20250404Petition to Intervene.pdf

RECEIVED
April 4, 2025
Kelsey Jae (ISB No. 7899) IDAHO PUBLIC
Law for Conscious Leadership UTILITIES COMMISSION
920 N. Clover Dr.
Boise, ID 83703
Phone: [phone]
[e-mail]
Attorney for the Clean Energy Opportunities of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO )
POWER COMPANY'S )
APPLICATION FOR APPROVAL OF ) CASE NO. IPC-E-24-44
SPECIAL CONTRACT AND TARIFF ) CLEAN ENERGY OPPORTUNITIES
SCHEDULE 28 TO PROVIDE ) FOR IDAHO PETITION TO
ELECTRIC SERVICE TO MICRON ) INTERVENE
IDAHO SEMICONDUCTOR )
MANUFACTURING (TRITON) LLC )
Pursuant to IDAPA 31.01.01.042, Clean Energy Opportunities for Idaho ("CEO") hereby
submits this petition to intervene in the above-captioned matter. As discussed below, CEO has
direct and substantial interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Clean Energy Opportunities for Idaho
Courtney White & Mike Heckler
3778 Plantation River Drive, Suite 102
Boise, Idaho 83703
courtney(a)cleanenery,yopportunities.com
mike0cleanenergyopportunities.com
This Intervenor's attorney is:
Kelsey Jae (ISB No. 7899)
920 N. Clover Dr., Boise, Idaho 83703
Ph: [phone]
[e-mail]
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 1
IPC-E-24-44

Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the names and addresses above. In the interest of
conserving natural resources and reducing the costs to all parties, please serve hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
2. CEO is a nonprofit corporation incorporated under the laws of the State of Idaho.
3. CEO has a direct and substantial interest in this proceeding. CEO has intervened and
actively participated in past dockets where matters related to cost causation and rate design have
been addressed, including in Idaho Power's most recent non-limited scope rate case,
IPC-E-23-11. Pursuant to the settlement and stipulation in IPC-E-23-11, CEO conducted
research and analysis related to opportunities for improving the accuracy of cost of service
analysis and the effectiveness of rate design via the utilization of hourly data. CEO has a direct
and substantial interest in continuing to participate in dockets relating to cost growth and rate
design, including this proceeding. Without an opportunity to intervene herein, CEO would not
have an adequate means of fully participating in the determination of matters related to those
cost growth and rate design issues.
4. CEO's participation as an intervenor in this proceeding will not unduly broaden the
issues or delay the proceeding because CEO's interest is directly related to the subjects addressed
in Idaho Power's application. CEO's involvement in this proceeding will not be duplicative of
other parties in this proceeding because no other party adequately represents CEO's interests.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 2
IPC-E-24-44

5. CEO intends to fully participate in this matter as a party. The nature and quality of
CEO's intervention in the proceeding is dependent upon the nature and effect of other evidence
in this proceeding. If necessary, CEO may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. CEO intends to seek intervenor funding pursuant to
IDAPA 31.01.01.161-165.
6. CEO seeks to intervene at this stage due to recent changes in the procedural posture of
this matter. Order No. 36446 stated that the matter would proceed under Modified Procedure
with no technical hearing. On March 14, 2025, the Commission issued Order No. 36512, which
vacated the comment deadline and scheduled oral arguments for Idaho Irrigation Pumpers
Association's Objection to Modified Procedure, Demand for Hearing, and Motion to Consolidate
for hearing with Interrelated Cases ("IIPA's Motion"). Oral arguments were heard on March 25,
2025 and the Commission stated that there would be a technical hearing. For the reasons stated
above, CEO has a direct and substantial interest in participating in the technical hearing as an
intervenor and requests intervenor status.
WHEREFORE, CEO respectfully requests the Commission grant this petition.
DATED this 4th day of April, 2025.
Respectfully submitted,
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 3
IPC-E-24-44

CERTIFICATE OF SERVICE
I hereby certify that on this 4th day of April, I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Electronic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
Monica Barrios-Sanchez
Commission Secretary
secretary0puc.idaho.gov
Idaho PUC Staff
f
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
chris.burdin(@puc.idaho.gov
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
Connie Aschenbrenner
Grant Anderson
mgoicoecheaallenOidahopower.com
[e-mail]
caschenbrennerna idahopower.com
gandersonOidahopower.com
dockets idahopower.com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman, Ph.D.
[e-mail]
lance 0aepisinsi0t.com
Industrial Customers of Idaho Power, Inc.
Peter J. Richardson
Dr. Don Reading
peterPrichardsonadams.com
dreading0mindspring.com
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 4
IPC-E-24-44

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart, LLP
darues chhoff(a)hollandhart.com
tnelson(a)hollandhart.com
awj ensen(a)hollandhart.com
aclee hollandhart.com
karoach0hollandhart.com
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 5
IPC-E-24-44