20231212Petition for Intervenor Funding.pdf

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
Page 1
CASE NO. IPC-E-23-11

Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC
SERVICE IN THE STATE OF IDAHO AND
FOR ASSOCIATED REGULATORY
ACCOUNT TREATMENT
CASE NO. IPC-E-23-11

APPLICATION FOR INTERVENOR
FUNDING OF THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.

COMES NOW the Idaho Irrigation Pumpers Association, Inc. (“IIPA”), by and through
counsel of record, Echo Hawk & Olsen, PLLC, and hereby respectfully makes application to 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) A summary of the expenses that the IIPA request 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.
(B) The IIPA’s Counsel, Eric L. Olsen of Echo Hawk & Olsen (“Mr. Olsen”) and its
witness Lance D. Kaufman, Ph.D. (“Mr. Kaufman”) participated in these proceedings. Mr. Olsen
and Mr. Kaufman prepared and served written discovery, reviewed and analyzed the various
parties’ positions, and attended and participated in person and via video conference in the various
RECEIVED
Tuesday, December 12, 2023 11:10:40 AM
IDAHO PUBLIC
UTILITIES COMMISSION

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
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CASE NO. IPC-E-23-11

technical conferences and settlement conferences held on September 18th, October 4th, and October
5th, 2023 (“Settlement Conferences”).
Mr. Kaufman’s review efforts focused on cost of capital, rate base, expenses, load forecast,
irrigation peak reward program, net power supply costs, cost of service, rate spread, and rate
design. During the Settlement Conferences all issues considered by IIPA, with the exception of
net power supply costs, were raised and discussed by the parties, including Idaho Power Company
(“IPC”). IPC offered reasonable responses to many of the issues and concerns raised by parties.
Between settlement discussions, IIPA met with members and other intervening parties to discuss
issues in the case. IIPA proposed many of the compromises that led to the Stipulation and
Settlement and associated Motion filed with the Commission on October 27, 2023 (the “Proposed
Settlement”). The IIPA’s proposed findings and recommendations are captured in the Proposed
Settlement. As a signatory, the IIPA believes that the Proposed Settlement and the resulting
proposed revenue requirement and new rates are a fair, just and reasonable resolution to the issues
addressed therein.
(C) The expenses and costs incurred by the IIPA set forth in Exhibit A are reasonable
in amount and were necessarily incurred. The expenses and costs were incurred in participating in
the technical and settlement conferences, in the drafting and review discovery responses, and
negotiating the final terms of the Proposed Settlement. Without incurring these expenses and costs,
IIPA would not have been able to fully participate in this matter.
(D) The costs described 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

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
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CASE NO. IPC-E-23-11

funding, to support its activities. Each year mailings are sent to approximately 7,000 Idaho
Irrigators (approximately one-third in the IPC 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.
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 to fully
participate in such a case. Because of the IIPA’s financial constraints, participation in this case,
preparing to file testimony, and participating in the settlement negotiations has been focused and
prudent.
(E) IIPA proposed many of the compromises that led to the rate spread and rate design
contained in the Proposed Settlement. As such, the issues that the IIPA raised and urged to be
adopted by in the settlement discussions materially differed from those addressed by the
Commission Staff and other parties.
(F) The IIPA’s participation addressed issues of concern to the general body of users
or consumers on IPC’s system in that the Irrigator adjustments adopted in the Stipulation reduced
the proposed rate increase for the majority of customer classes.

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
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CASE NO. IPC-E-23-11

(G) The IIPA represents the irrigation class of customers under Schedule 10 on IPC’s
system.
Based on the foregoing, it is respectfully submitted that the IIPA’s are 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 12th day of December, 2023.
ECHO HAWK & OLSEN

_____________________________________
ERIC L. OLSEN

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
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CASE NO. IPC-E-23-11

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 12th day of December, 2023, I served a true, correct
and complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to
Intervene to each of the following, via U.S. Mail or private courier, email or hand delivery, as
indicated below:

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Idaho Power
Lisa D. Nordstrom
Donovan E. Walker
Megan Goicoechea Allen
Timothy Tatum
Connie Aschenbrenner
Matthew T. Larkin
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Dayn Hardie
Chris Burdin
Deputy Attorneys General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8, Suite 201-
A (83714)
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
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CASE NO. IPC-E-23-11

Lance Kaufman, Ph.D.
Idaho Irrigation Pumpers Association, Inc.
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]
U.S. Mail
Hand Delivered
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Telecopy (Fax)
Electronic Mail (Email)
Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho Inc.
3778 Plantation River Dr., Ste 102
Boise, ID 83703
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Peter J. Richardson
Richardson, Adams, PLLC
515 N 27th Street
Boise, ID 83702
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Dr. Don Reading
280 S. Silverwood Way
Eagle, ID 83616
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
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CASE NO. IPC-E-23-11

Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
Micron Technology, Inc.
555 17th Street Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Tom Arkoosh
Arkoosh Law Offices
IdaHydro
913 W. River St, Suite 450
P.O. Box 2900
Boise, ID 83701
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Ed Jewell
Darrell Early
City of Boise Deputy City Attorney Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Wil Gehl, Energy Program Manager
City of Boise Dept of Public Works
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
Page 8
CASE NO. IPC-E-23-11

Matthew Nykiel
Brad Heusinkveld
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
[e-mail]
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Peter Meier
U.S. Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

F. Diego Rivas
NW Energy Coalition
1101 8th Ave.
Helena, MT 59601
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Benjamin J. Otto
NW Energy Coalition
1407 W. Cottonwood Court
Boise, ID 83702
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Steve W. Chriss
Director, Energy Services
Walmart, Inc.
2608 Southeast J Street
Bentonville, AR 72716
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Norman M. Semanko
Parsons Behle & Latimer
800 W. Main St., Suite 1300
Boise, ID 83702
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
Page 9
CASE NO. IPC-E-23-11

Justina A Caviglia, pro hac vice
Parsons Behle & Latimer
50 West Liberty St., Suite 750
Reno, NV 89502
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

_____________________________________
ERIC L. OLSEN

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
Page 10
CASE NO. IPC-E-23-11

EXHIBIT A
Expert Witness, Lance Kaufman, Expenses:
1. Witness Fees: 72.69 Hours @ $250 = $18,172.50

Legal Expenses:
1. Paralegal Fees: 6.1 Hours @ $90 = $ 549.00
2. Legal Fees Eric L. Olsen: 67.4 Hours @ $250 = $16,850.00
3. Soft Costs (Copies/Postage/Hotel) $ 509.51
Sub Total: $17,908.51

Grand Total: $36,081.01