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Home My WebLink About20240909IPC Answer to Kevin Dickeys Amended Petition To Intervene.pdf 0IQAHO POWER. LISA D. NORDSTROM Lead Counsel Inordstrom(cD-idahopower.com RECEIVED Monday, September 09, 2024 IDAHO PUBLIC September 9, 2024 UTILITIES COMMISSION VIA ELECTRONIC FILING Commission Secretary Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg 8, Suite 201-A (83714) PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. I PC-E-24-07 Application of Idaho Power Company for Authority to Increase Rates for Electric Service to Recover Costs Associated with Incremental Capital Investments and Certain Ongoing Operations and Maintenance Expenses Dear Commission Secretary: Attached for electronic filing in the above referenced matter, please find Idaho Power Company's Answer to Kevin Dickey's Amended Petition to Intervene. If you have any questions about the attached filing, please do not hesitate to contact me. Very truly yours, `' � Lisa D. Nordstrom LDN:cd Enclosures LISA D. NORDSTROM (ISB No. 5733) DONOVAN WALKER (ISB No. 5921) MEGAN GOICOECHEA ALLEN (ISB No. 7623) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2664 Facsimile: (208) 388-6936 Inordstrom(a-)_idahopower.com dwalker idahopower.com mgoicoecheaallen(o)_idahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY TO ) Case No. IPC-E-24-07 INCREASE RATES FOR ELECTRIC ) SERVICE TO RECOVER COSTS ) IDAHO POWER COMPANY'S ASSOCIATED WITH INCREMENTAL ) ANSWER TO KEVIN DICKEY'S CAPITAL INVESTMENTS AND CERTAIN ) AMENDED PETITION TO ONGOING OPERATIONS AND ) INTERVENE MAINTENANCE EXPENSES ) COMES NOW, Idaho Power Company ("Respondent", "Idaho Power" or "Company"), and pursuant to Procedural Rule' ("RP") 57, now answers the Amended Petition to Intervene of Kevin Dickey late in this proceeding dated September 6, 2024. The Company appreciates customer participation in all its cases at the Idaho Public Utilities Commission ("Commission"). In filing this Answer, Idaho Power wishes to ensure The Rules of Procedure of the Idaho Public Utilities Commission (IDAPA 31.01.01) can be accessed online at: https://adminruies.idaho.gov/rules/current/31/310101.pdf. IDAHO POWER COMPANY'S ANSWER - 1 an accurate record on which the Commission can base its final decision and offer transparency about the challenges Mr. Dickey may face in participating as an intervening party under RP 36 rather than as an interested person under RP 39. Mr. Dickey states in his Amended Petition that his "original filing was made one business day after receiving notice of ID Power's application in the mail with his regular power bill" and he "file[d] immediately as an intervenor upon receiving notice." Idaho Power's records indicate there are four meters receiving service at 2953 Honey Lane in Emmett, Idaho,2 including one account billed under Schedule 24, Agricultural Irrigation Service, and three accounts receiving services under Schedule 1, Residential Service. The irrigation account is enrolled in paperless billing, and as such, Mr. Dickey was provided notice of the Company's application electronically with his paperless billing email; that email was sent from Idaho Power on July 4, 2024, with the bill insert customer notice available via link in the email. With respect to Mr. Dickey's other accounts, all three residential accounts receive paper bills and are on "cycle 2" of the Company's billing cycles, pursuant to which the Company provided the customer notice required by RP 125 through a bill insert sent on July 5, 2024, via U.S. Mail. The Company is providing this information to clarify the timing of the notice(s) it provided to Mr. Dickey vis-a-vis the representations in the Amended Petition. The record demonstrates that Mr. Dickey was provided appropriate notice of the Company's Application, belying the suggestion that his untimely intervention was based on insufficient notice. Notwithstanding, Idaho Power does not object per se to the Amended Petition to Intervene filed September 6, 2024. However, the Company notes that there is 2 Ann Dickey is the customer of record on the four accounts associated with this address; Mr. Dickey is listed secondary for the three residential accounts. IDAHO POWER COMPANY'S ANSWER-2 extremely limited time for Mr. Dickey to review the case materials and voluminous discovery such that he can meaningfully participate settlement discussions later this month without experienced utility regulatory counsel. This is particularly true if he intends to "participate herein as a party, and if necessary, to introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in argument," as asserted in the Amended Petition. DATED at Boise, Idaho, this 9th day of September 2024. LISA D. NORDSTROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S ANSWER- 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 9th day of September 2024, 1 served a true and correct copy of Idaho Power Company's Answer to Kevin Dickey's Amended Petition to Intervene upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Chris Burdin U.S. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 11331 W. Chinden Blvd., Bldg No. 8, FTP Site Suite 201-A (83714) X Email: chris.burdinC@.puc.idaho.gov PO Box 83720 Boise, ID 83720-0074 Kevin Dickey Hand Delivered PO Box 337 U.S. Mail Emmett, ID 83717 Overnight Mail FAX FTP Site Email: bf�safelink.net Industrial Customers of Idaho Power Hand Delivered Peter J. Richardson U.S. Mail Richardson Adams, PLLC Overnight Mail 515 N. 27t" Street FAX Boise, Idaho 83702 FTP Site X Email peter richardsonadams.com Dr. Don Reading Hand Delivered 280 Silverwood Way U.S. Mail Eagle, Idaho 83616 Overnight Mail FAX FTP Site X Email dreading(cD-mindspring.com Idaho Irrigation Pumpers Association, Hand Delivered Inc. U.S. Mail Eric L. Olsen Overnight Mail ECHO HAWK & OLSEN, PLLC FAX 505 Pershing Avenue, Suite 100 FTP Site P.O. Box 6119 X Email elo echohawk.com Pocatello, Idaho 83205 IDAHO POWER COMPANY'S ANSWER -4 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance(a)aegisinsight.com Idaho Conservation League Hand Delivered Brad Heusinkveld U.S. Mail 710 N. 6t" Street Overnight Mail Boise, Idaho 83702 FAX FTP Site X Email bheusinkveld(a�_idahoconservation.org Micron Technology, Inc. Hand Delivered Austin Rueschhoff U.S. Mail Thorvald A. Nelson Overnight Mail Austin W. Jensen FAX Kristine A.K. Roach FTP Site Holland & Hart LLP X Email 555 17t" Street, Suite 3200 darueschhoff(Dhol land hart.corn Denver, CO 80202 tnelson(D-hollandhart.com aw'ensen hollandhart.com karoach(a)-hol land hart.com aclee(a-hollandhart.com mamcmillen(D_hollandhart.com Jim Swier Hand Delivered Micron Technology, Inc. U.S. Mail 8000 South Federal Way Overnight Mail Boise, ID 83707 FAX FTP Site X Email jswier micron.com City of Boise Hand Delivered Ed Jewell U.S. Mail Deputy City Attorney Overnight Mail Boise City Attorney's Office FAX 150 N. Capitol Blvd. FTP Site P.O. Box 500 X Email Boise, Idaho 83701 BoiseCityAttorney(a)-cityofboise.org e'ewel I(a-cityofboise.org IDAHO POWER COMPANY'S ANSWER- 5 Steven Hubble Hand Delivered Boise City Dept. of Public Works U.S. Mail 150 N. Capitol Blvd. Overnight Mail P.O. Box 500 FAX Boise, Idaho 83701-0500 FTP Site X Email shubble cityofboise.org Federal Executive Agencies Hand Delivered Peter Meier U.S. Mail Emily W. Medlyn Overnight Mail U.S. Department of Energy FAX 1000 Independence Ave., S.W. FTP Site Washington, DC 20585 X Email Peter.meier(a--)hg.doe.gov emily.medlyn(@_hg.doe.gov Christy Davenport Legal Administrative Assistant IDAHO POWER COMPANY'S ANSWER- 6