20240710Petition to Intervene.pdf

RECEIVED
Wednesday, July 10, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Peter Meier
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
[e-mail]
Attorneys for the Federal Executive Agencies
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07
OF IDAHO POWER COMPANY TO )
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ) THE FEDERAL EXECUTIVE
ASSOCIATED WITH INCREMENTAL ) AGENCIES' PETITION TO
CAPITAL INVESTMENTS AND CERTAIN ) INTERVENE
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES )
THE FEDERAL EXECUTIVE AGENCIES' PETITION TO INTERVENE
The United States Department of Energy ("DOE"), on behalf of itself and other federal
executive agencies (together, the "Federal Executive Agencies" or "FEA"), hereby petitions the
Idaho Public Utilities Commission (the "Commission") pursuant to Rules 71, 72, and 73 of the
Commission's Rules of Procedure,to intervene and become a party in this proceeding. In support
of this petition, DOE states:
1. The name and address of the Petitioner is:
Federal Executive Agencies
c/o U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
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Copies of all pleadings, production requests, production responses, Commission orders,
and other documents should be provided to:
Peter Meier
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
peter.meier(ahq.doe.gov
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
emily.medlyn&hq.doe._og_v
2. FEA has a direct and substantial interest in the subject matter of this proceeding. FEA
consists of agencies of the United States Government that have offices, facilities, and installations,
including the Idaho National Laboratory ("INL") and Mountain Home Air Force Base, that
purchase electricity from Idaho Power Company ("IPC"). INL is one of IPC's largest customers
and is a"special contract" customer under IPC's retail electric tariff.
3. FEA intends to participate in this proceeding as a party in all respects that may be
required for it to represent its interests, including submission of direct and responsive testimony,
examination and cross-examination of witnesses, submission of briefs, and presentation of and
response to motions and oral argument.
4. Granting FEA's Petition to Intervene will not unduly broaden the issues, nor will it
prejudice any party to this case.
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5. Without the opportunity to intervene, FEA could not participate in the lawful
determination of issues which will have a material effect on the rates, terms, and conditions under
which it receives service.
6. DOE has been delegated authority by the General Services Administration to represent
the consumer interest of the FEA in this proceeding under 40 U.S.C. §§ 501(c) and 121(d).
Consistent with Rule 5.5 of the Idaho Rules of Professional Conduct and Commentary note [1],
the appearance of a lawyer authorized by federal statute or other federal law to represent the
interests of the United States before an Idaho tribunal does not constitute the unauthorized practice
of law, even though such lawyer is not admitted to the bar of Idaho or through pro hac vice
admission. Peter Meier is an active member, in good standing, of the bar of Maryland and is an
attorney employed by DOE. Emily Medlyn is an active member, in good standing, of the bar of
South Carolina and is an attorney employed by DOE. Neither Mr. Meier nor Ms. Medlyn is
admitted to the bar of Idaho.
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WHEREFORE, FEA respectfully requests that this Commission grant this Petition to
Intervene in this proceeding and to present evidence, call and examine witnesses, present
argument, and to otherwise fully participate in this proceeding.
Respectfully submitted, this 1 Or' day of July 2024.
FEDERAL EXECUTIVE AGENCIES
BY THE U.S. DEPARTMENT OF ENERGY
(` t " l ' "
.lllbc� —
Emily W. Medlyn
Attorney-Adviser
Peter Meier
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
Fax: [phone]
peter.meierkhq.doe.gov
[e-mail]
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07
OF IDAHO POWER COMPANY TO )
INCREASE RATES FOR ELECTRIC )
SERVICE TO RECOVER COSTS ) CERTIFICATE OF SERVICE
ASSOCIATED WITH INCREMENTAL )
CAPITAL INVESTMENTS AND CERTAIN )
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES )
I CERTIFY that on this date I sent by email a true and correct copy of THE FEDERAL
EXECUTIVE AGENCIES' PETITION TO INTERVENE on the parties of record to this
proceeding.
DATED July 10, 2024.
Emily W. Medlyn
Attorney-Adviser
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
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