20250501Petition to Intervene.pdf

RECEIVED
May 01, 2025
Gregory M. Adams, ISB No. 7454 IDAHO PUBLIC
Richardson Adams, PLLC UTILITIES COMMISSION
515 N. 27th Street
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]
Rose Monahan, CA Bar No. 329861 (pro hac vice pending)
Sierra Club
2101 Webster Street, Suite 1300
Oakland, California 94612
Phone: [phone]
Email: [e-mail]
Attorneys for Sierra Club and Vote Solar
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 GENERATION PETITION TO INTERVENE OF
CUSTOMERS FROM DUNE 1, 2025 SIERRA CLUB AND VOTE
THROUGH MAY 31, 2026, SOLAR
INCOMPLIANCE WITH ORDER NO. 36048
COMES NOW the Sierra Club and Vote Solar and hereby requests leave to intervene in
the above captioned matter pursuant to the Idaho Public Utilities Commission Rules of
Procedure, IDAPA 31.01.01.071-073. As discussed below, Sierra Club and Vote Solar have
direct and substantial interests in these proceedings, and therefore should be granted intervention.
1. The name and address of Sierra Club's national headquarters is:
Sierra Club
2101 Webster Street, Suite 1300
Oakland, California 94612
[phone]
[e-mail]
IPC-E-25-15
Sierra Club and Vote Solar Petition to Intervene 1

2. The name and address of Vote Solar's national headquarters is:
Vote Solar
2443 Fillmore Street#380-1375
San Francisco, CA 94115
[phone]
[e-mail]
3. The Sierra Club is a national non-profit environmental and conservation association
incorporated under the laws of the State of California. Sierra Club is dedicated to the
protection of public health and the environment. Sierra Club petitions to intervene in this
proceeding on behalf of itself and its approximately 2,325 members who live and
purchase utility services in Idaho, many of whom are residential customers of Idaho
Power Company. Sierra Club claims a direct and substantial interest in this proceeding on
behalf of its members who are customers of Idaho Power Company, including members
who are currently net billing customers or who wish to become net billing customers in
the future, because the outcome will impact customer rates for rooftop solar production
that is exported to Idaho Power's system.
4. Vote Solar is a national non-profit organization incorporated under the laws of the State
of California. Vote Solar claims a direct and substantial interest in this proceeding on
behalf of itself and its 213 members in Idaho, many of whom are customers of Idaho
Power and/or are Idaho Power net billing customers. Vote Solar's mission is to realize a
100% clean energy future through a solutions-driven,people-first approach. Vote Solar
focuses on solar energy because it is plentiful, low cost, and has a unique ability to allow
energy users to play a direct and critical role in energy production. Vote Solar advocates
across the country for rooftop solar export rates that fairly compensate rooftop solar
owners for the value that they provide to their local utility's electric system. Vote Solar's
IPC-E-25-15
Sierra Club and Vote Solar Petition to Intervene 2

expertise in rooftop solar compensation from engagement in similar proceedings across
the country will provide valuable insight to the Commission's evaluation of Idaho
Power's request to significantly reduce its export credit rate.
5. Sierra Club and Vote Solar will jointly respond to Idaho Power Company's request to
significantly decrease the current export credit rate for rooftop solar customers, and thus
will not unduly broaden the issues or prejudice any party to this case.
6. Sierra Club and Vote Solar intend to participate herein as a joint party by submitting
comments on Idaho Power's application, and, if necessary, by introducing evidence,
cross-examining witnesses, calling and examining witnesses, and being heard in
argument.
7. Sierra Club and Vote Solar further join Clean Energy Opportunities for Idaho's ("CEO")
request for the Commission consider whether comment deadlines should be moved
further into the future from May 15, 2025. As CEO notes, this proceeding concerns
technical issues in which discovery would be greatly beneficial,but the May 15, 2025
deadline for comments does not provide sufficient time to engage in discovery. Should
additional time be granted, Sierra Club and Vote Solar would potentially engage in
discovery and would be better able to provide more thorough comments to the
Commission.
8. Sierra Club and Vote Solar request that copies of all future pleadings, production
requests, production responses, Commission orders, and other documents to the names
and addresses listed below. In the interest of conserving natural resources and reducing
the costs to all parties,please provide copies of all documents via electronic mail in
accordance with IDAPA Rules 31.01.01.063.02-03.
IPC-E-25-15
Sierra Club and Vote Solar Petition to Intervene 3

Rose Monahan
Sierra Club
2101 Webster Street, Suite 1300
Oakland, California 94612
[phone]
[e-mail]
Kate Bowman
Vote Solar
299 S. Main St.
Suite 1300, PMB 93601
Salt Lake City, UT 84111
[phone]
[e-mail]
WHEREFORE, Sierra Club and Vote Solar respectfully request that this Commission
grant their Petition to Intervene in these proceedings and to appear and participate in all matters
as may be necessary and appropriate; and to present evidence, call and examine witnesses,
present argument, and to otherwise fully participate in these proceedings. Sierra Club and Vote
Solar further respectfully request that this Commission consider extending the comment deadline
beyond May 15, 2025, for a minimum of an additional thirty days to provide comment.
DATED this 1 st day of May, 2025
Gregory M. Adams
ISB No. 7454
Rose Monahan,
CA Bar No. 329861 (pro hac vice pending)
Attorneys for Sierra Club and Vote Solar
IPC-E-25-15
Sierra Club and Vote Solar Petition to Intervene 4

CERTIFICATE OF SERVICE
I hereby certify that on this Pt day of May 2025, I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following persons via the method of service
indicated below:
Electronic mail only(see Order 35375)
Idaho Public Utilities Commission
Monica Barrios-Sanchez, Secretary
[e-mail]
Erika K. Melanson
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
[e-mail]
[e-mail]
docketsn idahopower.com
Individual Intervenor
Kevin Dickey
[e-mail]
Clean Energy Opportunities for Idaho ("CEO')
Kelsey Jae
[e-mail]
Gregory M. Adams