20240612Petition to Intervene.pdf

RECEIVED
Wednesday, June 12, 2024
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 )
APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-24-07
COMPANY TO INCREASE RATES )
FOR ELECTRIC SERVICE TO ) PETITION TO INTERVENE
RECOVER COSTS ASSOCIATED )
WITH INCREMENTAL CAPITAL ) IDAHO CONSERVATION LEAGUE
INVESTMENTS AND CERTAIN )
ONGOING OPERATION AND )
MAINTENANCE EXPENSES )
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]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-07 Page 1
Idaho Conservation League—Petition to Intervene

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:
Brad Heusinkveld
Idaho Conservation League
Regulatory Counsel
710 N. 6th 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 was
party to Idaho Power's previous rate case, IPC-E-23-11, and a signatory to the resulting
settlement. The Company's current request stands to increase rates and recover investments and
operational expenses germane to ICUs interest in decarbonization. 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.
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-07 Page 2
Idaho Conservation League—Petition to Intervene

4. ICL intends to participate in this matter as a parry. The nature and quality of ICUs
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. ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 12th day of June, 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-24-07 Page 3
Idaho Conservation League—Petition to Intervene

CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of June, 2024, 1 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 Idaho Irrigation Pumpers Association
Monica Barrios-Sanchez Eric L. Olsen
Commission Secretary Echo Hawk& Olsen, PLLC
[e-mail] 505 Pershing Ave., Ste 100
[e-mail] P.O. Box 6119
Pocatello, Idaho 83205
Idaho Power Company elo(&echohawk.com
Megan Goicoechea Allen
Lisa Nordstrom Lance Kaufman, Ph.D
Donovan Walker 2623 NW Bluebell Place
Attorneys for Idaho Power Company Corvallis, Oregon 97330
P.O. Box 70 Boise, Idaho 83707 [e-mail]
[e-mail]
[e-mail] Industrial Customers of Idaho Power
[e-mail] Peter J. Richardson
[e-mail] Richardson Adams, PLLC
515 N. 27th St.
Tim Tatum P.O. Box 7218
Connie Aschenbrenner Boise, Idaho 83702
Matt Larkin [e-mail]
[e-mail]
cashenbrenner(abidahopower.com Dr. Don Reading
[e-mail] 280 Silverwood Way
Eagle, Idaho 83616
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-07 Page 4
Idaho Conservation League—Petition to Intervene

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-24-07 Page 2
Idaho Conservation League—Petition to Intervene