20240521Petition to Intervene.pdf

RECEIVED
2024 May 21, 5:36PM
IDAHO PUBLIC
Kelsey Jae (ISB No. 7899) UTILITIES COMMISSION
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Phone: [phone]
[e-mail]
Attorney for the Clean Energy Opportunities of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO )
POWER COMPANY'S ) CASE NO. IPC-E-24-16
APPLICATION FOR A CPCN FOR ) CLEAN ENERGY OPPORTUNITIES
THE BOISE BENCH BATTERY ) FOR IDAHO
STORAGE FACILITY ) PETITION TO INTERVENE
Pursuant to IDAPA 31.01.01.042, Clean Energy Opportunities for Idaho ("CEO") hereby
submits this petition to intervene in the above-captioned matter. As discussed below, CEO has
direct and substantial interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Clean Energy Opportunities for Idaho
Courtney White &Mike Heckler
3778 Plantation River Drive
Suite 102
Boise, ID 83703
Courtney0cleanenergyopportunities.com
mikena cleanenergyopportunities.com
This Intervenor's attorney is:
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise, Idaho 83703
Ph: [phone]
[e-mail]
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 1
IPC-E-24-16

Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the names and addresses above. In the interest of
conserving natural resources and reducing the costs to all parties, please serve hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
2. CEO is a nonprofit corporation incorporated under the laws of the State of Idaho.
3. CEO has a direct and substantial interest in this proceeding. The organization was
founded with a mission to bring problem-solving rigor and solution-focused approaches to
advance clean energy and better serve the long-term interests of Idahoans and future generations.
As indicated in Eric Hackett's testimony, with the exception of the PowerEx market purchase,
the ranks of final shortlisted 2026 projects all involved solar or BESS or both resource types.'
Increasing reliance on variable energy resources such as solar directly affect the value of using
historical costing approaches based on peak hour requirements.2 Further, a decision resulting in
the issuance of a CPCN for the acquisition of a 150MW BESS would directly affect the
valuation of additional solar and battery resources in the Company's next Integrated Resource
Planning process.3 CEO has a direct and substantial interest in continuing to participate in
' See IPC-E-24-16, Hackett Direct, Table 3, page 39.
z See IPC-E-24-16, Ellsworth Direct at page 8: "However, as the wider industry, and the
Company, experience increased reliance on variable energy resources, whose hour-to-hour and
season-to-season generation changes, it is no longer viable to only contemplate peak hour
requirements."
3 See IPC-E-24-16, Ellsworth Direct at page 26: "When solar PV and battery storage additions
become unbalanced via large additions of one and not the other, the result is a lower ELCC for
the resource that was added, and a higher ELCC for the resource that was not added. This is
occurring in 2026 given the large quantity of battery storage the Company is adding in 2025, and
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 2
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dockets relating to the timing of high risk hours and the associated costs and the valuation of
energy resources. Without an opportunity to intervene herein, CEO would not have an adequate
means of fully participating in the determination of matters related to those issues.
4. CEO's participation as an intervenor in this proceeding will not unduly broaden the
issues or delay the proceeding because CEO's interest is directly related to the subjects addressed
in Idaho Power's application. CEO's involvement in this proceeding will not be duplicative of
other parties in this proceeding because no other party adequately represents CEO's interests.
5. CEO intends to fully participate in this matter as a party. The nature and quality of
CEO's intervention in the proceeding is dependent upon the nature and effect of other evidence
in this proceeding. If necessary, CEO may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. CEO intends to seek intervenor funding pursuant to
IDAPA 31.01.01.161-165.
6. CEO requests the Commission grant this Petition to Intervene despite its filing after the
intervention deadline. Due to its small staffing level (two individuals) and matters that staff
recently faced related to family health issues, CEO has not been able to timely respond to Idaho
Power's application in this docket. Upon reviewing the testimony in this docket, and in light of
related issues raised by Staff in comments submitted under IPC-E-23-144, CEO believes it
essential to fully understand the matters raised in this case in order to most effectively perform
its obligations for holding workshops'related to how a supplemental hourly informed cost of
service analysis could affect future time-of-use and other rate design matters. For that reason,
now further adding to this storage in 2026, resulting in a lower ELCC for energy storage
facilities."
'See IPC-E-23-23, Staff Comments, Feb 15, 2024, pages 21-24.
'See IPC-E-23-11, Stipulation and Settlement, section 13, page 11.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 3
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CEO has determined that it would be in its best interest to intervene in this case. CEO believes
that its intervention will not prejudice any parties to this matter or otherwise delay this matter.
CEO agrees to accept the record and the schedule for this case as it stands.
WHEREFORE, CEO respectfully requests the Commission grant this petition.
DATED this 21st day of May, 2024.
Respectfully submitted,
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 4
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CERTIFICATE OF SERVICE
I hereby certify that on this 21st 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:
Electronic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
Monica Barrios-Sanchez, Secretary
[e-mail]
Idaho Power Company
Donovan Walker
Tim Tatum
[e-mail]
[e-mail]
[e-mail]
Micron Technology, Inc.
Jim Swier
[e-mail]
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 5
IPC-E-24-16