20260821IIPA Written Comments - Redacted.pdf

Eric L. Olsen(ISB#4811)
ECHO HAWK& OLSEN, PLLC RECEIVED
505 Pershing Ave., Ste. 100 AUGUST 21, 2026
IDAHO PUBLIC
P.O. Box 6119
UTILITIES COMMISSION
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: elo(a)echohawk.com
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION CASE NO. IPC-E-26-09
OF IDAHO POWER AND PACIFICORP
D/B/A ROCKY MOUNTAIN POWER FOR CASE NO. PAC-E-26-06
CERTIFICATES OF PUBLIC
CONVENIENCE AND NECESSITY FOR IDAHO IRRIGATION PUMPERS
SEGMENT E-8 OF THE GATEWAY WEST ASSOCIATION,INC.'S WRITTEN
500-KV TRANSMISSION LINE. COMMENTS
The Idaho Irrigation Pumpers Association, Inc. ("IIPA"), by and through counsel, hereby submits
its Written Comments on Idaho Power Company ("Idaho Power") and PacifiCorp's Joint
Application for Certificates of Public Convenience and Necessity for Segment E-8 of the Gateway
West 500-KV Transmission Line ("Gateway West" or"Segment 8"), as follows:
Introduction
IIPA submits these comments to preserve issues related to cost causation, future cost allocation,
and ratemaking treatment associated with the proposed Gateway West transmission investment.
IIPA does not seek in these comments to relitigate regional transmission planning policy or broader
western transmission development objectives. Rather, IIPA's focus is narrower: the purpose is to
ensure that the record clearly reflects the extent to which Idaho retail customers may bear costs
associated with facilities that provide regional, multi-system, or evolving benefits that extend
beyond Idaho-specific retail service obligations.
The record establishes that Idaho Power will own and control 99% of Segment 8's capacity, with
PacifiCorp retaining 1%. Notably, PacifiCorp held a contractual option, exercisable prior to the
Segment 8 CPCN filing, to increase its ownership and capacity share in Segment 8 to as much as
50%, and did not exercise it. With the Segment 8 CPCN now filed and PacifiCorp's interest
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page I
CASE NO.IPC-E-26-09 and PAC-E-26-06

remaining at one percent, the Segment 8 allocation appears settled at 99:1 for purposes of this
proceeding.'
At the same time, the agreements continue to characterize the broader Gateway West project in
terms of"capacity share," "incremental system capacity," and ongoing ownership flexibility, and
preserve live option rights with respect to Segments 9 and 10.2 The beneficiary structure of the
Gateway West program therefore remains subject to future modification even though the Segment
8 split is now fixed.' In EPA's view, both circumstances, an Idaho funded Segment 8 whose
principal co-owner declined to participate, and a broader program whose cost and benefit
allocation continues to evolve weigh in favor of preserving careful scrutiny regarding future cost
allocation and ratemaking.
These provisions are important because they indicate that the final beneficiary structure of the
project remains dynamic. In IIPXs view, that continuing evolution weighs in favor of preserving
careful scrutiny regarding future cost allocation and ratemaking treatment.
I. Segment 8 is now overwhelmingly an Idaho-funded facility
Beyond the 99%ownership interest reflected in the First Amendment, the most telling indication
that Segment 8 is an Idaho specific facility is PacifiCorp's own decision not to participate in it.
Under the Fourth Amendment, PacifiCorp held an option to acquire up to a 50% ownership and
capacity share in Segment 8, exercisable before Idaho Power filed for a CPCN a PacifiCorp, the
regional co-owner best positioned to assess whether Segment 8 serves multi-system or regional
needs, declined that option and remains at 1%. In discovery, Idaho Power confirmed that its 99%
share equates to- of capacity while PacifiCorp's one percent equates to NNEW The
party with the most information about the project's regional value, given the contractual right to
take half, took essentially none.
The Idaho funded character of the project extends to associated facilities. Idaho Power has
confirmed that the Mayfield substation, into which Segment 8 terminates, will be 100% owned
and funded by Idaho Power, at a total estimated cost of , of_
costs has been included within the Segment 8 cost estimate. No
portion of the Mayfield substation is allocated to PacifiCorp.
The record is clear that Idaho Power customers are expected to bear nearly all costs associated
with Segment 8.
t First Amendment,p.1,Recitals C-E;p.2 section 3.1;p.4 Exhibit B.
2 Second Amendment,p.6-7 sections 3.1(a}(e).
'Fourth Amendment,p.3-5 sections 3.1(c)_
4 Fourth Amendment.
5 Idaho Power Resp.to Staff 1st Prod,Req.No 7.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 2
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The First Amendment states that Idaho Power "has an interest in developing Segment 8 and is
willing to fund the remaining Project Costs related to that segment."6 The same amendment revised
the ownership structure so that Idaho Power would own 99% of Segment 8, while PacifiCorp
would retain only 1% interest.7
The Second Amendment further expanded Idaho Power's role by requiring the Project Manager to
"regularly consult with and obtain the written approval of Idaho Power" regarding all material
Segment 8 activities, including:
1. Bid materials;
2. Contract terms;
3. Engineering;
4. Geotechnical investigations; and
5. Acquisition of property interests$.
The agreements also moved substantial additional work into the "Segment 8 Preconstruction
Project."9 The Third Amendment then expanded that categorization further by providing that"all
remaining work effort associated with the Federal Permitting Project and State Permitting Project
with respect to Segment 8"would thereafter be considered part of the Segment 8 Preconstruction
Project effective January 1, 2024.10
Collectively, these amendments demonstrate that Idaho retail customers are positioned to bear the
overwhelming majority of Segment 8 development and preconstruction costs.
II. Ownership and capacity across the Gateway West program remain subject to
change, even as the Segment 8 split is fixed
While the Segment 8 ownership and capacity allocation now appears settled, the same is not true
of the broader Gateway West program. The Second Amendment expressly contemplates future
negotiated changes to Segment Ownership Interests and Capacity Shares for Segments 8, 9, and
10.11 The Fourth Amendment establishes a set of interlocking option rights, including PacifiCorp's
option to increase its share in Segment 9 and Idaho Power's contingent options in Segments 9 and
10 which remain exercisable in connection with the future CPCN filings for those segments, with
each exercise priced by reference to that segment's accrued Project Costs and AFUDC.12
These provisions confirm that the allocation of ownership,capacity,and cost across Gateway West
will continue to evolve as the remaining segments advance.That ongoing evolution,taken together
with the project's repeated characterization in regional and incremental system capacity terms,
'First Amendment,p.1,Recital C.
'First Amendment,p.1,Recital D;p.2 section 3.1;p.4 Exhibit B.
'Second Amendment,p.9 section 4.2(e).
v See Second Amendment,p. 1-2,definitions of"Segment 8 Preconstruction Project"and"Project Costs"
°Third Amendment,p.2 section 3(b).
"Second Amendment.
12 Fourth Amendment.
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 3
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counsels against treating any cost causation or allocation determination in this Segment 8
proceeding as fixed for the program as a whole.
III. The Commission should preserve cost causation issues for future ratemaking
proceedings
IIPA recognizes that regional transmission projects may provide broad system value. However,
regional value does not automatically establish that all associated costs should be assigned to Idaho
retail customers without careful examination of Idaho specific benefits.
This quantification gap is confirmed by the Company's own admissions in this docket and in the
related 2025 Integrated Resource Plan proceeding.13 In this proceeding, Idaho Power has
confirmed that it calculated no levelized cost for Segment 8 under the 99% ownership structure
and instead modeled the segment "as a baseline assumption." In the 2025 IRP, Idaho Power
assumed Segment 8 in every case and every scenario,running no with and without comparison for
the segment, in contrast to the "Without SWIP" case it did evaluate for SWIP-N, and has
acknowledged that it has not performed and does not possess comparative analyses measuring the
major transmission projects against local generation, demand response, or storage alternatives.14
The Company has further confirmed that its IRP load forecast is modeled at a single"Idaho Power"
node, without geographic granularity. The result is that no analysis in either record quantifies the
extent to which Segment 8's costs correspond to Idaho retail reliability obligations as distinct from
broader regional or multi-system transfer capability.
Here, the record demonstrates:
1. that Idaho customers are expected to fund nearly all Segment 8 costs;
2. that project ownership and capacity rights remain subject to future modification; and
3. that the agreements repeatedly emphasize regional transmission capability and future
transfer flexibility.
Under these circumstances, IIPA respectfully submits that the Commission should preserve all
issues related to:
1. future cost allocation;
2. prudence review;
3. affiliate or multi-system benefits;
4. transmission utilization;
5. capacity value allocation; and
6. ratemaking treatment in future proceedings.
13 Case No.IPC-E-25-23.
14 Company Response to Staff 1 st Prod.Req.No 4.
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At minimum, the current record does not yet fully quantify the extent to which Segment 8 costs
are associated with Idaho retail reliability obligations versus broader regional transmission
objectives or future multi-system transfer capability.
Conclusion
For the foregoing reasons, IIPA respectfully requests that the Commission preserve issues relating
to cost causation, allocation of regional transmission benefits, and future ratemaking treatment
associated with Gateway West Segment 8 and related facilities.
DATED this 21 st day of August, 2026.
EC WK& OLSEN
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 5
CASE NO.IPC-E-26-09 and PAC-E-26-06

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 21" day of August, 2026, I served a true, correct and
complete copy of the foregoing to each of the following, via method indicated below:
Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail
Kelsea Ross, Deputy Attorney General ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
P.O. Box 83720 ❑ Telecopy(Fax)
Boise, ID 83720-0074 ® Electronic Mail (Email)
[e-mail]
kelsea.ross(c�puc.Idaho.gov
Lisa C. Lance ❑ U.S. Mail
Tim 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
llancegidahopower.com
dockets kidahopower.com
ttatum(c iidahopower.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(kae isg insi hg t.com ® Electronic Mail (Email)
deborah. log sser(a�gmail.com
Jana Saba ❑ U.S. Mail
Joe Dallas ❑ Hand Delivered
Rocky Mountain Power ❑ Overnight Mail
1407 West North Temple, Suite 330 ❑ Telecopy(Fax)
Salt Lake City, Utah 84116 ® Electronic Mail (Email)
joseph.dallasgpacificorp.com
j ana.saba(d),p acificop2.com
Austin Rueschhoff ❑ U.S. Mail
Thorvald A. Nelson ❑ Hand Delivered
Richard A. Arnett ❑ Overnight Mail
Holland & Hart LLP ❑ Telecopy(Fax)
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 6
CASE NO.IPC-E-26-09 and PAC-E-26-06

555 17th Street, Suite 3200 ® Electronic Mail (Email)
Denver, CO 80202
darueschhoff ahollandhart.com
tnelson(i�hollandhart.com
raarnettghollandhart.com
acleekhollandhart.com
tlfrielghollandhart.com
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.WRITTEN COMMENTS—Page 7
CASE NO.IPC-E-26-09 and PAC-E-26-06