20240917Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
DATE: SEPTEMBER 17, 2024
SUBJECT: IN THE MATTER OF THE APPLICATION OF IDAHO POWER
COMPANY TO INCREASE RATES FOR ELECTRIC SERVICE TO
RECOVER COSTS ASSOCIATED WITH INCREMENTAL CAPITAL
INVESTMENTS AND CERTAIN ONGOING OPERATIONS AND
MAINTENANCE EXPENSES; CASE NO. IPC-E-24-07.
On May 31, 2024, Idaho Power Company ("Company") filed an application
("Application") with the Idaho Public Utilities Commission ("Commission") requesting an order
approving a revision to the Company's schedules of rates for electric service in the state of Idaho.
The Company requests an increase in annual Idaho jurisdictional revenue of $99,293,220. The
Company proposed an effective date of July 1, 2024, with the understanding that the Commission
would likely suspend the proposed effective date. The Company's Application is structured around
an anticipated effective date of January 1, 2025.
On June 21, 2024, the Commission issued a Notice of Application, Notice of Suspension
of Proposed Effective Date, and Notice of Intervention Deadline. Order No. 36238. The
Commission granted intervention to: Idaho Irrigation Pumpers Association, Inc.; Industrial
Customers of Idaho Power; Micron Technology, Inc.; the city of Boise City; The United States
Department of Energy on behalf of the Federal Executive Agencies; and the Idaho Conservation
League. Order Nos. 36235, 36237, 36277. On July 26, 2024, the Commission issued a Notice of
Parties.
On July 29, 2024, Kevin Dickey filed a Petition to Intervene. On August 20, 2024, the
Commission took up the Petition during the Commission's Decision Meeting. On September 6,
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2024, the Commission issued Order No. 36316 providing Dickey with fourteen (14) days to file
an Amended Petition to Intervene containing supplemental information.
Amended Petition to Intervene
On September 9, 2024, Dickey filed an Amended Petition for Intervention. The Amended
Petition provides in relevant part:
Dickey is not representing a partnership or corporation.
Dickey's original filing was made one business day after receiving notice
of ID Power's application in the mail with his regular power bill. At the time of
filing,Dickey did not realize that the deadline for petitions had passed,and assumed
that it had not, as he had just been notified. While ignorance of the law excuses no
one, Dickey did file immediately as an intervenor upon receiving notice.
Dickey does not know if his interests are being fully represented or protected
by the numerous intervenors that filed timely petitions, thus this amended
application. Dickey has multiple power interests: residential, irrigation, solar-that
may be individually represented by the other intervenors, but collectively there is
no one intervenor that represents Dickey's multiple interests.
Amended Petition at 2.
Idaho Power's Answer to Amended Petition
On September 9, 2024, the Company filed an Answer to the Amended Petition. The
Company represents that Dickey was provided appropriate notice of the Company's Application
including email notification sent on July 4, 2024, with the bill insert customer notice available via
link in the email, and notification by three paper bills through a bill insert sent on July 5, 2024,via
U.S. Mail.
The Company also noted the challenges Dickey may face in participating as an intervening
parry under Idaho Public Utilities Rule of Procedure 36, rather than as an interested person under
Rule 39. The Company reasons that there is extremely limited time for Dickey to review the case
materials and voluminous discovery such that he may meaningfully participate in settlement
discussions later this month without experienced utility regulatory counsel.
COMMISSION DECISION
Does the Commission wish to grant the Petition?
0, -)-Z�A-
Chris Burdin
Deputy Attorney General
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