20260417Petition to Intervene.pdf

Kelsey Jae (ISB No. 7899)
521 E. 41st St. #506
RECEIVED
Garden City, Idaho 83714
APRIL 17, 2026
[phone] IDAHO PUBLIC
[e-mail] UTILITIES COMMISSION
Attorney for the Clean Energy Opportunities of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO )
POWER COMPANY'S PETITION )
TO EVALUATE CLASS )
COST-OF-SERVICE ) CASE NO. IPC-E-26-07
METHODOLOGY, CONSIDER )
ALTERNATIVE CLASS ) CLEAN ENERGY OPPORTUNITIES
COST-OF-SERVICE STUDIES, AND ) FOR IDAHO PETITION TO
DETERMINE COST OF SERVICE ) INTERVENE
CONSIDERATIONS FOR NEW )
LARGE-LOAD CUSTOMERS )
Pursuant to IDAPA 31.01.01.042, Clean Energy Opportunities for Idaho ("CEO") hereby
submits this Petition To Intervene in the above-captioned matter. As discussed below, CEO has
direct and substantial interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Clean Energy Opportunities for Idaho
Courtney White & Mike Heckler
3778 Plantation River Drive, Suite 102
Boise, Idaho 83703
courtney(@cleanenergyopportunities.com
[e-mail]
This Intervenor's attorney is:
Kelsey Jae (ISB No. 7899)
521 E. 41st St. #506
Garden City, Idaho 83714
Ph: [phone]
[e-mail]
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE - 1
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Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the names and addresses above. In the interest of
conserving natural resources and reducing the costs to all parties, please serve hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
2. CEO is a nonprofit corporation incorporated under the laws of the State of Idaho.
3. CEO has a direct and substantial interest in this proceeding. CEO strives to serve the
long-term interests of Idahoans, and updating the Class Cost of Service ("CCOS") methodology
and the pricing structures it implies to more accurately reflect modern cost dynamics is essential
to that goal. CEO has intervened and actively participated in past dockets involving the CCOS
methodology and is a signatory to the settlement agreement in IPC-E-25-16 that called for the
opening of this docket. CEO has taken the position, "Public interest will not be served if a future
application for a rate increase is solely informed by the allocation policies presented in the
IPC-E-25-16 application." (CEO Final Comments, IPC-E-25-16, p5). CEO posits that electric
grid conditions are radically different today from those existing when the 1992 CCOS
methodology was developed. CEO has previously commented on why transformative industry
changes call for substantial CCOS changes. If left unchanged or only moderately changed,
inaccurate assumptions underlying the CCOS method filed in IPC-E-25-16 will continue to—and
may increasingly- suggest disproportionately higher rate increases for small customers such as
residential. New large loads exacerbate the problem. Further, when pricing structures are
informed by CCOS, those CCOS inaccuracies lead to misleading price signals and inadequate
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mitigation of future costs. Without an opportunity to intervene, CEO would not have an adequate
means of fully participating in the process of effectively addressing issues that have taken several
years to be presented in a focused manner like this docket.
4. CEO's participation as an intervenor in this proceeding will not unduly broaden the
issues or delay the proceeding because CEO's interest is directly related to the subjects that will
be addressed in Idaho Power's application. CEO's involvement in this proceeding will not be
duplicative of other parties in this proceeding because no other party adequately represents
CEO's interests. Given the metaphor of costs as a pie, some parties have motive to minimize the
share of the pie for their client, and the Company is incentivized to employ rate structures that
minimize inter-annual variability in its revenue stream. CEO, in contrast, is able to focus on
evidence-based fairness and matters affecting the long-term size of the pie.
5. CEO intends to fully participate in this matter as a party. CEO will strive to ensure
the Commission is presented with meaningful alternatives and a clear framing of the subjective
assumptions and policy choices which can at times get buried in the math. CEO notes that this is
an extremely impactful docket, yet its wonkiness raises challenges. Large customers will be
represented by experts who can engage effectively while small customers may be
under-represented. This docket challenges us to take extra care that issues are resolved on their
merits and not by a weighting of party positions. The nature and quality of CEO's intervention in
the proceeding is dependent upon the nature and effect of other evidence in this proceeding. CEO
may introduce evidence, be heard in argument, and call, examine, and cross-examine witnesses.
CEO intends to seek intervenor funding pursuant to IDAPA 31.01.01.161-165.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE - 3
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WHEREFORE, CEO respectfully requests the Commission grant this petition.
DATED this 17th day of April, 2026.
Respectfully submitted,
'U
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE - 4
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CERTIFICATE OF SERVICE
I hereby certify that on this 17th day of April, 2026 I delivered true and correct copies of
the foregoing PETITION TO INTERVENE 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
Erika Melanson
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Lisa Lance
Timothy Tatum
Grant Anderson
mgoicoecheaallenOidahopower.com
[e-mail]
ttaturnPidahopower.com
gandersonOidahopower.com
dockets idahopower.com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman, Ph.D.
Deborah Glosser, Ph.D.
eloPechohawk.com
lance Paegisinsight.com
deborah.gosser@ gmail.com
Northwest Energy Coalition
Benjamin J. Otto
Lauren McCloy
Derek Goldman
benOrtwenerg y�org
laurenOnwenerg y�org
derek@nwenerg y�org
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE - 5
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Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE - 6
IPC-E-26-07