20210818Petition to Intervene.pdf

Ryan Bushland
ABC Power Co. LLC
184 W. Chrisfield Dr.
Meridian, ID 83646
Telephone: [phone]
Email:
ryan.bushland@abcpower. co
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
INITIATE A MULTI.PHASE
COLLABORATIVE PROCESS FOR THE
STUDY OF COSTS, BENEFITS, AND
COMPENSATION OF NET EXCESS
ENERGY ASSOCIATED WITH
CUSTOMER ON-SITE GENERATION
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E-21-21
PETITION TO INTERVENE OF
ABC POWER LLC
COMES NOW ABC Power Co. LLC, an Idaho based energy company, and hereby requests
leave to intervene in the above captioned matter pursuant to the Idaho Public Utilities Commission
Rules of Procedure, IDAPA 3 1 .01 .01 .07 l-073 , and to appear and participate herein as a party, and
as grounds therefore states as follows:
l. The name and address of the intervenor is:
Ryan Bushland
ABC Power Company LLC
184 W. Chrisfield Dr.
Meridian,ID 83646
Telephone: [phone]
Email : ryan.bushland@abcpower. co
Mr. Bushland is a Principal of ABC Power Company LLC. ABC Power is a limited liability
company operating in Idaho. Pursuant to IDAPA rule 43 Mr. Bushland can represent ABC Power
Company LLC as an officer of the corporation in this administrative proceeding to design a study of
distributed values.
Copies of all pleadings, production requests, production responses, Commission orders and
other documents should be provided as noted above.
2. This Intervenor, ABC Power Company LLC, is a company representing its
potential customers, primarily Idaho residential and commercial properly owners and claims direct
and substantial interest in this proceeding in that this filing is the first in a series that may initiate
changes in rates and requirements that may negatively affect their participation in on-site
generation. Intervenor stafus is necessary to protect our customer interests in protecting and
promoting private generation ownership in Idaho.
3. ABC Power Company LLC intends to participate herein as a party and, if necessary,
to introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
argument. The nature and quality of evidence which this Intervenor will introduce is dependent
upon the nature and effect of other evidence in this proceeding.
WHEREFORE, ABC Power Company LLC respectfully requests that the Commission grant this
petition to intervene and to fully participate in these proceedings.
DATED this l8s day of August,2}2l
Ryan Bushland, Principal
ABC Power Company LLC
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MAII.ING
I HEREBY CERTIFY that on the l8th day of August 2021, I served a true and correct
copyof the foregoing document(s) upon the following person(s), in the manner indicated:
Ryan Bushland
ABC Power Company
Electronic mail only (See Order 34781):
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
seuetary@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
[e-mail]
Connie Aschenbrenner
caschenbrenner@idahopower. com
[e-mail]
Industrial Customers of Idaho Power
Peter J. Richardson, Richardson Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
[e-mail]
Ida Hydro
C. Tom Arkoosh, Arkoosh Law Office
Tom. [e-mail]
Erin. [e-mail]
Idaho Conseration League
Ben Otto Idaho Conservation League
[e-mail]
Idaho Clean Energy Association
Kevin King, President
staff@idahocleanenergy. org
Idaho Solar Owners Network
Joshua Hill, President
[e-mail]
Micron Technology, Inc.
Austin Rueschhoff
darueschoff@ho llandhart.com
Thorvald A. Nelson
[e-mail]
Austin W. Jensen
awj [e-mail]