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 ROCKY ) CASE NO. PAC-E-24-04
MOUNTAIN POWER FOR )
AUTHORITY TO INCREASE ITS ) PETITION TO INTERVENE
RATES AND CHARGES IN IDAHO )
AND APPROVAL OF PROPOSED ) IDAHO CONSERVATION LEAGUE
ELECTRIC SERVICE SCHEDULES )
AND REGULATIONS )
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. PAC-E-24-04 Page 1
Idaho Conservation League—Petition to Intervene

Brad Heusinkveld
Idaho Conservation League
Regulatory Counsel
710 N. 61h 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 PacifiCorp, dba Rocky Mountain Power("Rocky
Mountain 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 is party to the PacifiCorp Multistate Protocol ("MSP") and has participated
in numerous conversations regarding the Company's insurance and catastrophic fire funds
requested in this filing. The Company's proposals are relevant to ICL's interests in utility
operation and also our longstanding engagement on lands in Idaho. 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 ICL'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,
IDAHO PUBLIC UTILITIES COMMISSION, Case No. PAC-E-24-04 Page 2
Idaho Conservation League—Petition to Intervene

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. PAC-E-24-04 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
Rocky Mountain Power [e-mail]
Joseph Dallas
Attorney for Rocky Mountain Power Lance Kaufinan, Ph.D
825 NE Multnomah, Suite 2000 2623 NW Bluebell Place
Portland, OR 97232 Corvallis, Oregon 97330
[e-mail] [e-mail]
Mark Alder
Idaho Regulatory Affairs
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. PAC-E-24-04 Page 4
Idaho Conservation League—Petition to Intervene