20250902Petition to Intervene.pdf

RECEIVED
September 2, 2025
Irion Sanger, ISB No. 12488 IDAHO PUBLIC
Sanger Greene PC UTILITIES COMMISSION
4031 SE Hawthorne Blvd.
Portland, OR 97214
Tel: [phone]
Fax: [phone]
[e-mail]
Counsel for Renewable Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF IDAHO POWER ) Case No. IPC-E-25-23
COMPANY'S 2025 INTEGRATED )
RESOURCE PLAN ) RENEWABLE ENERGY
COALITION'S PETITION TO
INTERVENE
COMES NOW the Renewable Energy Coalition ("REC") and hereby requests
leave to intervene in the above captioned matter pursuant to the Idaho Public Utilities
Commission(the "Commission") Rules of Procedure, IDAPA 31.01.01.071-073. As
discussed below, REC has a direct and substantial interest in these proceedings, and
therefore should be granted intervention.
In support of this Petition, REC states as follows:
1. The name and address of REC is:
Renewable Energy Coalition
c/o John R. Lowe
P.O. Box 25576
Portland, OR 97298
E-Mail: [e-mail]
2. REC will be represented in this proceeding by Sanger Greene, P.C. All
documents relating to these proceedings should be served on the following persons at the
addresses listed:
REC PETITION TO INTERVENE Page 1

Irion Sanger
Sanger Greene, P.C.
4031 SE Hawthorne Blvd.
Portland, OR 97214
E-Mail: [e-mail]
And, for documents served electronically,please also add:
[e-mail]
[e-mail]
[e-mail]
3. REC is a coalition of Idaho and northwest qualifying facility("QF")
power producers that have interconnection and power purchase agreements ("PPAs")
with Idaho investor owned utilities, or who may seek to interconnect and enter into PPAs
with Idaho utilities, including Idaho Power. REC's members own and operate over fifty
renewable energy generation facilities in Idaho, Montana, Oregon, Washington, Utah, and
Wyoming. Several types of entities are members of REC, including irrigation districts,
water districts, corporations, and individuals. The majority of the individual QFs are
small hydroelectric projects. Most of REC's members operate existing projects that have
been operating and selling to Idaho utilities for numerous years. Some may be
considering new projects or acquiring existing ones.
4. REC has a direct and substantial interest in this proceeding that will not be
adequately represented by any other party. The Integrated Resource Plan ("IRP")
represents Idaho Power's commitment to develop a long-term resource plan that
considers cost, risk, uncertainty, and the long-run public interest. The IRP will form the
foundation for Idaho Power's future generation, demand side management, and
transmission investments.
REC PETITION TO INTERVENE Page 2

5. The IRP will impact Idaho Power's retail rates as well as its avoided cost
rates for QFs that sell power under the Public Utility Regulatory Policies Act
("PURPA"). REC's members are QFs that have (or intend to have)power purchase
agreements with Idaho utilities with rates based on its avoided costs.
6. REC has participated in numerous regulatory proceedings in the
Northwest intended to promote competitive markets, PURPA, renewable energy, and
diversity of generation ownership, including all the recent major proceedings regarding
qualifying facility contract and rate eligibility. REC's intervention will assist the
Commission in resolving the issues and will not unreasonably broaden the issues,
burden the record, or delay this proceeding. Finally, REC's interest is not adequately
represented by any other party in this proceeding.
7. Without the opportunity to intervene herein, REC would be without a
manner or means of participating in the lawful determination of issues which may affect
the ability of REC members to contract with Idaho Power.
WHEREFORE, REC respectfully requests that the Commission grant its petition
to intervene with full party status 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, cross-examine witnesses, present argument, and to otherwise fully participate
in the proceedings.
REC PETITION TO INTERVENE Page 3

Dated this 2nd day of September 2025.
Respectfully submitted,
- Aw� -
Irion A. Sanger, ISB No. 12488
Sanger Greene, PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Telephone: [phone]
Fax: [phone]
[e-mail]
Of Attorneys for REC
REC PETITION TO INTERVENE Page 4

CERTIFICATE OF DELIVERY
I HEREBY CERTIFY that on this 2nd day of September, 2025, 1 caused to be served
a true and correct copy of the foregoing document upon the following individuals in the
manner indicated below:
Electronic Mail Only(See Order No. 35058):
Idaho Public Utilities Commission
Commission Secretary
secretary�ic,puc.idaho.gov
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
Tim Tatum
Riley Maloney
m goicoecheaallen&idahopower.com
dwalker(cr�,idahopower.com
dockets(kidahopower.com
ttatum(kidahopower.com
rmaloney&idahopower.com
Idaho Irrigation Pumpers Association
Eric L. Olsen
Lance Kaufman
elo(kechohawk.com
taysha(k echohawk.com
lance(c�r�,aeginsi hg t
Micron Technology
Austin Rueschhoff
Thorvald A.Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland&Hart, LLP
darue schhoff khol landhart.c om
tnelsonghollandhart.com
awj ensen(cr�,hollandhart.com
karoach&hollandhart.com
aclee&hollandhart.com
tlfriel(cr�,hollandhart.com
REC PETITION TO INTERVENE Page 5

NW Energy Coalition and Renewable Northwest
Lauren McCloy
Derek Goldman
Mike Goetz
Kathie Chamberlain
Kyle Unruh
lauren&nwenergy.org
derekknwenergy.org
mike&renewablenw.org
katherine(krenewablenw.org
kyle&renewablenw.ora
Irion A. Sanger
REC PETITION TO INTERVENE Page 6