20210715Petition to Intervene.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Phone: [phone]
[e-mail]
Attorney for the Clean Energy Opportunities of ldaho
IN THE MATTER OF IDAIIO
POWER COMPAT{Y'S
APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES FOR
ELECTRIC SERVICE TO
REC OVER COSTS ASSOCIATED
\trITH TTIE JIM BRIDGER POWER
PLANT
BEFORE THE IDAHO PTJBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.ZI.L7
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO
PETITION TO INTERVENE
Pursuant to IDAPA 31.01.01.042, Clean Energy Oppornrnities for ldaho, Inc. ("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 should be granted intervention.
L. The name of this intervenor is:
Clean Energy Opportunities for ldaho, Inc.
Michael Heckler
Courtrrey White
3778 Plantation River Drive, Suite 102
Boise, ID 83703
mike@cleanenergyopportunities. com
courtney @cleanenergyopportunities. com
This lntervenor's attorney is:
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise, Idaho 83703
Ph: [phone]
[e-mail]
CLEAN ENERGY OPPORTUNTTIES FOR IDAHO - PETITION TO INTERVENE
IPC-E-zr-t7
1
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, unless otherwise provided by Order. Production requests,
responses, notices, Commission orders, and other filings may be submitted via electronic mail in
accordance with IPUC Rules 3 1.0 1.0 1.063.02-03.
2. CEO is a non-profit corporation incorporated under the laws of the State of Idaho.
3. CEO has a direct and substantial interest in this proceeding. The organization was
founded with a mission to bring problem-solving rigor and solution-focused approaches to
advance clean energy and better serve the long-term interests of Idahoans and future generations.
The need to bring these skills and approach into clean energy related dockets was an impetus for
founding the organization. The purpose of CEO's efforts is the reduction of greenhouse gas
emissions, including the accelerated retirement of coal resources. CEO seeks those reductions
while ensuring that the long-term interests of Idahoans are given fair consideration. The
organization aims to contribute from a perspective informed by collaborative problem-solving
approaches and multiple stakeholder interests as the issues associated with accelerated retirement
of coal plants are contemplated.
4. CEO's participation as an intervenor in this proceeding will not unduly broaden the
issues or delay the proceeding. CEO respects the scope of this docket and is pursuing interests
that fall outside this scope via other dockets and other venues. CEO's involvement in this
proceeding will not be duplicative of other parties in this proceeding because no other pafiy
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE
tPC-E-21-r7
2
adequately represents CEO's interests while also offering advanced analytical skills gained via
graduate-level business degrees and private sector experience in business analysis.
5. CEO intends to fully participate in this matter as a party. The nature and quality of
CEO's intervention in the proceeding is dependent upon the nature and effect of other evidence
in this proceeding. If necessary, CEO may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. CEO intends to seek intervenor funding pursuant to
rDAPA 31.01.01. 161-155.
WHEREFORE, CEO respectfully requests the Commission grant this petition.
DATED this 14th day of July, 2021.
Respectfully submitted,
ls\e
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNINES FOR IDAHO. PETITION TO INTERVENE
IPC-E-21-17
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CERTIFICATE OF SERVICE
I hereby certify that on this 14th day of July, 202L, 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
Jan Noriyuki
Commission Secretary
[e-mail]. sov
Idoho PUC Staff
Eric Shaner
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]. sov
Idaho Power Company
Lisa D. Nordstrom
Matt Larkin
Idaho Power Company
L22L West Idaho Street, 83702
P.O. Box 70 Boise,Idaho 83707
lnordstrom@idahooower. com
dockets@idahopower. com
[e-mail]
Boise City
Ed Jewell
Deputy City Attorney
Boise City Attomey's Office
150 N. Capitol Blvd. I P.O. Box 500
Boise, Idaho 83701-0500
BoiseCi tyAttorney @ci tyofboise.org
ei [e-mail]
I daho C onserv ation L e a g ue
Benjamin J. Otto
710 N. 6th St. Boise,Idaho 83702
botto@idahoconservation. org
Industriol Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St., P.O. Box 7218
Boise, Idaho 83702
[e-mail]
Dr. Don Reading
6070 Hill Road Boise, Idaho 83703
dreadins @mindsorins.com
Sierra Club
Rose Monahan
Ana Boyd
2101Webster Street, Suite 1300
Oakland, Califomia 946L2
[e-mail]
[e-mail]
rs\k
Kelsey Jae
Axorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE
IPC-8.2L.L7
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