20250407Petition to Intervene.pdf

RECEIVED
April 7, 2025
Gregory M. Adams (ISB No. 7454) IDAHO PUBLIC
Richardson Adams, PLLC UTILITIES COMMISSION
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Irion Sanger(ISB No. 12488)
Sanger Law, PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Northwest and Intermountain Power Producers Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION ) CASE NO. GNR-E-25-01
STAFF'S APPLICATION FOR APPROVAL )
OF AN OVERSIGHT PROCESS FOR THE ) NORTHWEST & INTERMOUNTAIN
ACQUISITION OF LARGE SUPPLY-SIDE ) POWER PRODUCERS COALITION'S
PETITION TO INTERVENE
ELECTRICAL RESOURCES )
Northwest& Intermountain Power Producers Coalition("NIPPC") hereby petitions to
intervene as a party to this proceeding under Idaho Public Utilities Commission ("Commission")
Rule of Procedure, Rule 71, IDAPA 31.01.01.071.
In support of its Petition to Intervene, NIPPC states as follows:
1. The name and address of this Intervenor is:
Northwest& Intermountain Power Producers Coalition
c/o Spencer Gray
Executive Director
P.O. Box 504
Mercer Island, WA 98040
[e-mail]
NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION TO
INTERVENE
GNR-E-25-01 —PAGE 1

Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Gregory M. Adams, Irion A. Sanger, Spencer Gray
at the email addresses noted above.
2. NIPPC is a trade association whose members and associate members include
independent power producers active in the Pacific Northwest and Western energy markets.'
NIPPC's organizational purpose is to represent the interests of its members in developing rules
and policies that help achieve a competitive electric power supply market in the Pacific
Northwest. NIPPC has participated in numerous regulatory proceedings related to requests for
proposals ("RFPs"), bidding guidelines, and competitive markets before state regulatory
commissions in the Northwest and before the Federal Energy Regulatory Commission. Thus,
NIPPC's intervention will assist the Commission in resolving the issues present in this case.
3. NIPPC has a substantial interest in this proceeding in particular because
Commission Staff proposes to modify the previously approved competitive bidding requirements
in Idaho for utilities' acquisition of the major generation resources. NIPPC was an active party
in the underlying Idaho docket that resulted in this Commission's directive that Idaho Power
Company must adhere to the competitive bidding rules of the Oregon Public Utility Commission.
Thus,NIPPC has a direct interest in Commission Staff's request to replace that requirement with
its newly proposed bidding requirements. NIPPC's interests are not adequately represented by
' NIPPC's members include but are not limited to: Apex Clean Energy, Avangrid
Renewables, Aypa, Brookfield Renewable, Calpine Corp., Capital Power, Clearway,
Constellation, Cypress Creek Renewables, DG Energy Partners, EDF Renewable Energy, EDP
Renewables, Enel Green Power, esVolta, Invenergy LLC, Morgan Stanley,NextEra Energy,
NRG Energy, Obsidian Renewables, Pattern, Pine Gate Renewables, Qcells, Rye Development,
Shell Energy North America, and TransAlta.
NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION TO
INTERVENE
GNR-E-25-01 —PAGE 2

any other party in this proceeding.
4. Without being granted party status,NIPPC's right to fully participate in this
proceeding may be materially compromised.
5. This Petition to Intervene is timely filed under Rule 73, IDAPA 31.01.01.073,
because the Commission has not yet held a hearing or procedural conference, and the
Commission has not established a deadline for intervention. Thus, granting NIPPC's Petition to
Intervene will not unduly broaden the issues beyond their proper scope, nor will it unduly
prejudice any party to this case.
WHEREFORE,NIPPC respectfully requests that this Commission issue an order
granting NIPPC's Petition to Intervene.
Respectfully submitted this 7th day of April, 2025.
RICHARDSON ADAMS, PLLC
Gregory M. Adams (ISB No. 7454)
515 N. 271h Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Irion Sanger(ISB No. 12488)
Sanger Law, PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Northwest and Intermountain Power
Producers Coalition
NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION TO
INTERVENE
GNR-E-25-01 —PAGE 3

CERTIFICATE OF SERVICE
I HEREBY certify that I have on this 7th day of April, 2025, served the foregoing
Petition to Intervene by electronic mail to the following:
Monica Barios-Sanchez David Meyer
Commission Secretary Avista Corporation
Idaho Public Utilities Commission PO Box 3727
P.O. Box 83720 1411 East Mission Avenue
Boise, ID 83720-0074 Spokane, WA 99220-3727
[e-mail] [e-mail]
[e-mail]
Chris Burdin
Deputy Attorney General Mark Alder
Idaho Public Utilities Commission Joe Dallas
P.O. Box 83720 Rocky Mountain Power
Boise, ID 83720-0074 1407 West North Temple, Ste 330
[e-mail] Salt Lake City, UT 84116
[e-mail]
Donovan Walker [e-mail]
Idaho Power Company
1121 W. Idaho Street
PO Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
By:
Greg ry M. Adams (ISB No. 7454)
NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION TO
INTERVENE
GNR-E-25-01 —PAGE 4