20250515Petition to Intervene.pdf

RECEIVED
May 15,2025
IDAHO PUBLIC
UTILITIES COMMISSION
Tyler Grange
6149 Meeker Place
Boise ID 83713
208-997-6527
Tyler(@idahomeenergy com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ITS ) CASE NO. IPC-E-25-15
FIRST ANNUAL UPDATE TO THE EXPORT )
CREDIT RATE FOR NON-LEGACY ON- ) PETITION TO INTERVENE
SITE GENERATION CUSTOMERS FROM ) OF TYLER GRANGE
JUNE 1, 2025 THROUGH MAY 31, 2026 IN )
COMPLIANCE WITH ORDER NO. 36048 )
Tyler Grange ("Grange" or "Intervenor"), pursuant to the Commission's Rule of Procedure 71
through 74, hereby petitions the Commission for leave to intervene and to appear and
participate in this proceeding as a party, and as grounds therefore states:
1. The name and address of this Intervenor is:
Tyler Grange
6149 Meeker Place
Boise ID 83713
208-997-6527
Tyler@ idahomeenergy.com
Copies of all pleadings, production requests, production responses, Commission
orders, and other documents should be provided to the names and addresses listed above. 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.
2. Grange receives electric utility services from Idaho Power Company ("Idaho Power")
and has a direct and substantial interest in this proceeding. He is intervening in case
IPC-E-25-15 because the proposed changes by Idaho Power could significantly and
negatively impact solar customers and the broader clean energy economy in Idaho.
As a solar installer and advocate for homeowner energy independence, he believes this
proposal threatens the long-term financial viability of solar investments, undermines
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TYLER GRANGE
PETITION TO INTERVENE
IPC-E-25-15

customer confidence, and sets a dangerous precedent for how distributed energy
resources are valued. These changes could unfairly penalize existing and future solar
users, reducing the return on their investment and potentially stalling growth in a critical
sector that supports local jobs, innovation, and grid resilience.
Grange is intervening to ensure that customer voices are heard, economic fairness is
preserved, and Idaho continues to encourage responsible, forward-thinking energy
policy.
3. Grange intends to participate herein as a party, and if necessary, to introduce
evidence, cross-examine witnesses, call and examine witnesses, and be heard in
argument. The nature and quality of evidence Grange will introduce is dependent upon
the nature and effect of other evidence in this proceeding.
4. Granting Grange's Petition to Intervene will not unduly broaden the issues, nor will it
prejudice any party to this case.
5. Without the opportunity to intervene, Grange would be without adequate means to
participate in this proceeding that may have a material impact on his family's electric
expenses and his business.
6. Grange respectfully requests that the Commission grant this Petition to Intervene
despite its filing after the intervention deadline. Due to the demands of managing
ongoing solar projects and assisting his customers impacted by rising energy costs, and
the short timeline between the filing of this case and the intervention deadline (which
was not posted), Grange was unable to respond to Idaho Power's application in this
docket by the original deadline.
Upon reviewing the testimony in this case, Grange believes his position is unique from
the other intervenors because it represents a direct voice from a locally owned and
operated solar installation company with firsthand insight into how Idaho Power's
proposed changes will impact both current and prospective residential solar customers.
Unlike policy-focused or other individual intervenors, Grange brings the perspective of
an active service provider who sees daily how utility policy affects customer decisions,
financial feasibility, and clean energy adoption in real time.
For that reason, Grange has determined that it is in his best interest to intervene in this
case. Grange's participation can offer practical, data-driven insights that are not
currently represented in the docket.
w
y
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TYLER GRANGE
PETITION TO INTERVENE
IPC-E-25-15

Grange believes that granting this late intervention will not prejudice any other parties
to the matter or cause unnecessary delay. Grange agrees to accept the existing record
and current schedule for this proceeding as it stands.
WHEREFORE, Tyler Grange respectfully requests that the Commission grant his Petition
to Intervene in this proceeding 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 this proceeding.
DATED this 14th day of May, 2025
I ra n
t
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TYLER GRANGE
PETITION TO INTERVENE
IPC-E-25-15

CERTIFICATION OF SERVICE
I hereby certify that on 5/14/2025, a true and correct copy of the within and
foregoing PETITION TO INTERVENE OF TYLER GRANGE IN CASE NO. IPC-E-25-15 was
served in the manner shown to:
Electronic Mail
Idaho Power Company Commission Staff
Megan Goicoecha Allen Monica Barrios-Sanchez
Donovan E. Walker Commission Secretary
Connie Achenbrenner [e-mail]
Mary Alice Taylor
mp,oicoeacheaallen(@idahopower.com Clean Energy Opportunities for Idaho
dwalkerPidahopower.com Kelsey Jae
[e-mail] [e-mail]
caschenbrennerPidahopower com
[e-mail] Sierra Club & Vote Solar
Gregory M. Adams
Individual Intervenors Rose Monahan
Kevin Dickey [e-mail]
[e-mail] [e-mail]
Martha Bibb
[e-mail] City of Boise
Scott Pinizzotto Jessica Harrison
[e-mail] [e-mail]
[e-mail]
yler Grang
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TYLER GRANGE
PETITION TO INTERVENE
IPC-E-25-15