20210816Petition to Intervene.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise,ID 83703
Phone: [phone]
[e-mail]
Attorneyfor Clean Energ,t Opportunities of ldaho
IN THE MATTER OF IDAHO )
POWER COMPAI\Y'S )
APPLICATION TO INITIATE A )
MULTr-PHASE COLLABORATTVE )
PROCESS FORTHE STUDYOF )
cosTs, BENEFITS, AND )
COMPENSATTON OF NET EXCESS )
ENERGYASSOCIATED WITH )
cusroMER oN-srrE )GENERATION )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-2I-2I
CLEAI\ ENERGY OPPORTUNITIES
F'OR IDAHO
PETITION TO INTERVENE
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 should be granted intervention.
l. The name of this intervenor is:
Clean Energy Opportunities for Idaho
Michael Heckler
Courtney White
3TTSPlantation River Drive, Suite 102
Boise,ID 83703
nrikerDcleanerlersvoDDortunities.com
courtnev[)cleanenersvonoortunities.com
This Intervenor's attorney is:
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise, Idaho 83703
Ph: [phone]
kelsev,a)kelsev iae.cour
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE
[PC-E-2I-21
I
, ..' ,' ' 1, i', It i;
Please provide copies ofall 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 31.01.01 .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 - the reduction of greenhouse gas
emissions - is directly affected by an accelerated development of clean distributed energy
resources. In this docket, CEO is especially focused on the use of appropriate accounting
techniques and other methods for estimating and quantifring the costs and benefits associated
with such 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
CLEAN ENERGY OPPORTTINITIES FOR IDAHO . PETITION TO INTERVENE
LPC-E-2t-21
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proceeding will not be duplicative of other parties in this proceeding because no other party
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 intoduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. CEO intends to seek intervenor funding pursuant to
IDAPA 3 1.01.01. l6l-165.
WHEREFORE, CEO respectfully requests the Commission grant this petition.
DATED this l5th day ofAugvst,202l.
Respectfully submitted,
rs\e
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUMTIES FOR IDAHO . PETITION TO INTERVENE
rPC-E-21-21
3
CERTIT'ICATE OT' SERVICE
I hereby certit/ that on this l5th day ofAugust,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
secretarv@.ouc. idaho. sov
Idaho PUC Staff
Erick Shaner
Deputy Afforney General
Idaho Public Utilities Commission
[e-mail]. sov
Idaho Power Company
Lisa D. Nordstrom
Connie Aschenbrenner
Idaho Power Company
l22l West Idaho Street, 83702
P.O. Box 70 Boise,Idaho 83707
lnordstrom@ i dahopower. com
dockets@ idahopower.com
[e-mail]
IdaHydro
C. Tom Arkoosh
Arkoosh Law Offrces
913 W. River Street, Suite 450
P.O. Box 2900
Boise,ID 83701
[e-mail]
erin.ceci l(Earkoosh.com
Idaho Clean Energ,t Association
Kevin King
P.O. Box 2264 Boise, lD, 837 02
208-850-0880
st a ff@. i daho c I e anen ers v. o rs
Idaho Cons erttation League
Benjamin J. Otto
710 N. 6th St. Boise, Idaho 83702
botto@ idahoconservation.ors
Industrial Customers of ldaho Power
Peter J. Richardson
RichardsonAdams, PLLC
515 N. 27th St., P.O. Box 7218
Boise,Idaho 83702
oeter@richardsonadams. com
Dr. Don Reading
6070 Hill Road Boise,Idaho 83703
[e-mail]
t$\e
Kelsey Jae
Attorneyfor CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO . PETITION TO INTERVENE
LPC-E-2I-2t
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