20210804Petition to Intervene.pdf

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Board President of the Idaho Clean Enerry Association
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
Kevin King
P.O. Box 2264
Boise, Id.83702
208-850-0880
staff@idahocl eanenergy. org
IN THE MATTER OF IDAHO
POWER COMPANY'S
APPLICATION TO INITIATE A
MULTI.PHASE COLLABORATIVE
PROCESS FOR THE STUDY OF
cosTs, BENEFTIS, AND
COMPENSATION OF NET EXCESS
ENERGY ASSOCIATED WITH
CUSTOMER ON-SITE
GENERATION
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CASE NO. IPC-N-?L2I
PETITION TO INTERVENE OF THE
IDAHO CLEAN ENERGY
ASSOCIATION
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COMES NOW the Idaho Clean Energy Association ("ICEA")) and hereby requests leave
to intervene in the above captioned matter pursuant to the Idaho Public Utilities Commission
Rules of Procedure, IDAPA 31.01.01.071-073. As discussed below, ICEA has direct and
substantial interests in these proceedings, and therefore should be granted intervention.
l. The name of this intervenor is:
Kevin King
P .O. Box 2264
Boise, [d.83702
208-850-0880
staff@idaho cl eanenergy. org
Mr. King is the President of the ICEA Board of Directors. ICEA is a non-profit
corporation in Idaho. Pursuant to IDAPA rule 43 Mr. King can represent ICEA as an officer of
the corporation in this adminisfrative proceeding to design a study of distributed energy values.
This is not a quasi-judicial proceeding that adjudicates the legal rights or duties of a party.
Please provide copies of all pleadings, production requests, production responses,
ICEA PETITION TO INTERVENE
Commission orders, and other documents to the name and address above. [n the interest of
conserving natural resources and reducing the costs to all parties, please provide 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. Idaho Clean Energy Association claims a direct and substantial interest in this
proceeding on behalf of our members who provide distributed energy products and services to
Idaho Power customers. Idaho Power's proposal here directly impacts ICEA member's business
by proposing new methods to value the products and services they offer to Idahoans. Further,
Idaho Power states clearly this docket is the first of a series that will lead to new proposals for
distributed energy system rates and programs that will dictate ICEAs member's ability to
conduct a viable business in Idaho. Status as an intervenor is necessary for the ICEA to
effectively protect our member's interests in a viable distributed energy systems program at
Idaho Power. By responding to Idaho Power's petition, ICEA will not unduly broaden the
issues.
3. ICEA intends to fully participate in this matter as a party. The nature and quality of
ICEA's intervention in the proceeding is dependent upon the nature and effect of other evidence
in this proceeding. If necessary ICEA may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. ICEA may seek intervenor funding pursuant to IDAPA
31.01.0r.161-16s.
WHEREFORE, ICEA respectfully requests the Commission grant this petition.
DATED this 4ft day of August2}2l.
Respectfully submitted,
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Idaho Clean Energy
ICEA PETITION TO INTERVENE 2
CERTIFICATE OF SERVICE
I hereby certiff that on this 4th day of August202l,I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Kn*r;, Kr;r-'
Idaho Clean n"@GiEffi
Electronic mail only (See Order 34781):
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
secretary@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Connie Aschenbrenner
lnordstrom@idahopower. com
caschenbrenner@idahopower. com
dockets@idahopower. com
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
p eter@ri chardsonadams. com
Dr. Don Reading
dreading@nindspring. com
IdaHydro
C. Tom Arkoosh
Arkoosh Law Office
Tom. arkoosh@arkoosh. com
Erin. cecil@arkoosh. com
Idaho Conservation League
Ben Otto
Idaho Conservation League
botto@idahoconservation. org
ICEA PETITION TO INTERVENE 3