20240502Petition to Intervene.pdf

RECEIVED
Thursday, May 2, 2024 1:13:59 PM
IDAHO PUBLIC
UTILITIES COMMISSION
Matthew A. Nykiel (ISB No. 10270)
710 N. 6th St.
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. IPC-E-24-11
APPLICATION OF IDAHO POWER )
COMPANY FOR A DETERMINATION ) PETITION TO INTERVENE
OF 2023 DEMAND-SIDE )
MANAGEMENT EXPENSES AS ) IDAHO CONSERVATION LEAGUE
PRUDENTLY INCURRED )
COMES NOW the Idaho Conservation League ("ICL") to 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, ICL has direct and substantial interests in these
proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Matthew Nykiel
Attorney for Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]
Please provide copies of all pleadings,production requests,production responses,
Commission orders, and other documents to the name and address above. Please provide the same
documents to the following:
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 1
Idaho Conservation League—Petition to Intervene

Brad Heusinkveld
Idaho Conservation League, Energy Associate
710 N. 6tn St.
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]
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.
ICL asks to reserve the right to request hard copies of papers and documents, as may be
necessary, with appropriate notice and time.
2. Idaho Conservation League and claims a direct and substantial interest in this proceeding
on behalf of our members who are customers of Idaho Power Company("Idaho Power" or
"Company"). ICL represents its organizational interest, the interests of its approximately 11,000
members generally, and those who are customers within the Company's service territory. ICL
holds a seat in the Company's Energy Efficiency Advisory Group ("EEAG") which meets
quarterly to hear updates and advise on Idaho Power's efficiency and DSM programs. In the
EEAG, and by intervention in this preceding, ICL pursues its interest in reducing carbon
emissions and ensuring a well-functioning and flexible energy system. As a result, ICL and its
members have a direct and substantial interest in ensuring continued growth and proper
management of the Company's DSM and energy efficiency programs The Commission has
consistently granted ICL's intervention in Idaho Power dockets on similar grounds.
3. ICL's 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. ICL intends to participate in this matter as a party. The nature and quality of ICUs
intervention in this proceeding is dependent upon the nature and effect of other evidence in this
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 2
Idaho Conservation League—Petition to Intervene

proceeding. If necessary, we may introduce evidence, be heard in argument, and call, examine,
and cross-examine witnesses. ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 2nd day of May, 2024
Respectfully submitted
Is/Matthew A. Nykiel
Matthew A. Nykiel (ISB No. 10270)
Attorney for Idaho Conservation League
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 3
Idaho Conservation League—Petition to Intervene

CERTIFICATE OF SERVICE
I hereby certify that on this 2nd day of May, 2024, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Is/Matthew A. Nykiel
Matthew A. Nykiel (ISB No. 10270)
Attorney for Idaho Conservation League
Electronic Mail Only (See Order No. 35058):
Idaho Public Utilities Commission City of Boise
Monica Barrios-Sanchez Ed Jewell
Commission Secretary Steven Hubble
[e-mail] 150 N. Capital Blvd. P.O. Box 500
[e-mail] Boise, Idaho 83701-0500
[e-mail]
Commission Staff [e-mail]
Adam Triplett [e-mail]
Deputy Attorney General Idaho Public
Utilities Commission NWECISCCAP
[e-mail] F. Diego Rivas
NW Energy Coalition
Idaho Power Company 811 1 st Ave, Suite 305
Megan Goicoechea Allen Seattle, WA 98104
Lisa Nordstrom [e-mail]
Attorneys for Idaho Power Company
P.O. Box 70 Boise, Idaho 83707 Ken Robinette
[e-mail] South Central Community Action
[e-mail] Partnership 550 Washington Street South
[e-mail] Twin Falls, ID 83303
[e-mail]
Connie Aschenbrenner
Zack Thompson
[e-mail]
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-11 Page 4
Idaho Conservation League—Petition to Intervene