20250617Petition to Intervene.pdf

RECEIVED
June 17, 2025
Emily W. Medlyn IDAHO PUBLIC
Jelani A. Freeman UTILITIES COMMISSION
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
[e-mail]
Attorneys for the Federal Executive Agencies
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-25-16
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES ) THE FEDERAL EXECUTIVE
AND CHARGES FOR ELECTRIC ) AGENCIES' PETITION TO
SERVICE IN THE STATE OF IDAHO ) INTERVENE
THE FEDERAL EXECUTIVE AGENCIES' PETITION TO INTERVENE
The United States Department of Energy ("DOE"), on behalf of itself and other federal
executive agencies (together, the "Federal Executive Agencies" or "FEA"), hereby petitions the
Idaho Public Utilities Commission (the "Commission") pursuant to Rules 71, 72, and 73 of the
Commission's Rules of Procedure,to intervene and become a party in this proceeding. In support
of this petition, DOE states:
1. The name and address of the Petitioner is:
Federal Executive Agencies
c/o U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
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Copies of all pleadings, production requests, production responses, Commission orders,
and other documents should be provided to:
Emily W. Medlyn Dwight Etheridge
Jelani A. Freeman Exeter Associates, Inc.
U.S. Department of Energy 10480 Little Patuxent Parkway
1000 Independence Ave., S.W. Suite 300
Washington, D.C. 20585 Columbia, MD 21044
Phone: [phone] Phone: [phone]
emily.medlyn&hq.doe._og_v detheridge&exeterassociates.com
j elani.freeman(khq.doe.gov
2. FEA has a direct and substantial interest in the subject matter of this proceeding. FEA
consists of agencies of the United States Government that have offices, facilities, and installations,
including the Idaho National Laboratory ("INL") and Mountain Home Air Force Base, that
purchase electricity from Idaho Power Company ("IPC"). INL is one of IPC's largest customers
and is a"special contract" customer under IPC's retail electric tariff.
3. FEA intends to participate in this proceeding as a party in all respects that may be
required for it to represent its interests, including submission of direct and responsive testimony,
examination and cross-examination of witnesses, submission of briefs, and presentation of and
response to motions and oral argument.
4. Granting FEA'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, FEA could not participate in the lawful
determination of issues which will have a material effect on the rates, terms, and conditions under
which it receives service.
6. DOE has been delegated authority by the General Services Administration to represent
the consumer interest of the FEA in this proceeding under 40 U.S.C. §§ 501(c) and 121(d).
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Consistent with Rule 5.5 of the Idaho Rules of Professional Conduct and Commentary note [1],
the appearance of a lawyer authorized by federal statute or other federal law to represent the
interests of the United States before an Idaho tribunal does not constitute the unauthorized practice
of law, even though such lawyer is not admitted to the bar of Idaho or through pro hac vice
admission. Emily Medlyn is an active member, in good standing, of the bar of South Carolina and
is an attorney employed by DOE. Jelani Freeman is an active member, in good standing of the
bars of District of Columbia, New Jersey, New Mexico, New York, and Texas. Neither Ms.
Medlyn nor Mr. Freeman is admitted to the bar of Idaho.
WHEREFORE, FEA respectfully requests that this Commission grant this Petition to
Intervene in this proceeding and to present evidence, call and examine witnesses, present
argument, and to otherwise fully participate in this proceeding.
Respectfully submitted, this 17th day of June 2025.
FEDERAL EXECUTIVE AGENCIES
BY THE U.S. DEPARTMENT OF ENERGY
Ck A 111�-71� _
Emily W. Medlyn
Attorney-Adviser
Emily W. Medlyn
Jelani A. Freeman
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-25-16
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES ) THE FEDERAL EXECUTIVE
AND CHARGES FOR ELECTRIC ) AGENCIES' CERTIFICATE
SERVICE IN THE STATE OF IDAHO ) OF SERVICE
I CERTIFY that on this date I sent by email a true and correct copy of THE FEDERAL
EXECUTIVE AGENCIES' PETITION TO INTERVENE on the parties of record to this
proceeding.
DATED June 17, 2025.
Emily W. Medlyn
Attorney-Adviser
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
Phone: [phone]
[e-mail]
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