20250422Petition to Intervene.pdf

RECEIVED
April 22, 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 ITS FIRST )
ANNUAL UPDATE TO THE ) CASE NO. IPC-E-25-15
EXPORT CREDIT RATE FOR )
NON-LEGACY ON-SITE ) CLEAN ENERGY OPPORTUNITIES
GENERATION CUSTOMERS FROM ) FOR IDAHO PETITION TO
JUNE 1, 2025 THROUGH MAY 31, ) INTERVENE
2026, IN COMPLIANCE WITH )
ORDER NO. 36048 )
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
courtney0cleanenergyopportunities.com
mike cleanenergyopportunities.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-25-15

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 several dockets where matters related to cost causation and rate design
have been addressed. 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 that will
be 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.
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,
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 2
IPC-E-25-15

examine, and cross-examine witnesses. CEO intends to seek intervenor funding pursuant to
IDAPA 31.01.01.161-165.
6. CEO further requests that the Commission consider whether the comment
deadline could be moved to a later time than May 15, 2025, the date mentioned in Staff's April
15 Decision Memo. CEO questions whether the estimated quantity and cost of regulating
reserves needed to integrate ECR exports are accurately reflected by the utility-scale generation
inputs used in the VER study, noting:
• Exports from 13,800 non-legacy customer sites may have different output
variability compared to a limited number of utility-scale sites.
• Fixed panels on residences may have different diurnal and seasonal output
patterns compared to tracking systems at utility-scale sites.
• ECR applies to exports, the VER study was apparently based upon gross
generation.
Resolving such technical issues will likely require CEO to submit discovery requests to
Idaho Power. The May 15 comment cut-off would conflict with CEO's ability to submit, review,
analyze and respond with comments relevant to these issues.
WHEREFORE, CEO respectfully requests the Commission grant this petition.
FURTHERMORE, CEO respectfully requests that the Commission consider whether
comment deadlines could be moved to a more appropriate time, further into the future.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 3
IPC-E-25-15

DATED this 22nd day of April, 2025.
Respectfully submitted,
P��
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 4
IPC-E-25-15

CERTIFICATE OF SERVICE
I hereby certify that on this 22nd day of April, 2025, 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
Mary Alice Taylor
Regulatory Dockets
mmgoicoe [e-mail]
dwalkerOidahopower.com
caschenbrennerP idahopower.com
mtaylor idahopower.com
dockets Ca)idahopower.com
Kevin Dickey
bellefourcheO l O gmail.com
'U
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 5
IPC-E-25-15