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Home My WebLink About20260828Petition for Intervenor Funding.pdf RECEIVED August 28, 2026 IDAHO PUBLIC Eric L. Olsen(ISB#4811) UTILITIES COMMISSION ECHO HAWK& OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 Telephone: (208) 478-1624 Facsimile: (208)478-1670 Email: elo(a)echohawk.com Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER CASE NO. IPC-E-26-04 COMPANY'S APPLICATION FOR CERTIFICATES OF PUBLIC IDAHO IRRIGATION PUMPERS CONVENIENCE AND NECESSITY FOR ASSOCIATION,INC.'S PETITION THE SOUTH HILLS AND PEREGRINE FOR INTERVENOR FUNDING POWER PLANTS AND FOR AN ASSOCIATED ACCOUNTING ORDER. COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("IIPA"), by and through counsel of record, Echo Hawk & Olsen, PLLC, hereby respectfully petitions the Idaho Public Utilities Commission("Commission") for intervenor funding,pursuant to Idaho Code § 61-617A and IDAPA §§ 31.01.01.161 through .165, in this case, as follows: A) Itemized List of Expenses A summary of the expenses that the IIPA requests to recover broken down into legal fees, witness fees and other costs and expenses is set forth in Exhibit "A" attached hereto and incorporated by reference. Itemized statements from IIPA's Counsel, Eric L. Olsen of Echo Hawk & Olsen and its Expert witness Deborah Glosser, PhD. are also included as Attachments 1 and 2 to Exhibit"A" in support of said summary and are incorporated by reference. B) Statement of Proposed Findings IIPA recommended that, in considering the Application, the Commission recognize that the proposed facilities reflect not only an identified system capacity need but also procurement IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page I CASE NO.IPC-E-26-04 decisions made under significant timing constraints. IIPA urged the Commission to maintain a record sufficient to distinguish between costs attributable to the need for additional capacity and costs attributable to procurement timing, contractual optionality, execution risk, and other project- development considerations. IIPA further recommended that approval of the requested Certificates of Public Convenience and Necessity not be construed as resolving future questions concerning cost allocation, cost-of-service treatment, or customer responsibility for project-related costs. IIPA emphasized that future ratemaking proceedings may require examination of the causes and characteristics of particular project costs and that an adequate evidentiary record should therefore be preserved. In addition, IIPA sought to ensure that the record clearly reflects the magnitude and structure of project costs, the extent to which those costs are driven by system need versus procurement-related considerations, and the extent to which project risks have been retained by or transferred among stakeholders. These distinctions are relevant to future evaluations of cost causation and customer responsibility and differed materially from Commission Staff s comments. C) Statement Showing Costs The IIPA is requesting $6,063.20 in intervenor funding for the expenses and costs described in Exhibit A. The expenses listed in this Petition are reasonable,necessary, and directly related to meaningful participation in this proceeding. The costs reflect expenditures required to review the Company's Application, testimony, discovery responses, and related filings; prepare and submit data requests; analyze project cost information, contractual provisions, and related modeling; consult with expert witnesses; and prepare and submit written comments. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 2 CASE NO.IPC-E-26-04 The issues presented in this case involved substantial questions concerning project costs, procurement timing, risk allocation, and the potential ratemaking implications of the proposed facilities. The expenses incurred were proportionate to the scope and complexity of those issues and were necessary to permit effective participation by IIPA. IIPA exercised prudent judgment throughout the proceeding and sought to minimize costs while ensuring adequate representation of its members' interests. D) Explanation of Cost Statement The listed expenses in Exhibit A constitute a financial hardship for the IIPA. The IIPA is an Idaho nonprofit corporation qualified under I.R.C. § 501(c)(5) representing farm interests in electric utility rate matters affecting farmers in southern and central Idaho. The IIPA relies solely upon dues and contributions voluntarily paid by members, together with intervenor funding, to support its activities. Each year mailings and electronic solicitations are sent to approximately 7,000 Idaho Irrigators(approximately one-third in the PacifiCorp's service area and the remainder in IPC's service area), soliciting annual dues. IIPA recommends members make voluntary contributions based on acres irrigated or horsepower per pump. Member contributions have been falling which is believed to be attributable to increased operating costs and declining commodity prices. From member contributions the IIPA must pay all expenses, which generally include mailing expenses, meeting expenses, post office box, in addition to the expenses relating to participation in matters before the Commission. The Executive Director, Amy McKoon, is the only part-time paid contractor, receiving a retainer plus expenses for office space, office equipment, and secretarial services. Other IIPA officers and directors are elected annually and serve without compensation. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 3 CASE NO.IPC-E-26-04 It has been and continues to be a financial hardship for the IIPA to fully participate in important cases such as this one due to the time and expense that must be incurred for meaningful participation. Because of IIPA's financial constraints, participation in this case was focused and prudent. IIPA concentrated its efforts on reviewing the Company's Application and supporting testimony, conducting targeted discovery, analyzing project costs and related ratemaking implications, consulting with its expert witness, and preparing written comments on matters affecting irrigation customers. E) Statement of Difference IIPA's participation differed materially from that of Commission Staff. Staff focused primarily on issues relating to approval of the proposed facilities, treatment of AFUDC, potential cost caps, and whether some or all project costs should ultimately be borne by new large load customers. IIPA did not advocate a specific allocation methodology or cost-recovery outcome in this proceeding. Instead, IIPA focused on ensuring that the evidentiary record adequately distinguishes between costs associated with the Company's identified capacity need and costs associated with procurement timing, contractual optionality, execution risk, and related project-development considerations. IIPA further emphasized that approval of the requested CPCNs should not predetermine future questions concerning cost allocation,cost-of-service treatment,rate design, or customer responsibility for project-related costs. Accordingly, while Staff concentrated on immediate approval and cost-recovery issues, IIPA concentrated on preserving a factual record sufficient to allow future proceedings to evaluate cost causation and customer responsibility on a fully developed evidentiary basis. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 4 CASE NO.IPC-E-26-04 F) Statement of Recommendation IIPA's participation addressed issues of concern to the general body of utility users and consumers by helping ensure that the record adequately reflects the causes, characteristics, and ratemaking implications of the costs associated with the proposed facilities. The distinctions identified by IIPA regarding system need, procurement timing, contractual optionality, execution risk, and future cost recovery may affect the rates ultimately paid by Idaho Power customers. By advocating for a clear evidentiary record capable of supporting future cost-allocation and cost-of-service determinations, IIPA's participation promotes informed regulatory decision- making and assists the Commission in ensuring that future cost-recovery determinations are based upon sound cost-causation principles. These issues affect not only irrigation customers but the general body of Idaho Power customers. G) Statement Identifying Customer Class The IIPA represents the Irrigation class of customers under Schedule 24 on IPC's system. Based on the foregoing, it is respectfully submitted that the IIPA is a qualifying intervenor and should be entitled to an award of costs of intervention in the maximum amount allowable pursuant to Idaho Code § 61-617A and IDAPA §§ 31.01.01.161 through .165. DATED this 28th day of August, 2026. ECHO HAWK& OLSEN ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 5 CASE NO.IPC-E-26-04 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 28th 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 Idaho Public Utilities Commission ❑ Hand Delivered P.O. Box 83720 ❑ Overnight Mail Boise, ID 83720-0074 ❑ Telecopy(Fax) secretary,puc.idaho.gov ® Electronic Mail (Email) Kelsea Ross, Deputy Attorney General ❑ U.S. Mail Idaho Public Utilities Commission ❑ Hand Delivered 11331 W. Chinden Blvd., Bldg. No. 8, ❑ Overnight Mail Suite 201-A (83714) ❑ Telecopy(Fax) P.O. Box 83720 ® Electronic Mail (Email) Boise, ID 83720-0074 kelsea.ross&]2uc.Idaho.gov Donovan E. Walker ❑ U.S. Mail Timothy 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 dwalker&idahopower.com dockets(&idahopower.com ttatumgidahopower.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(a),ae isg insi hg t.com ® Electronic Mail (Email) deborah. log sserggmail.com IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 6 CASE NO.IPC-E-26-04 Austin Rueschhoff ❑ U.S. Mail Thorvald A. Nelson ❑ Hand Delivered Richard A. Arnett ❑ Overnight Mail Holland & Hart LLP ❑ Telecopy(Fax) 555 17th Street, Suite 3200 ® Electronic Mail (Email) Denver, CO 80202 darueschhoff,hollandhart.com tnelson(ir hollandhart.com raarnett(cr�,hollandhart.com acleeghollandhart.com tlfrielghollandhart.com Benjamin J. Otto ❑ U.S. Mail Lauren McCloy ❑ Hand Delivered Derek Goldman ❑ Overnight Mail Northwest Energy Coalition ❑ Telecopy(Fax) 1407 W. Cottonwood Ct. ® Electronic Mail (Email) Boise, ID 83702 bengnwenergy.org lauren(a-nwenergy.org derekgnwenerg�org Benjamin J. Otto ❑ U.S. Mail Mike Goetz ❑ Hand Delivered Aaron Menenburg ❑ Overnight Mail Kyle Unruh ❑ Telecopy(Fax) Renewable Northwest ® Electronic Mail (Email) 1407 W. Cottonwood Ct. Boise, ID 83702 ben(apnwenergy.org mike(arenewablenw.org aarongrenewablenw.org kyle(ab,renewablenw.org Z2�p�— ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 7 CASE NO.IPC-E-26-04 EXHIBIT A Expert Witnesses: Deborah Glosser, Expenses: 1. Witness Fees: 17.8 Hours @ $275 = $ 4,895.00 Sub Total: $4,895.00 Legal Expenses: 1. Paralegal Fees: 4.2 Hours @ $155 = $ 733.00 2. Legal Fees Eric L. Olsen: 1.7 Hours @ $250 = $ 425.00 3. Soft Costs (Copies/Legal Research) $ 10.20 Sub Total: $ 1,168.20 Grand Total: $6,063.20 IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 8 CASE NO.IPC-E-26-04 ATTACHMENT 1 Date Fee Type Cost Amount Total Description 4/15/2026 Legal $275.00 3.2 $880.00 Reading of petition and company testimony,drafting of initial data requests 4/16/2026 Legal $275.00 0.5 $137.50 Meeting with to discuss case specifics and challenges Review of responses to IPC DRs,recreation of company models from data,development of additional cost modeling, 4/17/2026 Legal $275.00 4.2 $1,155.00 review of contract provisions from discovery 4/20/2026 Legal $275.00 1.4 $385.00 Outline of comments 4/21/2026 Legal $275.00 1 $275.00 Development of comments intro 4/23/2026 Legal $275.00 4.5 $1,237.50 Review of other parties discovery,drafting of comments sections on optionality risk and rate impacts Drafting of sensitivity analysis modeling comments section,cost escalation,AFL contribution and conclusions.Emails with 4/24/2026 Legal $275.00 3 $825.00 Lance and Eric. 17.8 $4,895.00 ATTACHMENT2 Date Fee Type Cost Amount Total Description 3/20/2026 Paralegal $175.00 0.4 $70.00 Draft and file petition to intervene in the case 3/27/2026 Paralegal $175.00 0.7 $122.50 Draft data requests to IPC and file with the IPUC 4/17/2026 Paralegal $175.00 0.4 $70.00 Upload protective agreements for signature in case;email ELO and Debb's to Christy and Keri 5/26/2026 Paralegal $175.00 0.9 $157.50 Prepare response to NWEC First PR and file with the IPUC and update file and folder Email/call to Debb on comments deadline;Prepare written comments pleadingfor filingtoday with the Commission;email to Idaho Power for protective agreement for filings;Prep redacted and confidential versions;file with the IPUC commission 7/31/2026 Paralegal $175.00 1.7 $297.50 and update file and docket 6/5/2026 Paralegal $155.00 0.1 $15.50 Calendar deadlines forwritten comments and company reply. 4.2 $733.00 3/20/2026 Legal $250.00 0.1 $25.00 Revise Petition to intervene 3/27/2026 Legal $250.00 0.3 $75.00 Review and Revise Data Requests and See that same are served upon Idaho Power 4/17/2026 Legal $250.00 0.1 $25.00 Review and sign Protective Agreement and see that consultants sign 4/24/2026 Legal $250.00 0.2 $50.00 Review proposed comments and email Deborah re:same 5/26/2026 Legal $250.00 0.1 $25.00 Conf.with TF re:preparing response to NW Energy Coalition Data Request 7/31/2026 Legal $250.00 0.9 $225.00 Review and revise comments and see that same are filed 1.7 $425.00 3/31/2026 Soft $0.15 25 $3.75 5/29/2026 Soft $0.15 20 $3.00 7/31/2026 Soft $0.15 23 $3.45 $10.20 $1,168.20