20250819Petition to Intervene.pdf

RECEIVED
August 19, 2025
Andrew P. Moratzka(pro hac vice forthcoming) IDAHO PUBLIC
[e-mail] UTILITIES COMMISSION
STOEL RIVES LLP
33 South 6th Street
Minneapolis, MN 55402
Telephone: [phone]
Facsimile: 612.373.8881
W. Christopher Pooser, ISB No. 5525
[e-mail]
Alaina Harrington, ISB No. 11879
[e-mail]
STOEL RIVES LLP
101 S. Capitol Boulevard, Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: 208.3 89.9040
Attorneys for Idaho Forest Group LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION Case No. CIO-E-25-01
OF NORTHERN LIGHTS, INC. AND THE
CITY OF BONNERS FERRY FOR AN IDAHO FOREST GROUP LLC'S
ORDER APPROVING A SERVICE PETITION TO INTERVENE
TERRITORY AGREEMENT BETWEEN
THE APPLICANTS
Idaho Forest Group LLC ("IFG")petitions the Idaho Public Utilities Commission for leave
to intervene in the above entitled proceeding (the "Application") pursuant to Rules 72 and 73 of
the Commission's Rules of Practice and Procedure, IDAPA 31.01.01.072 and-.073. In support of
this Petition, IFG states as follows:
1. IFG has two facilities that could be impacted in the proceeding — one in Moyie Springs,
Idaho("Moyie Springs Mill") and another in Laclede, Idaho ("Laclede Mill"). The Moyie
Springs Mill presently takes electric service from the City of Bonners Ferry (the "CBF").
The Laclede Mill presently takes service from Northern Lights, Inc. ("NLI,"together with
CBF, "Applicants").
2. The address for the Moyie Springs Millis 3082 E Roosevelt, Moyie Springs, ID 83845.
3. The address for the Laclede Millis 30 Riley Creek Park Dr, Laclede, ID 82841.

4. IFG has a direct and substantial interest in these proceedings because any decision from
the Commission in this proceeding could directly and prejudicially affect the outcome of
an appeal filed by IFG, presently pending before the Idaho Supreme Court, that includes
this very issue regarding service territories of the filing parties and the service to IFG's
plant at Moyie Springs. In addition, this proceeding could directly or indirectly impact
IFG's electric rates and/or quality of electric service.
5. Given the short period of time IFG has had to review the Application, as well as the fact
that Applicants concede the information allegedly supporting the Application is obsolete,
IFG is unable to fully and adequately state its position or present all of its concerns and
arguments about this application at this stage of the proceedings. IFG nonetheless
endeavors to provide the high-level commentary IFG set forth in its comment dated August
19, 2025 ("Comment"). And IFG seeks to intervene for the purpose of receiving
documents, examining witnesses, and otherwise participating as appropriate in the
developments in this case. IFG reserves the right to supplement or modify the positions
set forth in its Comment.
6. IFG's representatives for the purpose of service of pleadings and other written materials
are as follows:
Andrew P. Moratzka(pro hac vice forthcoming)
[e-mail]
STOEL RIVES LLP
33 South 6th Street
Minneapolis, MN 55402
Telephone: [phone]
Facsimile: 612.373.8881
W. Christopher Pooser, ISB No. 5525
[e-mail]
Alaina Harrington, ISB No. 11879
[e-mail]
STOEL RIVES LLP
101 S. Capitol Boulevard, Suite 1900
Boise, ID 83702
Telephone: [phone]
Facsimile: 208.3 89.9040

Jesse Short, Director of Idaho Lumber Production
Idaho Forest Group
687 Canfield Ave., Suite 100
Coeur d'Alene, ID 83815
Telephone: [phone]
Email:[e-mail]
Christopher Pease, Plant Manager
Idaho Forest Group
3082 Roosevelt Road
Moyle Springs, ID 83845
Telephone: [phone]
Email: [e-mail]
Larry Crowley. Director
The Energy Strategies Institute
3738 S Harris Ranch Ave
Boise. ID 83716
Telephone: [phone]
Email: [e-mail]
7. This Petition is timely filed and will not unduly broaden the issues or otherwise delay these
proceedings.
WHEREFORE, IFG respectfully requests that the Commission grant this Petition to
Intervene and authorize IFG to participate in the above-entitled proceedings with full rights as a
formal party.
DATED: August 19, 2025 STOEL RIVES LLP
By: /s/W. Christopher Pooser
W. Christopher Pooser
Andrew P. Moratzka
Attorneys for Idaho Forest Group LLC

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 19, 2025, I served a true and correct copy of the
IDAHO FOREST GROUP LLC'S PETITION TO INTERVENE upon the following by
electronic mail only:
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83702
[e-mail]
Susan P. Weeks
James, Vernon, & Weeks, P.A.
1626 Lincoln Way
Coeur d'Alene, ID 83834
[e-mail]
Tyler R. Whitney
Cable Huston LLP
1455 SW Broadway, Ste 1500
Portland, OR 97201-3412
[e-mail]
/s/W. Christopher Pooser
W. Christopher Pooser
150053169.6 0026695-00011