20260227Petition to Intervene.pdf

Gregory M. Adams (ISB No. 7454) RECEIVED
Richardson Adams, PLLC FEBRUARY 27, 2026
515 N. 27th Street IDAHO PUBLIC
Boise, Idaho 83702 UTILITIES COMMISSION
Telephone: [phone]
Fax: [phone]
[e-mail]
Irion Sanger(ISB No. 12488)
Sanger Greene, PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Northwest and Intermountain Power Producers Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-26-03
COMPANY'S APPLICATION FOR )
APPROVAL OF THE 2032 ALL- SOURCE ) NORTHWEST & INTERMOUNTAIN
REQUEST FOR PROPOSALS TO ) POWER PRODUCERS COALITION'S
PETITION TO INTERVENE
MEET CAPACITY RESOURCE NEEDS IN )
AS EARLY AS 2031.
Northwest& Intermountain Power Producers Coalition("NIPPC") hereby petitions to
intervene as a party to this proceeding under Idaho Public Utilities Commission ("Commission")
Rule of Procedure, Rule 71, IDAPA 31.01.01.071.
In support of its Petition to Intervene, NIPPC states as follows:
1. The name and address of this Intervenor is:
NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION TO
INTERVENE
IPC-E-26-03 —PAGE I

Northwest& Intermountain Power Producers Coalition
c/o Spencer Gray
Executive Director
P.O. Box 504
Mercer Island, WA 98040
[e-mail]
Copies of all pleadings, production requests,production responses, Commission orders
and other documents should be provided to Gregory M. Adams, Irion A. Sanger, Spencer Gray
at the email addresses noted above.
2. NIPPC is a trade association whose members and associate members include
independent power producers active in the Pacific Northwest and Western energy markets.'
NIPPC's organizational purpose is to represent the interests of its members in developing rules
and policies that help achieve a competitive electric power supply market in the Pacific
Northwest. NIPPC has participated in numerous regulatory proceedings related to requests for
proposals ("RFPs"),bidding guidelines, and competitive markets before state regulatory
commissions in the Northwest and before the Federal Energy Regulatory Commission. Thus,
NIPPC's intervention will assist the Commission in resolving the issues presented in this case.
3. NIPPC has a substantial interest in this proceeding in particular because NIPPC
was an active party in recently concluded Docket No. GNR-E-25-01, where this Commission
adopted its current competitive bidding policy in Order No. 36898. Additionally, NIPPC's
member companies include potential bidders in Idaho Power's proposed request for proposals.
Thus,NIPPC has a direct interest in this proceeding, and NIPPC's interests are not adequately
' NIPPC's members include but are not limited to: Apex Clean Energy,Avangrid
Renewables, Aypa, Brightnight, Brookfield Renewable, Calpine Corp., Citadel, Clearway,
Constellation, Cypress Creek Renewables, EDF Renewable Energy, EDP Renewables, Enel
Green Power, Hanwha, Invenergy LLC, Morgan Stanley,NextEra Energy, NRG Energy,
Obsidian Renewables, Pattern, Rye Development, Shell Energy North America, and TransAlta.
NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION TO
INTERVENE
IPC-E-26-03 —PAGE 2

represented by any other party in this proceeding.
4. Without being granted party status,NIPPC's right to fully participate in this
proceeding may be materially compromised.
5. This Petition to Intervene is timely filed under Rule 73, IDAPA 31.01.01.073,
because the Commission has not yet held a hearing or procedural conference, and the
Commission has not established a deadline for intervention. Thus, granting NIPPC's Petition to
Intervene will not unduly broaden the issues beyond their proper scope, nor will it unduly
prejudice any party to this case.
WHEREFORE,NIPPC respectfully requests that this Commission issue an order
granting NIPPC's Petition to Intervene.
Respectfully submitted this 27th day of February, 2026.
RICHARDSON ADAMS, PLLC
/s/ Gregoa M. Adams
Gregory M. Adams (ISB No. 7454)
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Irion Sanger(ISB No. 12488)
Sanger Greene, PC
4031 SE Hawthorne Blvd.
Portland, OR 97214
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Northwest and Intermountain Power
Producers Coalition
NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION TO
INTERVENE
IPC-E-26-03 —PAGE 3

CERTIFICATE OF SERVICE
I HEREBY certify that I have on this 27th day of February, 2026, served the foregoing
Petition to Intervene by electronic mail to the following:
Monica Barrios-Sanchez Tim Tatum
Commission Secretary Connie Aschenbrenner
Idaho Public Utilities Commission Idaho Power Company
P.O. Box 83720 1121 W. Idaho Street
Boise, ID 83720-0074 PO Box 70
[e-mail] Boise, ID 83707-0070
ttatum@.idahopower.com
Jeffrey R. Loll [e-mail]
Deputy Attorney General
Idaho Public Utilities Commission Eric L. Olsen
P.O. Box 83720 Echo Hawk& Olson, PLLC
Boise, ID 83720-0074 505 Pershing Ave., Ste. 100
[e-mail] P.O. Box 6119
Pocatello, Idaho 83205
Donovan Walker [e-mail]
Idaho Power Company [e-mail]
1121 W. Idaho Street
PO Box 70 Lance Kaufman, Ph. D.
Boise, ID 83707-0070 Deborah Glosser, Ph. D.
[e-mail] 2623 NW Bluebell Place
[e-mail] Corvallis, OR 97330
[e-mail]
[e-mail]
By: /s/ Gregoa M. Adams
Gregory M. Adams (ISB No. 7454)
NORTHWEST & INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION TO
INTERVENE
IPC-E-26-03 —PAGE 4