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Home My WebLink About20220218Petition to Intervene.pdf-r: rra\i r.., 1-r,.rt-ll Abigail R. Germaine (ISB No. 9231) Elam & Burke, P.A. 251E. Front St. Suite 300 P.O. Box 1539 Boise, Idaho 83701 (208) 343-s4s4 (208) 384-5844 (fax) arq(Eelamburke.com Attorney for Renewable Northwest IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION TO PROCEED WITH RESOURCE PROCUREMENTS TO MEET IDENTIFIED CAPACTTY DEFICIENCIES IN 2023, 2024, AND 2025 TO ENSURE ADEQUATE, RELIABLE AND FAIR-PRICED SERVICE TO ITS CUSTOMERS. . . i:-, i3 5il |il, 2l ' ' -::=: : ,l- , , l:l-l'i..Ii BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-21-41 RENEWABLE NORTHWEST'S PETITION TO INTERVENE COMES NOW, Renewable Northwest and pursuant to Rules 7l through 73 of the Rules of Procedure of the Idatro Public Utility Commission (IDAPA 31.01.01.71 - 31.01.01.73), and pursuant to that Application filed on December 3,202t, and Notice of Application, Notice of lntervention Deadline, Order No. 35314, filed on February 4,2022, hereby petitions the Idaho Public Utilities Commission ("Commission") for leave to intervene herein and to appear and participate as a party, and as basis therefore states as follows: l. The name and address of this lntervenor is: Renewable Northwest c/o Max Greene, Regulatory & Policy Director 421 SW 6ft Ave, Suite 1400 Portland, OR97204 max(@renewablenw.ore 2. Copies of all pleadings, production requests, production responses, Commission orders, and other documents should be provided to Abigail R. Germaine at: RENEWABLE NORTHWEST'S PETITION TO INTERVENE - 1 Abigail R. Germaine Elam & Burke, P.A. 251 E. Front St. Suite 300 P.O. Box 1539 Boise, Idaho 83701 (208) 343-s4s4 (208) 384-5844 (fax) Idaho State Bar No. 9231 Email : are(rDelamburke. com ln the interest of reducing costs to all parties, please provide hard copies of pleadings, testimony, and briefs only. A1l other production requests, responses, notices, Commission orders and other filings may be submitted via electronic mail in accordance with Rule 63 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA 31.01.01.063). 3. Renewable Northwest is a renewable energy advocacy organization. Renewable Northwest is focused on policy and regulatory proceedings in Oregon, Washington, Idaho, and Montana. A coalition of renewable energy developers and supporting businesses, ratepayer advocates, and environmental NGOs, Renewable Northwest works to ensure transparent, efficient, and competitive markets for renewable energy across the Western United States. Renewable Northwest is committed to helping build a connected western electricity market and advocates for regional market expansion to value the geographic diversity of renewable energy generation. Renewable Northwest has extensive experience in Integrated Resource Planning and procurement processes, including ldaho Power Company's 2021 lntegrated Resource Plan, as well as the necessary policies to make these processes effective and efficient. Renewable Northwest also participated in the rulemakings that led to the adoption of the current Oregon Public Utility Commission and Washington Utilities and Transportation Commission resource procurement rules for electric utilities. RENEWABLE NORTHWEST'S PETITION TO INTERVENE - 2 4. Renewable Northwest has a direct and substantial interest in this matter as an industry advocate for renewable energy resources in the West. Renewable Northwest, and many of its members, would be negatively impacted by Idaho Power Company's request to eliminate the Commission's requirement for Idaho Power Company to comply with the Oregon Public Utility Commission's resource procurement rules. Renewable Northwest and many of its members are equally concerned with Idaho Power Company's petition to move away from utilizing tools that can provide substantial benefits to ratepayers such as competitive procurement rules and Power Purchase Agreements ("PPAs"), as well as the potential development of a Regional Transmission Organization ("RTO") or Independent System Operator ("ISO"), among other things. Many of Renewable Northwest's members participate in procurements regulated by state utility commissions, and these members would be harmed by the elimination of rules and guidelines for procurement of energy resources as advocated by Idaho Power's application. 5. Without the opportunity to intervene herein, Renewable Northwest would be without any means of participation in this proceeding which may have a negative impact on currently established beneficial procurement requirements and processes. If allowed to intervene, Renewable Northwest will participate in the proceedings and appear in all matters as may be necessary and appropriate; present evidence; call and examine witnesses; present argument; and otherwise fully participate in these proceedings. 6. Granting Renewable Northwest's petition to intervene will not unduly broaden the issues, nor will it prejudice any party to this case. 7. This Petition to lntervene is timely filed under Rule 73, IDAPA 31.01.01.073 because it is filed within the fourteen (la) day deadline to intervene established by Order No. 353t4. RENEWABLE NORTHWEST'S PETITION TO TNTERVENE - 3 8. Renewable Northwest intends to fully participate in this matter as a party. The nature and quality of Renewable Northwest's intervention in this proceeding is dependent on the nature and effect of other evidence in this proceeding. Renewable Northwest requests that the Commission issue a timely order granting this Petition to Intervene following the seven-day opposition period set forth in IDAPA 31.01.01.075. WHEREFORE, Renewable Northwest respectfully requests that this Commission grant this Petition to Intervene. DATED: February 18,2022. ELAM & BURKE, P.A. fr'*''1* Abigail R. Germaine Attorney for Renewable Northwest RENEWABLE NORTHWEST'S PETITION TO INTERVENE - 4 CERTIFICATE OF SERVICE I HEREBY certiry that I have on this 18th day of February 2022 servd the foregoing Petition to lntervene by electronic mail to the following: Jan Noriyuki Commission Secretary Idaho Public Uttlities Commission j an.noriyuki@puc. idaho. eov Donovan Walker Regulatory Dockets Idaho Power Company dwalker(Eidahopower. com dockets@ idahopower.com Tim Tatum Vice President, Regulatory Affairs Idaho Power Company ttatum @ idahopower. com Gregory M. Adams Attorneys for Northwest and Intermountain P ower Producers Coalition qre e@richardsonadams. com Jack Van Valkenburgh Attorneyfor STOP B2H Coalition i ack@vanvalkenburghlaw.com Beqiamin J. Otto Emma E. Sperry Attorneys for ldaho Conservation League botto(g) idahoconservation. ors Peter J. Richardson Attorneys for the Industrial Customers of Idaho Power peter@richardsonadams.com Dr. Don Reading dreadine@mindspring.com C. Tom Arkoosh Amber Dresslar Attorneys for ldaHydro tom. arkoosh(@arkoosh. com amber. dresslar@arkoosh. com erin.ceci l@arkoosh.com ,l ;tI.ttrrir{.'t, Abigail R. Germaine 4871-3605-7359, v. 3 RENEWABLE NORTHWEST'S PETITION TO INTERVENE - 5