20211105Application for Intervenor Funding.pdf

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
Page 1
CASE NO. PAC-E-21-07
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 ROCKY MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDULES AND
REGULATIONS
CASE NO. PAC-E-21-07
APPLICATION FOR INTERVENOR
FUNDING OF THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.
COMES NOW the Idaho Irrigation Pumpers Association, Inc. (“Irrigators”), 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 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 Irrigators’ Counsel, Eric L. Olsen of Echo Hawk & Olsen (“Mr. Olsen”) and
Irrigators’ witness Anthony J. Yankel of Yankel Associates, Inc. (“Mr. Yankel”) participated in
these proceedings. Mr. Olsen prepared and served written discovery, reviewed and analyzed the
various parties’ positions, and attended and participated via video conference in the various
RECEIVED
2021 NOV -5 PM 3:15
IDAHO PUBLIC
UTILITIES COMMISSION

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
Page 2
CASE NO. PAC-E-21-07

technical conferences and settlement conferences held in this matter focusing on the
appropriateness of the various aspects of PacifiCorp’s the general rate case.
Although, the parties have entered into a Settlement Stipulation, Mr. Yankel’s review
efforts focused on the Test Year revenue figures used by PacifiCorp in its filing. Mr. Yankel’s
prepared testimony would have concluded that PacifiCorp’s proposed Test Period revenue is too
low. The Test Period revenue was listed as $271,491,124 and should start at a very minimum of
$274,842,355— which is an increase of $3,351,231. This Test Period revenue adjustment, along
with all the other adjustments proposed by the other Intervenors and Commission Staff, were all
considered in coming up with the numbers included in the Settlement Stipulation.
(C) The Irrigators’ proposed findings and recommendations are captured in the
Settlement Stipulation and Attachments (the “Stipulation”) filed with the IPUC on October 25,
2021. As a signatory, the Irrigators believe that the Stipulation and the resulting proposed revenue
requirement and new rates are fair, just and reasonable resolution to issues addressed therein.
(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. Without incurring these expenses and
costs, the Irrigators would not have been able to fully participate in this matter.
(E) The costs described in Exhibit A constitute a financial hardship for the Irrigators.
The Irrigators are 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
Irrigators 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

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
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CASE NO. PAC-E-21-07

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
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 Irrigators 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 Irrigator officers and directors are elected annually and
serve without compensation.
It has been and continues to be a financial hardship for the Irrigators 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 Irrigators’ financial constraints, participation in this case,
preparing to file testimony, and participating in the settlement negotiations has been focused and
prudent.
(F) The Irrigators’ Test Year revenue issue was not raised by other parties and factored
into the revenue numbers included in the final Stipulation. 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 Irrigator adjustments adopted
in the Stipulation reduced the proposed rate increase for all customer classes.

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
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CASE NO. PAC-E-21-07

(H) The Irrigators represent the irrigation class of customers under Schedule 10 on
Rocky Mountain Power’s system.
Based on the foregoing, it is respectfully submitted that the Irrigators 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 5th day of November, 2021.
ECHO HAWK & OLSEN

_____________________________________
ERIC L. OLSEN

APPLICATION FOR INTERVENOR FUNDING OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
Page 5
CASE NO. PAC-E-21-07

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 5th day of November, 2021, 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)

Emily L. Wegener (Senior Attorney)
Ted Weston
Matthew D. McVee
PacificCorp/ dba Rocky Mountain Power
1407 WN Temple Ste 330
Salt Lake City, UT 84116
[e-mail]
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Data Request Response Center
PacifiCorp/ dba Rocky Mountain Power
825 NE Multnomah, Ste 2000
Portland, OR 97232
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Dayn Hardie
John Hammond, Jr.
Deputy Attorneys General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8, Suite 201-
A (83714)
[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. PAC-E-21-07

Anthony Yankel
Idaho Irrigation Pumpers Association, Inc.
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Bradley G. Mullins
MW Analytics, Energy & Utilities
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Randall C. Budge
Thomas J. Budge
Monsanto, One of the Bayer Group of
Companies
Racine Olsen, PLLP
P.O. Box 1391
Pocatello, ID 83204-1391
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Ronald L. Williams
Attorney for PacifiCorp Idaho Industrial
Customers
Williams Bradbury, P.C.
P.O. Box 388, Boise, ID 83701
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
PIIC Electronic Service Only:
Val Steiner
Kyle Williams
Adam Gardner
[e-mail]
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Additional Bayer Representatives:
James Smith
Mike Veile
[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.
Page 7
CASE NO. PAC-E-21-07

Brian Collins
Maurice Brubaker
Brubaker @ Associates
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Brad M. Purdy
Attorney at Law
219 N. 17th St.
Boise, ID 83702
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Lance Kaufman
Aegis Insight
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Kevin C. Higgins
Courtney Higgins
Milli Picharo
Neal Townsend
Energy Strategies
[e-mail]
[e-mail]
[e-mail]
[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 8
CASE NO. PAC-E-21-07

EXHIBIT A
Expert Witness, Anthony Yankel, Expenses:
1. Witness Fees: 277 Hours @ $200 = $55,400.00

Legal Expenses:
1. Paralegal Fees: 7 Hours @ $90 = $ 630.00
2. Legal Fees Eric L. Olsen: 27.6 Hours @ $200 = $ 5,520.00
3. Soft Costs (Copies/Postage) $ 109.70
Sub Total: $ 6,259.70

Grand Total: $61,659.70