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Home My WebLink About20260925Petition for Intervenor Funding.pdf RECEIVED September 25, 2026 Eric L. Olsen(ISB#4811) IDAHO PUBLIC ECHO HAWK& OLSEN, PLLC UTILITIES COMMISSION 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 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 PETITION 500-KV TRANSMISSION LINE. FOR INTERVENOR FUNDING 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 IIPA requests to recover, broken down into expert witness fees, legal fees, and other costs, is set forth in Exhibit "A," attached hereto and incorporated by reference. Itemized statements from IIPA's expert witness Deborah Glosser,Ph.D. and its Counsel, Eric L. Olsen of Echo Hawk & Olsen are also included as Attachments 1 and 2 to Exhibit "A" in support of said summary and are incorporated by reference. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 1 CASE NO.IPC-E-26-09 and PAC-E-26-06 B) Statement of Proposed Findings IIPA recommended that the Commission preserve for future ratemaking proceedings all issues relating to cost causation, future cost allocation of regional transmission benefits,prudence, affiliate or multi-system benefits, transmission utilization, capacity value allocation, and the ratemaking treatment of Gateway West Segment E-8 and related facilities. IIPA explained that Idaho Power will own and control 99 percent of Segment E-8's capacity while PacifiCorp will retain only one percent, leaving Idaho Power customers positioned to bear nearly all project costs. IIPA further recommended that approval of the requested Certificates of Public Convenience and Necessity ("CPCN") not be construed as resolving future questions concerning cost allocation, cost-of-service treatment, or customer responsibility for Segment E-8 costs. IIPA also identified that ownership, capacity shares, and cost responsibility across the broader Gateway West program remain capable of evolving as Segments 9 and 10 advance. IIPA therefore urged the Commission to avoid treating any cost-causation or allocation determination in this Segment E-8 proceeding as fixed for the Gateway West program as a whole. Finally, IIPA asked that the record preserve the distinction between Idaho retail reliability obligations and the broader regional,multi-system,and transfer-capability benefits associated with Segment E-8. These recommendations were directed to the Commission's future review of project prudence, allocation, and ratemaking treatment rather than opposition to issuance of the CPCNs. C) Statement Showing Costs IIPA requests $5,970.20 in intervenor funding for the expenses and costs described in Exhibit A. The expenses were reasonable, necessary, and directly related to IIPA's participation in this proceeding. The work included reviewing the Company's Application and testimony, the governing project agreements and amendments, discovery responses, Commission Staff s IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 2 CASE NO.IPC-E-26-09 and PAC-E-26-06 comments, and the Companies' Joint Reply Comments; analyzing ownership, capacity, project- cost, and future-ratemaking issues; consulting with IIPA's expert witness; and preparing and filing IIPA's Written Comments. The issues presented required focused review of the 99-to-1 ownership and capacity allocation for Segment E-8, PacifiCorp's unexercised option to increase its Segment E-8 interest, Idaho Power's funding responsibility,the continuing option rights and potential changes affecting other Gateway West segments, the absence of binding ratemaking treatment in this proceeding, and the need to preserve cost-causation and allocation issues for later proceedings. The expenses incurred were proportionate to the scope and complexity of those issues, and IIPA exercised prudent judgment to minimize costs while adequately representing 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 IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 3 CASE NO.IPC-E-26-09 and PAC-E-26-06 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. It has been and continues to be a financial hardship for IIPA to fully participate in important cases such as this one because of the time and expense required for meaningful participation.Given IIPA's financial constraints, its work in this proceeding was focused and prudent. IIPA concentrated on targeted review and discovery concerning Segment E-8 ownership, capacity, project costs, contractual rights, regional and multi-system benefits, and future ratemaking implications; consultation with its expert witness; and preparation of written comments addressing issues affecting irrigation customers. E) Statement of Difference IIPA's participation differed materially from that of Commission Staff. Staff evaluated whether the Companies demonstrated need and whether Segment E-8 was the least-cost, least-risk alternative; recommended approval of both CPCNs; raised concerns regarding project sizing, new large loads, delay risk, and cost overruns; and proposed cost tracking, system-capacity planning, and periodic budget compliance filings. IIPA did not oppose issuance of the CPCNs or advocate a specific allocation methodology in this proceeding. Instead,IIPA focused on the 99-to-1 ownership and capacity split,PacifiCorp's decision not to exercise its option to acquire a larger Segment E-8 interest, Idaho Power's responsibility for nearly all Segment E-8 costs, the evolving ownership and capacity structure of the broader Gateway West program, and the distinction between Idaho retail obligations and regional or multi-system benefits. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 4 CASE NO.IPC-E-26-09 and PAC-E-26-06 Accordingly, Staffs comments centered on the present CPCN decision, project need, alternatives, project risks, and proposed compliance requirements, while IIPA concentrated on preserving a record for later prudence, cost-allocation, cost-of-service, and ratemaking determinations. The Companies' Joint Reply Comments expressly acknowledged IIPA's request that those issues be addressed in future proceedings. F) Statement of Recommendation IIPA's participation addressed issues of concern to the general body of utility users and consumers by ensuring that the record reflects who will own, control, and initially fund Segment E-8; the regional and multi-system benefits the project may provide; and the need to determine prudence, cost causation, allocation, and ratemaking treatment on a complete record when recovery is later requested. Because Idaho Power will hold 99 percent of Segment E-8's capacity, these issues may materially affect the costs ultimately assigned to Idaho Power customers. By identifying these issues before construction and future cost-recovery proceedings, IIPA's participation promotes informed regulatory decision-making and helps ensure that later determinations are based on sound cost-causation principles and an accurate understanding of project benefits and responsibility. Those matters affect irrigation customers as well as the broader body of Idaho Power customers. G) Statement Identifying Customer Class IIPA represents the Irrigation class of customers under Schedule 24 on Idaho Power Company's system. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 5 CASE NO.IPC-E-26-09 and PAC-E-26-06 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 25th day of September, 2026. EC WK& OLSEN ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 6 CASE NO.IPC-E-26-09 and PAC-E-26-06 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 25th day of September,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) secretga@Xuc.idaho.gov 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.PETITION FOR INTERVENOR FUNDING—Page 7 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.PETITION FOR INTERVENOR FUNDING—Page 8 CASE NO.IPC-E-26-09 and PAC-E-26-06 EXHIBIT A Expert Witnesses: Deborah Glosser, Expenses: 1. Witness Fees: 17.9 Hours @ $275 = $ 4,922.50 Sub Total: $4,922.50 Legal Expenses: 1. Paralegal Fees: 3.5 Hours @ $175 = $ 612.50 2. Legal Fees Eric L. Olsen: 1.7 Hours @ $250 = $ 425.00 3. Soft Costs (Copies/Legal Research) $ 10.20 Sub Total: $ 1,047.70 Grand Total: 5,970.20 IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PETITION FOR INTERVENOR FUNDING—Page 9 CASE NO.IPC-E-26-09 and PAC-E-26-06 ATTACHMENT 1 Date Fee Type Cost Amount Total Description 5/11/2026 Legal $275.00 1 $275.00 Data request acquisition and organization 5/13/2026 Legal $275.00 3 $825.00 Review data request information and work on modeling 5/14/2026 Legal $275.00 4 $1,100.00 Continue on data request reviewworkfor comments on case 5/15/2026 Legal $275.00 4 $1,100.00 Begin drafting written comments 5/17/2026 Legal $275.00 2.2 $605.00 Finish final draft of comments and email to Eric and Taysha 5/28/2026 Legal $275.00 3 $825.00 Review new data requests from IPC and RMP,correspondence 9/12/2026 Legal $275.00 0.7 $192.50 Reviewwritten comments filed by Company and IPC 17.9 $4,922.50 ATTACHMENT2 Date Fee Type Cost Amount Total Description 4/8/2026 Paralegal $175.00 0.3 $52.50 Draft petition to intervene and file with the IPUC and prep for new file in system 4/15/2026 Paralegal $175.00 0.9 $157.50 Prepare data requests in case for Idaho Power Company;file with the IPUC and calendar response deadline CaIL W/ELO protective order.Email via Docusign for signatures.Save completed docs and summary to file.Email signature 5/6/2026 Paralegal $175.00 0.3 $52.50 pages. 5/28/2026 Paralegal $175.00 0.6 $105.00 Begin preparing pleading for written comments and revisions 5/29/2026 Paralegal $175.00 0.9 $157.50 Finish written comments and prepare for atty review 8/19/2026 Paralegal $175.00 0.4 $70.00 Review comments and email team on revisions and Friday deadline for updates needed;update 9/14/2026 Paralegal $175.00 0.1 $17.50 Update docket with comments from IPC 3.5 $612.50 4/8/2026 Legal $250.00 0.3 $75.00 Initial Review of application for CPCN for Gateway West transmission line;Conf.with TF re:Filing Petition to Intervene 4/15/2026 Legal $250.00 0.3 $75.00 Review Data Requests for information on Segment 8 of Gateway West 5/6/2026 Legal $250.00 0.5 $125.00 Review and sign Protective Agreement and see that Lance and Deborah sign Exhibit As to the same 5/6/2026 Legal $250.00 0.2 $50.00 Email Signature pages to Idaho Power Company to receive confidential data requests 8/21/2026 Legal $250.00 0.4 $100.00 Review and finalize comments for Gateway West Segment 8 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 $1,047.70