20220111Petition to Intervene.pdf

Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N.276 Steet
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
greg@richardsonadams. com
Attorney for Northwest and Intermountain Power Producers Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO 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 SERVICE TO TTS CUSTOMERS
CASENO. IPC-E-21-41
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NORTHWEST AND INTERMOI'NTAIN
POWER PRODUCERS COALITION'S
PETITION TO INTERVENE
Northwest and Intermountain Power Producers Coalition ('NIPPC") hereby petitions to
intervene as a party to this proceeding under Idaho Public Utilities Commission ("Commission")
Rule of Procedure, Rule TI,IDAPA 31.01.01.071.
ln support of its Petition to Intervene, NIPPC states as follows:
l. The name and address of this lntervenor is:
Northwest and lntermountain Power Producers Coalition
c/o Spencer Gray
Executive Director
P.O. Box 504
Mercer Island, WA 98040
[e-mail]
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Gregory M. Adams at the email address noted above
NORTHWEST AND TNTERMOUNTATN POWER PRODUCERS COALITION'S PETITION
TO INTERVENE
TPC-E-21-4I _PAGE I
and to Spencer Gray at the email address noted above.
2. NIPPC is a ffade association whose members and associate members include
independent power producers active in the Pacific Northwest and Westem energy markets.l
NIPPC's organizational purpose is to represent the interests of its members in developing rules
and policies that help achieve a competitive electric power supply market in the Pacific
Northwest. NIPPC has participated in numerous regulatory proceedings related to requests for
proposals (o'RFPs"), bidding guidelines, and competitive markets before state regulatory
commissions in the Norlhwest and before the Federal Energy Regulatory Commission. Thus,
NIPPC's intervention will assist the Commission in resolving the issues.
3. NIPPC has a substantial interest in this proceeding in particular because Idaho
Power Company ("Idaho Power") proposes to eliminate the previously approved competitive
bidding rules for its acquisition of the major generation resources under consideration in this
docket. NIPPC was an active party in the underlying Idaho docket that resulted in this
Commission's adoption of the competitive bidding rules of the Oregon Public Utility
Commission, which Idaho Power cites in its application. Thus, NIPPC has a direct interest in
Idaho Power's request to eliminate use of those requirements. Additionally, given the
opportunity, independent power producers, including NIPPC members, may participate in Idaho
Power's competitive solicitations at issue in this docket, as well as future solicitations, and
NIPPC's participation in this proceeding can help ensure that such processes are reasonable, fair
I NIPPC's members include but are not limited to: Calpine Corp, Constellation Exelon,
Cycle, DG Energy Partrers, Direct Energy, Ecoplexus, EDF Renewable Energy, EDP
Renewables, lnvenergy LLC, Morgan Stanley, NewSun Energy, NextEra Energy, Obsidian
Renewables, Perennial Power Holdings, Rye Development, Shell Energy North America, Sierra
Pacific lndustries, TransAlta Energy Marketing, and Tyr Energy.
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION
TO INTERVENE
wc-E-2t-41 - PAGE 2
and balanced. NIPPC's interests are not adequately represented by any other party in this
proceeding.
4. Without being granted party status, MPPC's right to fully participate in this
proceeding may be materially compromised.
5. This Petition to Intervene is timely filed under Rule 73, IDAPA 31.01.01.073,
because the Commission has not yet held a hearing or procedural conference, and the
Commission has not established a deadline for intervention. Thus, granting NIPPC's Petition to
Intervene will not unduly broaden the issues beyond their proper scope, nor will it unduly
prejudice any party to this case.
WIIEREFORE, NIPPC respectfully requests that this Commission issue an order
granting NIPPC's Petition to lntervene.
Respectfully submitted this I lth day of January 2022.
RICHARDSON ADAMS, PLLC
u^-
515 N. 2 7tr
. Adams (ISB No. 7454)
Street
Boise,Idatro 83702
Telephone: [phone]
Fax: [phone]
greg@richardsonadam s.com
Attorneys for Northwest and Intennountain Power
Producers Coalition
NORTHWEST AND INTERMOTJNTAIN POWER PRODUCERS COALITION'S PETITION
TO INTERVENE
wc-E-2141 - PAGE 3
CERTIFICATE OF SERYICE
I HEREBY certifi/ that I have on this 1lth day of January 2022, served the foregoing
Petition to lntervene by electronic mail to the following:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
j an.noriyuki@puc. idaho. gov
John R. Hammond
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, lD 83720-0074
j ohn. hammond@puc. idaho. gov
Donovan Walker
Regulatory Dockets
PO Box 70
Boise,ID 83707-0070
dwalker@idahopower. com
dockets@idahopower. com
Dr. Don Reading
6070 Hill Road
Boise, tD 83703
dreading@mindspring. com
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27tr Steet
PO Box 7218
Boise, TD 83702
peter@richardsonadams. com
Benjamin J. Otto
Emma E. Sperry
Idaho Conservation League
710 N. 6ft Street
Boise, tD 83702
botto@idahoconservation. org
esperry@idalroconservation. org
Tom Arkoosh
Amber Dresslar
Arkoosh Law Offices
913 W. River Street, Ste 450
PO Box 2900
Boise,ID 83701
tom. arkoosh@arkoosh. com
amber. dresslar@arkoosh. com
erin. cecil@arkoosh. com
By:
M. Adams (ISB No. 7454)
NORTHWEST AND TNTERMOUNTAIN POWER PRODUCERS COALITION'S PETITION
TO INTERVENE
TPC-E-21-4I - PAGE 4