20211222Petition to Intervene.pdf

IPC-E-21-41 ICL PETITION TO INTERVENE 1 December 21, 2021
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street Boise, ID 83701 Ph: [phone] Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
POWER COMPANY’S APPLICATION FOR AUTHORITY TO PROCEED WITH RESOURCE PROCUREMENTS TO MEET IDENTIFIED CAPACITY DEFICIENCIES IN 2023, 2024, AND 2025 TO ENSURE ADEQUATE, RELIABLE, AND FAIR-PRICED
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CASE NO. IPC-E-21-41
PETITION TO INTERVENE OF THE IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League (“ICL”) 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, ICL has direct and substantial
interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Idaho Conservation League 710 N. 6th St. Boise, Idaho 83702 Ph: [phone]
[e-mail]
Idaho Conservation League 710 N. 6th St. Boise, Idaho 83702 Ph: 208-537-7993 ext. 230
[e-mail]
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the name and address above. In the interest of
conserving natural resources and reducing the costs to all parties, please provide hard copies of
RECEIVED
2021 DEC 22 PM 3:58
IDAHO PUBLIC
UTILITIES COMMISSION
IPC-E-21-41 ICL PETITION TO INTERVENE 2 December 21, 2021
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 Conservation League claims a direct and substantial interest in this proceeding
as a customer and on behalf of our members who are customers of Idaho Power. As Idaho's
largest state‐based conservation organization, we have approximately 11,000 members most of
whom are residential customers of Idaho Power. ICL’s Boise headquarters is a Schedule 9 Idaho
Power customer and our Ketchum field office is a Schedule 7 customer. ICL and our members
have a direct and substantial interest in ensuring that the Idaho Public Utilities Commission
exercises effective oversight of utility procurement processes. Idaho Power’s proposal would
eliminate this oversight at a crucial juncture in the process – characterizing resource needs,
collecting a set of competitively priced projects to assess, and using an unbiased, transparent
selection process to discover the most reliable and most fair priced of the available options.
Without the ability to intervene in Idaho Power’s request to reduce commission oversight, ICL
will not have the ability to protect the interest of our members or our organization. ICL’s
intervention will respond directly to the issues raised in Idaho Power’s application and thus will
not unduly broaden the issues.
3. ICL intends to participate fully in this matter as a party. The nature and quality of
ICL’s intervention in the proceeding is dependent upon the nature and effect of other evidence in
this proceeding. Because Idaho Power makes several dubious factual assertions about the nature
of resources, contract terms, market mechanisms, and state policy, ICL requests a formal hearing
in this matter. If necessary ICL may introduce evidence, be heard in argument, and call, examine,
IPC-E-21-41 ICL PETITION TO INTERVENE 3 December 21, 2021
and cross-examine witnesses. ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.

WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 21th day of December, 2021.
Respectfully submitted,
/s/ Benjamin J. Otto Benjamin J. Otto Idaho Conservation League
IPC-E-21-41 ICL PETITION TO INTERVENE 4 December 21, 2021
CERTIFICATE OF SERVICE
I hereby certify that on this 21st day of December, 2021, I delivered true and correct copies of the foregoing PETITION TO INTERVENE to the following persons via the method of service noted:
/s/ Benjamin J. Otto
Benjamin J. Otto
Electronic mail only (See Order 35058): Idaho Public Utilities Commission
Jan Noriyuki, Secretary
[e-mail] Idaho Power Donovan E. Walker
Tim Tatum
[e-mail] [e-mail] [e-mail]
IdaHydro
C Tom Arkoosh Amber Dresslar [e-mail] [e-mail]
[e-mail]

Industrial Customers of Idaho Power Industrial Customers of Idaho Power c/o Peter J. Richardson Richardson Adams, PLLC
[e-mail] Dr. Don Reading [e-mail]