20260821Comments_1.pdf

RECEIVED
August 21, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-26-09
COMPANY AND PACIFICORP )
D/B/A ROCKY MOUNTAIN ) COMMENTS OF THE NW
POWER FOR CERTIFICATES OF ) ENERGY COALITION
PUBLIC CONVENIENCE AND ) AND RENEWABLE
NECESSITY FOR SEGMENT E-8 ) NORTHWEST
OF THE GATEWAY WEST 500-KV )
TRANSMISSION LINE. )
Pursuant to the Notice of Modified Procedure in Idaho Public Utilities Commission
("Commission") Order No. 370696,NW Energy Coalition("NWEC") and Renewable Northwest
("RNW"), herein after the Joint Advocates submit these comments in the above-captioned
matter. The Joint Advocates recommend the Commission approve the utility application.
A Certificate of Public Convenience and Necessity("CPCN") for a transmission line has
differences from a CPCN for generation resources. There is a well-developed marketplace for
independent power developers and a range of resource types that can meet energy needs. There is
no equivalent marketplace for independent transmission development. And there is no equivalent
marketplace for different resource options that provide the service that bulk transmission
provides. Therefore, the competitive procurement policies the Joint Advocates critiqued when
commenting on Idaho Power's gas plants do not apply in the same way for transmission lines.
Further, without an independent developer sector that can finance new projects,utilities finance
transmission development. Without alternative financing tools available, granting a CPCN in this
docket will support the utility keeping borrowing costs reasonable. So, the question is whether
the utilities have consistently identified the transmission resource as an effective resource to
maintain reliable and affordable service for customers and whether they have a reasonable plan
to finance and construct the resource.
IPC-E-26-09 NWEC/RNW Comments
August 21,2026 1

A series of utility Integrated Resource Plans for both Applicants demonstrate that
Gateway West Segment E-8 is a good resource to meet Idaho's growing energy needs and
enhance reliability. Our groups have critiqued the utilities' IRPs in the past about clean energy
assessments. However, regarding transmission,both Idaho Power and PacifiCorp's plans do a
good job of analyzing how transmission expansion can maintain reliable and affordable energy.
Relevant here, Gateway West Segment E-8, can address the growing grid congestion between
Idaho Power's two major load centers in the Magic and Treasure Valleys. This segment is part of
the larger Gateway project that should enable access to the high-capacity factor and low energy
cost wind resources in Wyoming. Utility IRP's show that Wyoming wind is a prudent, cost-
effective resource especially to meet the growing wintertime energy needs attributable to
forecasted new large loads. Adding Segment E-8 helps complete the larger Gateway project to
enable access to these generation resources and broaden the pool of resources available to
customers,thereby lowering overall generation costs.
Adding Segment E-8 appears to decrease overall risk by enabling access to new resources
and enhancing the bulk transmission system. This is distinct from a different case where the Joint
Advocates opposed a utility CPCN for new gas power generation. That case relies upon a third
parry to build a pipeline to fuel the plants with a notoriously volatile commodity. This case to
add transmission capacity is distinct. Segment E-8 will address a current transmission constraint
and enable access to non-fueled resources shown in multiple studies to be cost effective but
unable to move from Wyoming into Idaho. By addressing constraints and opening opportunities,
Segment E-8 appears to reduce risks for customers.
Siting and permitting large scale transmission lines can be a risk. The utilities secured
federal land use permits for Segment E-8 in the 2017-2018 timeframe. Since then, our
IPC-E-26-09 NWEC/RNW Comments
August 21,2026 2

understanding is the utilities have secured most of the additional land use permits. As a project
developed by utilities with a long history serving Idaho and a focus on enhancing local
reliability, this project is distinct from the SWIP-North project where the economic driver and
the local permitting were less certain. The Commission can have strong confidence that
approving this application will enable the utilities to move forward and build the resource
without reliance on third party developers or other utility partners.
Finally, we support the utilities' proposal to account for the project costs for future
recovery. We take no position on the specific costs, much of which is confidential information.
To protect customers and keep the utilities focused on cost control, we recommend the
Commission apply a soft cap to the project costs and require the utilities to justify exceedances in
future prudency cases.
For the reasons stated above, we recommend the Commission approve Idaho Power and
PacifiCorp's Application for a CPCN for Gateway West Segment E-8.
Respectfully submitted,
Is/Benjamin J. Otto, ISB #8292 Is/Mike Goetz
NW Energy Coalition & Regulatory Affairs Director
Renewable NW Renewable Northwest
1407 W Cottonwood Court 421 SW Sixth Ave. #975
Boise, ID 83702 Portland, OR 97204
[phone] [phone]
/sl&le Unruh /s/AaronMenenberg
Director, Montana& Idaho Idaho Policy Manager
Renewable Northwest Renewable Northwest
IPC-E-26-09 NWEC/RNW Comments
August 21,2026 3

CERTIFICATE OF SERVICE
I hereby certify that on this 21 st day of August 2026, I delivered true and correct copies of the
foregoing COMMENTS OF NWEC AND RNW in IPUC Docket No. IPC-E-26-09 to the
following persons according to Rule 61.03 via electronic mail only.
/s/Beniamin J Otto, ISB No 8292
Attorney for NWEC and RNW
Idaho Public Utilities Commission Idaho Power Company
Monica Barros-Sanchez Lisa Lance
Commission Secretary Timothy Tatum
[e-mail] Connie Aschenbrenner
[e-mail]
[e-mail]
Idaho Public Utilities Commission Staff [e-mail]
Kelsea E. Ross [e-mail]
Deputy Attorney General
[e-mail] Joe Dallas, PacifiCorp
[e-mail]
Idaho Irrigation Pumpers Association Jana Saba, PacifiCorp
Eric L. Olsen [e-mail]
Lance Kaufman
[e-mail]
[e-mail]
Micron Technology, Inc
Austin Rueschhoff
Thorvald A. Nelson
Richard A. Arnett
Holland&Hart, LLP
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
IPC-E-26-09 NWEC/RNW Comments
August 21,2026 4