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HomeMy WebLinkAbout20250822Petition to Intervene.pdf Benjamin J. Otto, ISB No. 8292 RECEIVED 1407 W Cottonwood Crt. August 22, 2025IDAHO PUBLIC Boise, Idaho 83702 UTILITIES COMMISSION Telephone: (208) 724-1585 Ben@nwenergy.org Attorney for the Northwest Energy Coalition and Renewable Northwest BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER CASE NO. IPC-E-25-23 COMPANY'S 2025 INTEGRATED PETITION TO INTERVENE RESOURCE PLAN. OF THE NORTHWEST ENERGY COALITION AND RENEWABLE NORTHWEST COMES NOW, The Northwest Energy Coalition and Renewable Northwest, hereinafter referred to as "NWEC/RNW," under Commission Rules of Procedure, IDAPA 31.01.01.71 - .73, with this petition for leave to intervene herein and participate as a party. Based on the information detailed below, we respectfully request that the Commission grant this Petition. 1. The name and address of this Intervenor is: Northwest Energy Coalition Renewable Northwest c/o Benjamin J. Otto 1407 W Cottonwood Crt. Boise, Idaho 83702 Telephone: (208) 724-1585 ben@nwenergy.org Copies of all pleadings,production requests,production responses, Commission orders and other documents should be provided to Benjamin Otto as noted above, as well as: Lauren McCloy,NWEC Utility and Regulatory Director, lauren@nwenergy.org Derek Goldman,NWEC Policy Associate, derek@nwenergy.org Mike Goetz, RNW Regulatory Affairs Director, mike@renewablenw.org Katie Chamberlin, RNW Regulatory Manager, katherine@renewablenw.org Kyle Unruh, RNW Director, Montana and Idaho, kyle@renewablenw.org 2. The Northwest Energy Coalition (NWEC) is a 501c3 public interest organization with individual and organizational members in Idaho, Montana, Oregon, and Washington with a decades-long interest in advocating for reliable and affordable energy that protects the natural NWEC/RNW Petition to Intervene page I IPC-E-25-23 values important to residents of the Northwest. NWEC seeks to intervene in this matter on behalf of our Idaho members, both individual and entities, who are residential and small commercial customers of Idaho Power. NWEC claims a direct and substantial interest in this proceeding in to protect the interests of its members in ensure robust, fair, and transparent planning for future resource needs. 3. Renewable Northwest (RNW) is a 5010 public interest organization with members in Idaho, Montana, Oregon, and Washington, with a decades-long interest in promoting cost-effective and reliable renewable energy options across the northwest. RNW's membership consists of public interest groups,renewable energy developers and technology providers with existing and potential projects capable of meeting Idaho Power's needs. RNW seeks to intervene in this docket to protect its members' direct and substantial interest in ensuring a fair and adequate opportunity for independent power providers to inform Idaho Power's planning process and contribute to meeting the needs of Idaho Power's customers. 4. NWEC and RNW intend 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 that NWEC and RNW will introduce depend upon the nature and effect of other evidence in this proceeding. 5. Without the opportunity to intervene herein,NWEC and RNW would be deprived of the most effective and efficient means to participate fully in this proceeding, which may have a material impact on the type and amount of new resources, both customer side and supply side, needed to meet future needs. NWEC and RNW have a long history of engaging with Idaho Power and other utilities across the Northwest on issues related to their operations. Our organizations and members have strong interests in fair and accurate representation of resource needs, options, costs, risks, and assessment of the most cost-effective future portfolio of resources, both customer side and supply side, as well as balancing between utility-owned and independent providers. These interests are unique to our organization and members and not adequately represented by any current intervening parry. WHEREFORE,NWEC and RNW respectfully request that the Commission grant this Petition to Intervene and allow NWEC and RNW to participate fully in this proceeding. Respectfully submitted this 22nd day of August, 2025,by Benjamin J. Otto ISB No 8292 Attorney for NWEC and RNW NWEC/RNW Petition to Intervene page 2 IPC-E-25-23 CERTIFICATE OF SERVICE I hereby certify that on this 22nd day of August 2025, I delivered true and correct copies of the foregoing PETITION TO INTERVENE of NWEC and RNW in IPUC Docket No. IPC-E-25-23 to the following persons according to Rule 61.03 via electronic mail only. /'ff ,��/�' Benjamin J. Otto ISB No 8292 Attorney for NWEC Idaho Power Company Idaho Public Utilities Commission Megan Goicoechea Allen Monica Barros-Sanchez Donovan E. Walker Commission Secretary Timothy Tatum secretary@puc.idaho.gov Riley Maloney mgoicoecheaallen@idahopower.com Idaho Irrigation Pumpers Association dwalker@idahopowcr.com Eric L. Olsen dockets@idahopower.com Lance Kaufman ttatum@idahopower.com elo@echohawk.com rmaloney@idahopower.com lance@aegisinsight.com mbabbitt@idahopower.com Micron Technology, Inc Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen Kristine A.K. Roach Holland&Hart, LLP darueschhoff@hollandhart.com tnelson@hollandhart.com awjensen@hollandhart.com karoach@hollandhart.com aclee@hollandhart.com tlfriel@hollandhart.com NWEC/RNW Petition to Intervene page 3 IPC-E-25-23