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Home My WebLink About20200610Application for Intervenor Funding.pdfECHOHNWrc &OLSEN M,q.mA. EcHo HAwK EpJc L. OLseN JoSEPH T. PnrsroN .,\ l"[oR\1,\'s 5{]-il)},Rsilt\(;.A\I Sil l(}() I'O IIO\ 6ll() l)(x'.r r l,r.l.r>. II) Sll05-6 I I I 2(tti 17ti i(,1.1 20li.17li-l(r7(t t rr \\ \\ \\ I ('lt()lt \\\ k ( ()\t June 10,2020 Diane Hanian, Commission Secretary Idaho Public Utilities Commission 472W. Washington Boise, ldaho 83720-007 4 diane.holt@puc.idaho. gov Re: CASE No.: PAC-E-18-0t IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION FOR AUTHORIZATION TO CHA}IGE DEPRECIATION RATES APPLICABLE TO ELECTRIC PROPERTY Dear Ms. Hanian: Enclosed please find the original Application for Intervenor Funding of the ldaho Irrigation Pumpers Associations, Inc. in PAC-E-I8-08 to be filed electronically per Order No. 34602. Electronic copies are being served per the Certificate of Service. Please file the Application in the case file. tf you have any questions, please don't hesitate to call. Thank you. Sincerely, Eric L. Olsen ELO/rjb Enclosures H:\WDOX\CLIENTS\l 343\0022\000797 I 0.DOCX {:::r , -*f(.:::.$ L.- +, ;# lii()o$ #rn &)(} s ,',,, I --.'t- r'i *".. 5. r-, r$t1$) Eric L. Olsen (ISB# 481l) ECHO HAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello,Idaho 83205 Telephone : (208) 47 8-l 624 Facsimile: (208) 47 8-167 0 Email: elo@echohawk.com Attorneyfor Intervenor ldaho Irrigation Pumpers Association, Inc. BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION FiTCTIVED ?[:S JU,q l0 P]l 3r ltr ':- ' irri li ii;-! ir'' :..; i UlrLtV, ::'i r::*ti ilCi,il,{tSSl0},i IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION FOR AUTHORIZATION TO CHANGE DEPRECIATION RATES APPLICABLE TO ELECTRIC PROPERTY CASE NO. PAC-E-18.08 APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. COMES NOW the Idaho lrrigation Pumpers Association, Inc. ("Irrigators"), by and through counsel of record, Echo Hawk & Olsen, PLLC, and hereby respectfully makes application to the ldaho Public Utilities Commission ("Commission") for intervenor funding, pursuant to ldaho Code 5 6l-617A and IDAPA 5S 3l.0l.0l.16l through .165, in this case, as follows: (A) A summary of the expenses that the Irrigators 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 lrrigators' Counsel, Eric L. Olsen of Echo Hawk & Olsen ("Mr. Olsen") and Irrigator's witness Dr. Lance Kaufman of Aegis Insight ("Dr. Kaufman"), and Irrigators' witness Anthony J. Yankel of Yankel Associates, Inc. ("Mr. Yankel") participated in these proceedings. Mr. Olsen and Dr. Kaufman prepared and served written discovery, reviewed and analyzed the various parties' positions, and attended and participated via conference call or in person in the APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. PAC-E-1E-08 Pagc I numerous technical conferences and settlement conferences held in this matter focusing on the appropriateness of the various elements of the depreciation study of the proposed PacifiCorp system and Idaho specific asset accounts. Dr. Kaufman's efforts focused on the depreciable lives, retirement dispersion patterns, net salvage, and decommissioning costs of PacifiCorp's assets. Dr. Kaufman performed actuarial analysis of every PacifiCorp plant account with vintage accounting records. Dr. Kaufrnan reviewed PacifiCorp's proposed net salvage values and compared these values with annual, average, and rolling average historic cost of removal, salvage, and net salvage amounts for each PacifiCorp plant account. Dr. Kaufinan reviewed PacifiCorp's initially filed decommissioning study and the revised decommissioning and remediation study. Mr. Yankel's efforts focused on the appropriateness PacifiCorp's request to accelerate the retirement and depreciation of seven coal fire plants in its fleet (Cholla-4, Colstrip 3&$, Craig l&2, and Bridger I & 2). Mr. Yankel's eflorts were put on hold in the middle of this case as PacifiCorp readdressed the appropriate term for the acceleration of depreciation and forecast decommissioning costs of these thermal plants in the 2019 IRP. Ultimately, the thermal plant lives and the decommission costs were removed from the current settlement and are being addressed in Phase [I ofthis case. (C) The lrrigators' proposed findings and recommendations are captured in the Stipulation on Depreciation Rate Changes and in its supporting Attachments (the "stipulation") to be filed with the IPUC shortly. As a signatory, the Irrigators believe that the Stipulation and the resulting proposed depreciation rates are fair, just and reasonable resolution to issues addressed therein. APPLICATION FOR INTERVENOR FUI{DING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PAC-E-18-08 Page 2 (D) The expenses and costs incurred by the Irrigators 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 Stipulation and will assist the Irrigators in completing Phase II of this case. Without incurring these expenses and costs, the Irrigators would not have been able to fully participate in this matter. (E) The costs described in Paragraph (A) above constitute a financial hardship for the Irrigators. The Irrigators are an Idaho nonprofit corporation qualified under I.R.C.5 501(c)(5) representing farm interests in electric utility rate matters affecting farmers in southern and central Idaho. The Inigators rely solely upon dues and contributions voluntarily paid by members, together with intervenor funding, to support its activities. Each year mailings are sent to approximately 7,000 Idaho Irrigators (approximately one-third in the Rocky Mountain Power service area), soliciting annual dues. The Irrigators recommend members make voluntary contributions based on acres inigated 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 Irrigators must pay all expenses, which generally include mailing expenses, meeting expenses and shared office space in Boise, Idaho, in addition to the expenses relating to participation in matters before the Commission. The Executive Director, Lynn Tominaga, is the only part-time paid contractor, receiving a retainer plus expenses for office space, office equipment, and secretarial services. Other Irrigator officers and directors are elected annually and serve without compensation. APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.pAC-E-lE_18 page 3 It has been and continues to be a financial hardship for the lrrigators 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 lrrigators' financial constraints, participation in this case, and filing of testimony and cross-examination of witnesses has been prudent. (F) The Irrigators' raised many issues, that were not raised by other parties, some of which were not included in the final Stipulation. The final Stipulation contained Irrigator requested adjustments to Accounts 343, Idaho 363, ldaho 364, and Wyoming 390 that were solely Irrigator's proposals that did not appear in any other party's settlement offers. As such, the issues that the Irrigators raised and urged to be adopted by in the settlement discussions materially differed from those addressed by the Commission Staff and other parties. (G) The Irrigators' participation addressed issues of concern to the general body of users or consumers on Rocky Mountain Power's system in that the lrrigator adjustments adopted in the Stipulation reduced the proposed rate increase for all customer classes. (H) The Irrigators represent the irrigation class of customers under Schedule l0 on Rocky Mountain Power's system. Based on the foregoing, it is respectfully submitted that the Irrigators are a qualiffing intervenor and should be entitled to an award of costs of intervention in the maximum amount allowable pursuant to Idaho Code 5 6l-617A and IDAPA 55 3l.0l.0l.l6l through .165. DATED this 10ft day of June,2O2O. ECHO HAWK & OLSEN, PLLC By: ERIC L. OLSEN Affomey for Idaho lrrigation Pumpers Association, Inc APPLICATION FOR INTERVENOR FTII\DING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.PAC-E-18-08 Pagc 4 CERTIFICATE OF SERVICE I hereby certiff that on the lOth day of June , 2020,I caused to be served a true and correct copy of the foregoing by the method indicated below, and addressed to the following: Diane M. Hanian, Secretary Idaho Public Utilities Commission P.O. Box 83720 I l33l W. Chinden Blvd. Building 8, Suite 201-A Boise,ID 83714 diane.holt@.puc. idaho.gov Edward Jewell Deputy Attomey General Idaho Public Utilities Commission 47 2 W . Washington (837 02) P.O. Box 83720 Boise, ID 83720-0074 edward. iewell@puc.idaho. q0v U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Ovemight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) trtrxtrx trtrtrtrx trtrtrtrx Emily L. Wegener (Senior Atorney) Yvonne R. Hogle Ted Weston PacifiCorp/ dba Rocky Mountain Power 1407 WN Temple Ste 330 Salt Lake City, UT 841l6 em i l-v. we gener(apac i fi corp.conr vvonne.hosle@pac ifi corp.com ted.weston ificorn.com D. Matthew Moscon Lauren Shurman PacifiCorp/ dba Rocky Mountain Power Stoel Rives, LLP 201 s. state St., ste I100 salt Lake city, UT 841I I matt.mosco 6)stoel.cont lauren.shurm l.con't APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC PAC-E-18-08 Page 5 Data Request Response Center PacifiCorp/ dba Rocky Mountain Power 825 NE Multnomah, Ste 2000 Portland, OR97232 datareq uest@paci fi corp.com Dr. Lance D. Kaufman Idaho lrrigation Pumpers Association, Inc. 4801 W. Yale Ave. Denver, CO 80219 lance@aegisinsi ght.com Anthony Yankel Idaho Irrigation Pumpers Association, Inc. 12700 Lake Avenue, Unit 2505 Lakewood, OH44107 tony@yankel.net Randall C. Budge Thomas J. Budge Attorneys for Monsanto Company Racine Olsen, PLLP P.O. Box 1391 Pocatello, ID 83204-1391 rcb@racinelaw.net tjb@racinelaw.net Brubaker & Associates Monsanto Company 16690 Swingley Ridge Rd., #140 Chesterfield, MO 63017 mbrubaker@consultbai.com kiverson@consultbai.com Ronald L. Williams Attorney for PacifiCorp Idaho Industrial Customers Williams Bradbury, P.C. P.O Box 388 Boise,ID 83701 ron@wil liamsbradbury.com U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Ovemight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Ovemight Mail Telecopy (Fax) Electronic Mail (Email) trx trtrtrtrx APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.PAC-E-18-08 Pege 6 II Jim Duke ldahoan Foods PacifiCorp Idaho Industrial Customer jduke@idahoan.com Kyle Williams BYU Idaho PacifiCorp Idaho Industrial Customers williamsk@byui.edu Val Steiner Nu-West Industries, [nc. PacifiCorp Idaho Industrial Customers Val.steiner@agrium.com Benjamin J. Otto Idaho Conservation League 710 N. 6th Street Boise,lD 83702 botto@idahoconservation. org Matthew Gerhart (CO Bar #50908) Attorney for Sierra Club 1536 Wynkoop St., Ste.200 Denver, CO 80202 matt. gerhart@ sierracl ub.org Ana Boyd Sierra CIub 2l0l Webster St., Ste. 1300 Oakland, CA946l2 ana.boyd@sierraclub.org U.S. Mail Hand Delivered Ovemight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) trtrtrtrx trtrtrtrx trnntrx trtrtrtr U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Ovemight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) APPLICATION FOR INTERVENORFUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.PAC-E-1&08 Pege 7 Eric L. Olsen, Echo Hark & Olsen PLLC APPLICATIONI'ORINTERVENOR UNI}ING OFTEE IDAHOIRRIGATIONPI'MPEBSASS(rcIATION,INC. PAC-E 1t{8 Prgot EXHIBIT A Expert Witness, Anthony Yankel, Expenses: l. Witness Fees: 42 Hours @ $ZOO: Expert Witness, Dr. Lance D.IGufman, Expenses: l. Witness Fees: 91.85333 Hours @$ZtO: 2. Travel Expenses & Costs: Sub Total: Legal Expenses: l. Paralegal Fees: 5.7 Hours @ $gO: 2. Legal Fees Eric L. Olsen:44 Hours @ $ZOO = 3. Travel Expenses & Costs: 4. Soft Costs: Sub Total: $8,400.00 $11,424.23 $ lss.00 $11,579.23 $ s13.00 $ 7,638.00 $ 203.77 $ 23.06 $ 8,377.83 Grand Total: $28,357.06 APPLICATION FOR INTERVENOR FUNDING OF THE IDAIIO IRRIGATION PI'MPERS ASSOCIATION,INC. PAC-E lt-08 Prgc 9