20240501Petition to Intervene.pdf

RECEIVED
Wednesday, May 1, 2024 12:54:46 PM
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO ) CASE NO. IPC-E-24-11
POWER COMPANY'S )
APPLICATION FOR A ) PETITION TO INTERVENE OF
DETERMINATION OF 2023 ) NW ENERGY COALITION AND
DEMAND-SIDE MANAGEMENT ) SOUTH CENTRAL COMMUNITY
EXPENSES AS PRUDENTLY ) ACTION PARTNERSHIP
INCURRED )
COMES NOW the NW Energy Coalition("NWEC") and the South Central Community
Action Partnership ("SCCAP",jointly"NWEC/SCCAP")hereby request leave to intervene in
the above captioned matter pursuant to the Idaho Public Utilities Commission Rules of
Procedure, IDAPA 31.01.01.071-073. As discussed below,NWEC has a direct and substantial
interest in these proceedings, and therefore should be granted intervention.
1. The name and address of this intervenor is:
NW Energy Coalition
811 1"Ave, Suite 305
Seattle, WA 98104
South Central Community Action Partnership
550 Washington Street South
Twin Falls, ID 83303
2. Please provide copies of all pleadings,production requests,production responses,
Commission orders, and other documents to the following:
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 1
NWEC/SCCAP,Petition to Intervene

F. Diego Rivas Ken Robinette
Regulatory Counsel Chief Executive Officer
NW Energy Coalition South Central Community Action
1101 81h Ave Partnership
Helena, MT 59601 550 Washington Street South
[phone] Twin Falls, ID 83303
diegognwenergy.org [phone]
ken(ksccap-id.org
In the interest of reducing costs to all parties,pleadings, testimony, briefs, production
requests, responses, notices, Commission orders, and other filings may be submitted via
electronic mail in accordance with Idaho Public Utilities Commission Rule 31.01.01.063.02-03.
NWEC/SCCAP ask to reserve the right to request hard copies of papers and documents, as may
be necessary with appropriate notice and time.
3. NWEC and SCCAP claim direct and substantial interests in this proceeding on behalf of
its members and clients who are customers of Idaho Power. NWEC has 11 member
organizational members in Idaho. NWEC and their members have a direct and substantial
interest in ensuring that Idaho Power acquires all cost-effective energy efficiency, implements
cost-saving demand response programs, and that cost recovery does not present a barrier to
implementation of demand-side management(DSM)programs. Furthermore,NWEC and its
members have an equity interest in ensuring that low-income customers are not left behind in the
dynamic energy landscape and that low-income weatherization remains a key component of the
utility's overall DSM portfolio.
For its part, SCCAP, as an implementor of weatherization services, claims a direct and
substantial interest in ensuring utility contributions remain a component of overall low-income
weatherization funding. Decisions in this docket will affect the ability of those receiving SCCAP
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 1
NWEC/SCCAP,Petition to Intervene

services, many of which are customers of Idaho Power, to afford continued electricity rates and
services.
NWEC and SCCAP have previously intervened in similar utility dockets in Idaho on these
grounds. NWEC/SCCAP intervention will respond directly to the issues raised in the Company's
application and will not unduly broaden the scope of the issues or this proceeding.
4. NWEC/SCCAP intend to fully participate in this matter as a party. The nature and quality
of NWEC/SCAAP's intervention in this proceeding is dependent upon the nature and effect of
other evidence in this proceeding. If necessary,we may introduce evidence, be heard in
argument, and call, examine, and cross-examine witnesses.
WHEREFORE,NWEC respectfully requests the Commission grant this petition.
DATED this 1 st day of May, 2023.
Respectfully submitted,
AI F. Diego Rivas
F. Diego Rivas (requesting admittance Pro Hac Vice)
Counsel for NW Energy Coalition and South Central
Community Action Partnership
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 2
NWEC/SCCAP,Petition to Intervene

CERTIFICATE OF SERVICE
I hereby certify that on this I It day of May, 2024, I delivered true and correct copies of
the foregoing PETITION TO INTEVENE to the following persons via the method of service
noted:
/s/F. Diego Rivas
Regulatory Counsel
NW Energy Coalition
1101 8m Ave
Helena, MT 59601
[e-mail]
Electronic Mail Only(See Order No. 35058):
Idaho Public Utilities Commission
Monica Barrios-Sanchez
Commission Secretary
[e-mail]
[e-mail]
Commission Staff
Adam Triplett
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Connie Aschenbrenner
1221 W. Idaho St.
P.O. Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
City of Boise
Ed Jewell
Steven Hubble
150 N. Capital Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
[e-mail]
[e-mail]
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 3
NWEC/SCCAP,Petition to Intervene