")
suggested in its recent Large Loads Working Group Reliability Guideline:3
Demand may outstrip generation supply as large loads are added faster than the
addition of generation resources. Many large loads are expected to require firm
service,limiting their ability to be considered flexible or providing limited demand-
response capabilities. This directly impacts [bulk power system] reliability through
the reduction of [Balancing Authority] Operating Reserves. To address this,
[Resource Planners] should model scenarios in their evaluation of resource
adequacy, such as delayed generation additions, before incorporating large load
additions.
Id. at 12 (emphasis added).
Accordingly, Staff recommends that the Commission direct IPC to submit a detailed plan
explaining how it will resolve system capacity deficits caused by additional NLL whenever IPC
proposes to serve additional NLL.
Risk of Cost Overrun. Staff believes that the Segment E-8 project cost is comparable to
that of the B2H transmission line,4 and like 132H, it is very expensive with a high probability of
cost overruns. Furthermore,because this is a self-build project, Staff believes there is an absence
of overall cost constraint that is usually present with a third-party construction contract. Therefore,
Staff believes that the only external constraint to project cost overruns will be Staffs prudence
review when the Companies file for cost recovery of the Segment E-8 project. To facilitate an
effective prudence review, Staff recommends the Commission order IPC to provide more detailed
budget information through compliance filings, as discussed below.
In the Application,IPC provided an overall project budget as of March 13,2026,consisting
of a single amount for each of the following cost categories: "Permitting," "Pre-Construction,"
"Construction of Segment-8,""Mayfield Station and Line Terminal,""Hemingway and Midpoint
s NERC"Risk Mitigation for Emerging Large Loads"Large Loads Working Group Reliability Guideline May 2026
https://www.nerc.com/globalassets/our-work/guidelines/reliability/RG_Risk-Mitigation-For-Emerging-Large-
Loads.pdf(last visited July 16,2026).
a The estimate for Segment E-8 can be found in IPC Response to Staff Production Request No. 19—Confidential
Attachment. The B2H cost can be found in Case No.IPC-E-23-01,Confidential Exhibit No. 11.
STAFF COMMENTS 10 AUGUST 21, 2026

Line Terminals, Communication Regeneration Station," "Overhead," "AFUDC," and
"Contingency". Barretto Direct, Confidential Exhibit No. 5. In Staff Production Request No. 19,
Staff referenced Confidential Exhibit No. 5 and requested that the Companies provide an itemized
breakdown of the costs included in each cost category. In response, IPC provided the same
spreadsheet included in the Application as Confidential Exhibit No. 5.
Staff requested all monthly forecasts used to track project budgets and schedules. In
response, IPC provided monthly forecasts from March 2024 through February 2026. IPC
Response to Staff Production Request No. 21. The forecasts include actual costs through the
previous month and forecasts through the following two years. Id. The most recent forecast,
dated February 2026,provides projections through 2028 but does not include projections for 2029
or 2030. Id.
Due to the insufficient response to Staff Production Request No. 19 and the lack of
forecasted costs for 2029 and 2030 provided in response to Staff Production Request No. 21, Staff
was unable to review a detailed project budget to establish a baseline for comparison when the
Companies seek recovery of the project in future proceedings. Staff recommends the Commission
require the Companies, through compliance filings, to submit a project budget broken down by
cost category for each phase of the project within 60 days of its Final Order. Staff believes that
the Companies will seek recovery for each phase after each phase has been placed in service.
Therefore, Staff believes it is necessary to have detailed budgets per project phase to conduct an
adequate prudence review when the Companies seek cost recovery.
Staff further recommends the Commission require the Companies to submit, through
compliance filings, monthly budget forecasts as it becomes available, similar to those provided
in IPC Response to Staff Production Request No. 21. This information would allow Staff to
compare initial and updated budgets to actual project costs and identify budget changes and cost
overruns. It would also allow Staff to more efficiently investigate the reasons for those changes
when evaluating the prudence of project costs in future proceedings.
Financing and Ratemaking Treatment
IPC intends to finance the project through a combination of available cash and operating
cash flow, available credit facilities and borrowing and debt issuances, and future equity infusions.
Application at 18. PAC intends to finance the project through a combination of net cash flow,
STAFF COMMENTS I I AUGUST 21, 2026

public and private debt offerings, issuance of commercial paper,use of unsecured revolving credit
facilities, capital contributions, and other sources. Id. Staff believes the financing methods
proposed by the Companies are reasonable sources to finance the project.
The Companies are not requesting binding ratemaking treatment for the project in this case
and will make separate filings in future proceedings to address project cost recovery. Application
at 17. Staff agrees with the Companies that ratemaking treatment should be determined in future
proceedings when the project is used and useful. At that time, actual costs can be reviewed, and
the Commission can determine the prudence and appropriate ratemaking treatment of costs.
STAFF RECOMMENDATION
Staff recommends that the Commission:
1. Approve CPCNs for Segment E-8 for both IPC and PAC.
2. Direct IPC to ensure all costs associated with Segment E-8 are fully captured and
distinctly tagged in its records for future allocation according to the NLL allocation
method.
3. Direct IPC to submit a detailed plan explaining how it will resolve system capacity
deficits caused by additional NLL whenever IPC proposes to enroll additional NLL.
4. Direct the Companies, through compliance filings, to submit:
a. The current budget for each phase of the project, broken down by cost category,
within 60 days of the Final Order; and
b. Monthly budget forecasts within 30 days after each forecast is finalized, similar
to those provided in IPC Response to Staff Production Request No. 21.
Respectfully submitted this 21 st day of August 2026.
Kelsea E. Ross
Deputy Attorney General
Technical Staff. Matt Suess, Kimberly Loskot, Shubhra Deb Paul, James Chandler, Vicki Stephens
I:\Utility\UMISC\COMMENTS\IPC-E-26-09\PAC-E-26-06 Comments.docx
STAFF COMMENTS 12 AUGUST 21, 2026

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21'DAY OF AUGUST 2026,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NOS. IPC-E-26-09 AND PAC-E-26-06, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
LISA C. LANCE TIM TATUM
CORPORATE COUNSEL CONNIE ASCHENBRENNER
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707 BOISE ID 83707
E-MAIL: E-MAIL:
llancekidahopower.com ttatum(kidahopower.com
dockets(&idahopower.com caschenbrenner(&,idahopower.com
JOE DALLAS JANA SABA
ASSISTANT GENERAL COUNSEL REGULATORY AFFAIRS MANAGER
PACIFICORP ROCKY MOUNTAIN POWER
825 NE MULTNOMAH STREET, SUITE 1407 WEST NORTH TEMPLE, SUITE 330
2000 SALT LAKE CITY, UTAH 84116
PORTLAND, OREGON 97232 E-MAIL:
E-MAIL: jana.saba(d),pacificorp.com
joseph.dallaskpacificorp.com
Intervenor:
Idaho Irrigation Pumpers Association,Inc.
(IIPA)
ERIC L. OLSEN LANCE KAUFMAN, PH.D.
ECHO HAWK& OLSEN, PLLC DEBORAH GLOSSER, PH.D.
P.O. BOX 6119 2623 NW BLUEBELL PLACE
505 PERSHING AVE, SUITE 100 CORVALLIS, OR 97330
POCATELLO, ID 83205 E-MAIL:
E-MAIL: lance(q,ae_is�_h
elo(d),echohawk.com deborah. log sser(&r gmail.com
tayshakechohawk.com
Intervenor:
Micron
Austin Rueschhoff
Thorvald A. Nelson
Richard A. Arnett
Holland&Hart, LLP
555 171h St., Ste. 3200
Denver, CO 80202
darueschhof[khollandhart.com i
tnelsonAhollandhart.com
raarnettkhollandhart.com PATRICIA JORD ,SECRETARY
acleeAhollandhart.com
tlfriel(a,hollandhart.com
CERTIFICATE OF SERVICE