20251215Petition for Intervenor Funding.pdf

RECEIVED
December 15, 2025
IDAHO PUBLIC
Kelsey Jae (ISB No. 7899) UTILITIES COMMISSION
Kelsey Jae LLC
521 E. 41st St.
Garden City, Idaho 83714
[phone]
[e-mail]
Attorney for Clean Energy Opportunities for Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER )
COMPANY FOR AUTHORITY TO ) CASE NO. IPC-E-25-16
INCREASE ITS RATES AND )
CHARGES FOR ELECTRIC ) CLEAN ENERGY OPPORTUNITIES
SERVICE IN THE STATE OF IDAHO ) FOR IDAHO'S PETITION FOR
AND AUTHORITY TO IMPLEMENT ) INTERVENOR FUNDING
CERTAIN MEASURES TO )
MITIGATE THE IMPACT OF )
REGULATORY LAG
COMES NOW Clean Energy Opportunities for Idaho ("CEO"), by and through its
attorney of record, Kelsey Jae of the firm Kelsey Jae LLC, pursuant to Idaho Code § 61-617A
and IDAPA 31.01.01.161-165 with the following request for intervenor funding. CEO is an
intervenor in this case pursuant to Order No. 36557. This request is timely under Rule 164
because this request is filed within the deadline set by the Public Utilities Commission ("PUC"
or "Commission").
I. Applicability of Idaho Code § 61-617A and IDAPA Rule 31.01.01.161
Idaho Power Company("Idaho Power" or the "Company") is a regulated public utility
that has gross Idaho intrastate annual revenues exceeding $3,500,000.00.
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II. IDAPA Rule 31.01 .01.162 requirements
A. Itemized list of expenses
Idaho Code provides that the Commission may award "legal fees, witness fees, and
reproduction costs"to intervenors in a proceeding. Idaho Code § 61-617A. The attached Exhibit
A is an itemized list of legal fees incurred by CEO's legal counsel assisting CEO with
investigating and responding to Idaho Power's Application; analyzing and conducting discovery;
preparing analyses, presentations, and proposals for review by other parties; meaningfully
participating in several meetings, negotiation sessions, and hearings; supporting the development
of the settlement stipulation; and filing of testimony. CEO focused its participation and input on
facts and issues that are directly relevant to this docket.
B. Statement of proposed findings
CEO signed the Settlement Agreement and requests that it be approved in its entirety.
Compromises were made during the process of negotiating a settlement agreement, as is the
nature of the process. CEO's support for the settlement was premised, in part, upon the inclusion
of the following:
• Stipulation term 8c, which modified the time periods for Schedules 9 and 19 time-of-use
("TOU") rates to better align with a low-cost time window during day hours when solar
supply is high relative to demand, and
• Stipulation term 10, which calls for a Class Cost of Service ("CCOS") case to include
study of an hourly informed class allocation of Production and Transmission revenue
requirement.
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CEO also asks the Commission to grant this request for intervenor funding.
C. Statement showing costs
CEO requests $2,974.80 in intervenor funding for attorney fees, as shown in Exhibit A.
These fees were incurred reasonably and appropriately. This case covered complex and technical
issues and required reviewing and responding to extensive analyses and/or proposals of the
Company, Commission Staff, and other active parties and community members. To uncover and
understand the facts, CEO reviewed multiple data sets; reviewed discovery requests and
submitted its own discovery requests; and engaged in lengthy analytic efforts internally and with
other parties. CEO and its legal counsel were active participants in all stages of the proceeding.
For each of these efforts, CEO endeavored to be efficient with time and delegation of tasks. CEO
maintained clear divisions of labor to reduce expenses. This request does not include hours
invested by CEO officers, Michael Heckler and Courtney White. CEO requests an hourly rate for
legal counsel of $222 per hour. For all these reasons, CEO's request for intervenor funding to pay
the costs of the listed attorney is reasonable.
D. Explanation of cost statement
CEO is a nonprofit organization. In this proceeding, CEO represented its directors and
supporters who are Idaho Power ratepayers. To provide consistent, professional, and impactful
advocacy, CEO dedicates significant time to energy issues and specifically to policy making at
the Commission. CEO has actively participated in prior proceedings on related matters. CEO
does not have any financial interest in the outcome of this proceeding.
The cost of this time and hiring legal counsel is a significant financial commitment and
hardship for a nonprofit organization. Because contributions to CEO are inherently unstable and
IPC-E-25-16 - CLEAN ENERGY OPPORTUNITIES FOR IDAHO -
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sometimes insufficient, the availability of intervenor funding is essential for CEO to participate
fully in these proceedings. CEO has no pecuniary interest in the outcome of this case; rather
CEO dedicated its time and resources to represent the interests of its supporters.
E. Statement of difference
In general, CEO's contribution to this docket differs from PUC Staff's due to both CEO's
leadership in presenting recommendations on matters that were not prioritized by PUC Staff and
due to CEO's different position on certain matters.
• Different priorities. In testimony supporting the IPC-E-25-16 settlement agreement,
PUC Staff witness Louis describes - in the context of supporting the CCOS single issue
case - that "trying to resolve CCOS in a general rate case is difficult due to the focus on
developing, and supporting,the revenue requirement as a first priority."' CEO entered the
docket with different priorities and took initiatives to ensure these matters were
addressed: to improve on the Company's traditional CCOS methodology and to improve
on the degree to which price signals can mitigate future costs.
• Different positions. CEO's positions at times differ materially from those of PUC Staff.
For example, PUC Staff's testimony stated a finding that the Company's CCOS study
was valid and could be used to allocate the revenue requirement for the settlement.z CEO
has consistently opposed the Company's sole reliance on its use of monthly observations
'Case No.IPC-E-25-16 Staff Witness Louis,M Direct Testimony(November 18, 2025), 5:9-11 (emphasis added).
2Case No.IPC-E-25-16 Staff Witness Louis,M Direct Testimony(November 18, 2025),4:16-24.
The CCOS study was used as the basis to spread the revenue requirement increase. Staff performed an
analysis showing that the costs included for recovery in this case are not driven by the need to provide
service for these new large-load customers as detailed in Staff Witness Suess'Testimony.This analysis
showed the validity of the CCOS study and that the results could be used to allocate the revenue
requirement for the Settlement.
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to determine the fair allocation of bulk power system costs.' E.g., CEO's Final Comments
filed in the 2023 General Rate case stated, "CEO believes that there shouldn't be another
rate case filed by the Company that is not informed by a cost to serve analysis reflecting
the costs to serve load in all hours of the test year.i4
Prior to this docket, the 2023 General Rate Case Settlement Agreement stipulated that
CEO would lead workshops related to development of hourly informed rate design and hourly
informed cost of service.5 CEO authored two follow-up reports: "Hourly Informed Rate Design"
and "An Hourly Informed Bulk Power System COS Alternative." CEO was able to leverage
findings from that process to lead the advocacy for certain improvements to price signals and to
CCOS in this rate case.6
If CEO had not intervened and had not presented compelling evidence on these topics, it
is unlikely that the settlement agreement would have included the stipulated modifications to
TOU time windows (term 8c) or the stipulated review of an hourly informed CCOS methodology
(term 10).
F. Statement of recommendation
CEO's recommendations focused on opportunities for price signals to improve long-term
affordability for all customers, and on opportunities to improve on the accuracy and fairness of
cost allocation methodologies.
a For background, consider CEO's finding stated in its report IPC-E-23-11 Follow-up:An Hourly Informed Bulk
Power System COS Alternative,distributed via email to IPC-E-23-11 parties,Dec 16, 2024:
When compared to the traditional 12CP/4CP method,the magnitude of differences in class allocations that
arise from use of an hourly informed cost of service method are substantial,challenging the appropriateness
of continuing to solely rely on a 12CP/4CP method,as it was employed in Idaho Power's 2023 General
Rate Case(GRC),in future general rate cases.
4 IPC-E-23-11,CEO Final Comments,p7.
s IPC-E-23-11, Settlement Agreement, Stipulation 13,p11.
s Note that CEO did not request or receive intervenor funding for the workshop related efforts.
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G. Statement showing class of customer
A component of CEO's mission is to bring problem-solving rigor and solution-focused
approaches to better serve the long-term interests of Idahoans and future generations. CEO's
engagement and testimony in this docket sought to serve the interests of customer classes which
CEO refers to in testimony as "small customers." These customer classes include Small General
Service (standard and on-site generators), Residential (standard, on-site generators, and Time of
Day), Master Mobile Home Park, and Agricultural Irrigation.
Based on the foregoing reasons, CEO respectfully requests that the Commission grant
this Petition for Intervenor Funding in the amount of$2,974.80 as illustrated in Exhibit A.
DATED this 15th day of December, 2025.
Respectfully submitted,
Kelsey Jae
Attorney for CEO
Exhibit A: Statement of Costs
IPC-E-25-16 - CLEAN ENERGY OPPORTUNITIES FOR IDAHO -
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Exhibit A: Statement of Costs
For attorney fees incurred by Kelsey Jae LLC
Analyzing Idaho Power's application and direct testimonies; 13.4 hours @
conducting relevant legal research; analyzing discovery requests and $222/hr
responses of other parties; drafting CEO discovery; crafting response
strategies, including comment/testimony/settlement strategies and
filings; participating in settlement conferences
Total 13.4 hours
$2,974.80
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CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of December, 2025. I delivered true and correct
copies of the foregoing PETITION FOR INTERVENOR FUNDING to the following persons via
the method of service noted:
Electronic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
Monica Barrios-Sanchez
Commission Secretary
secretary0puc.idaho.gov
Idaho PUC Staff
f
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
chris.burdin(@puc.idaho.gov
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
Connie Aschenbrenner
Grant Anderson
mgoicoecheaallenOidahopower.com
[e-mail]
caschenbrennerna idahopower.com
gandersonOidahopower.com
dockets idahopower.com
City of Boise
Ed Jewell
Katie O'Neil
BoiseCityAttorneyOcityofboise.org
ej ewellOcityof boise.org
koneilOcityofboise.org
Federal Executive Agencies
Emily W. Medlyn
Jelani A. Freeman
Dwight Etheridge
emily.med [e-mail]
j elani.freemanOhq.doe.gov
detheridgeCa)exeterassociates.com
IPC-E-25-16 - CLEAN ENERGY OPPORTUNITIES FOR IDAHO -
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Gannon, et. al.
John Gannon
Randy Morris
Deborah Fease
Amy Lorrance
j ohngannon200 P gmail.com
occidentalpacific(a)hotmail.com
feased854(a)gmail.com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman, Ph.D.
elo(a)echohawk.com
lance(a)aegisinsi ht.com
Industrial Customers of Idaho Power
Peter J. Richardson
peterna richardsonadams.com
Kroger
Kurt J. Boehm
Jody Keyle Cohn
kboehm(a)bkllawfirm.com
i kylercohn(a)bkllawfirm.com
Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
darueschhoff(a)hollandhart.com
tnelson(a)hollandhart.com
awi [e-mail]
karoach(a)hollandhart.com
aclee(a)hollandhart.com
[e-mail]
Northwest Energy Coalition
Ben Otto
Lauren McCloy
Derek Goldman
ben(a)nwenerg y�org
laurenOnwenerg y�org
derek@nwenerg y�org
IPC-E-25-16 - CLEAN ENERGY OPPORTUNITIES FOR IDAHO -
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Kelsey Jae
Attorney for CEO
IPC-E-25-16 - CLEAN ENERGY OPPORTUNITIES FOR IDAHO -
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