20220210Petition to Intervene.pdf

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i ;';, jl Fil 2: 3lAbigail R. Germaine (ISB No. 9231)
Elam & Burke, P.A.
251E. Front St. Suite 300
P.O. Box 1539
Boise, Idaho 83701
(208\ 343-s4s4
[phone] (fax)
ars(Aelamburke.com
Attorneyfor Western Power Trading Forum
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ij.
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATTON TO
PROCEED WITH RESOURCE
PROCUREMENTS TO MEET IDENTIFIED
CAPACITY DEFICIENCIES IN 2023, 2024,
AND 2025 TO ENSURE ADEQUATE,
RELIABLE AND FAIR-PRICED SERVICE
TO ITS CUSTOMERS.
CASE NO. IPC-E-21-41
WESTERN POWER TRADING
FORUM'S PETITION TO
INTERVENE
COMES NOW, Western Power Trading Forum, herein referred to as "WPTF," and
pursuant to Rules 71 through 73 of the Rules of Procedure of the ldaho Public Utility Commission
(IDAPA 31.01.01.71 - 31.01 .01.73), and pursuant to that Application filed on December 3,2021,
and Notice of Application, Notice of Intervention 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:
1. The name and address of this lntervenor is:
Western Power Trading Forum
c/o Scott Miller, Executive Director
1540 River Park Drive, Suite 2l I
Sacramento, CA 95815
smiller(@wptf.ore
2. Copies of all pleadings, production requests, production responses, Commission
orders, and other documents should be provided to Abigail R. Germaine at:
WPTF'S PETITION TO INTERVENE - I
Abigail R. Germaine
Elam & Burke, P.A.
251F,. Front St. Suite 300
P.O. Box 1539
Boise,Idaho 83701
(208) 343-s4s4
[phone] (fax)
Idaho State Bar No. 9231
Email: are(aelamburke. com
In the interest of reducing costs to all parties, please provide hard copies of pleadings,
testimony, and briefs only. All 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. WPTF is a broad-based industy organization of more than 100 companies that do
business and advocate for competitive electricity market rules, and strong system reliability,
throughout the Western Interconnection. Originally formed by competitive suppliers, WPTF
includes electic services providers, developers of generation resources, transmission developers,
community choice aggregators, investor-owned utilities, public utilities, and others. WPTF
encourages information sharing and providing knowledge in discrete areas of the Western Power
business. WPTF acts as an advocate for competitive market outcomes in forums like the Federal
Energy Regulatory Commission (FERC), the Western Electricity Coordinating Council (WECC),
the Northwest Power Pool (recently renamed the "Westem Power Pool"), the California
lndependent System Operator (CAISO), state regulatory commissions, state legislatures and
elsewhere. WPTF has broad knowledge and experience on market rules and policies. WPTF has
acted as an experienced resource in regulatory proceedings across the coun@, including at FERC,
on competitive market policies, market development, and procurement issues as well as efforts to
enhance reliability in the Western Interconnection. WPTF has also been active in other state
WPTF'S PETITION TO INTERVENE - 2
procurement procedures such as most recently in Utah, but also in California and Washington.
WPTF's participation in this case will be beneficial to the Commission and other parties.
4. WPTF has a direct and substantial interest in this matter as an industry advocate for
competitive outcomes that enhance reliability and efficient power supply in the energy market in
the West. WPTF, 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. WPTF and
many of its members are equally concerned with Idaho Power Company's petition to move away
from utilizing procurement tools which can provide substantial benefits to ratepayers such as
competitive procurement rules, the use of Power Purchase Agreements ("PPAs"), and
development of Regional Transmission Organizations ("RTO") and Independent System
Operators ("ISO"), among other things. Many of WPTF's members utilize these tools and the
competitive bidding rules and would be anxious to participate in Idaho Power's solicitation of
energy resources and would be inhibited from doing so ifthat process was eliminated as advocated
by Idaho Power's application.
5. Without the opportunity to intervene herein, WPTF 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, WPTF 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 WPTF's petition to intervene will not unduly broaden the issues, nor will
it prejudice any party to this case.
WPTF'S PETITION TO TNTERVENE - 3
7. This Petition to lntervene is timely filed under Rule 73, IDAPA 31.01.01.073
because it is filed within the fourteen (14) day deadline to intervene established by Order No.
353t4.
8. WPTF intends to fully participate in this matter as a party. The nature and quality
of WPTF's intervention in this proceeding is dependent on the nature and effect of other evidence
in this proceeding. WPTF 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, WPTF respectfully requests that this Commission grant this Petition to
Intervene.
DATED: February 10, 2022.
ELAM & BURKE, P.A.
Abigail R. Germaine
Attorney for Western PowerTrading Fonrm
WPTT'S PETITION TO INTERVENE - 4
CERTIFICATE OF SERVICE
I HEREBY certiry that I have on this lfth day of February 2022 served the foregoing
Petition to lntervene by electronic mail to the following:
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
ian.noriyuki@puc. idaho. sov
Donovan Walker
Regulatory Dockets
Idaho Power Company
dwalker@idahooower. com
[e-mail]
Tim Tatum
Vice President, Regulatory Affairs
Idaho Power Company
ttatum@ idahopower. com
Gregory M. Adams
Attorneys for Nortlw es t and
Intermountain P ower Producers
Coalition
[e-mail]
4891-8902-8621, v.4
Benjamin J. Otto
Emma E. Sperry
Attorneys for Idaho Consertation League
botto@ idahoconservation. ore
esperry@ idahoconservation. ore
Peter J. Richardson
Attorneys for the Industrial Customers of
Idaho Power
peter@richardsonadams. com
Dr. Don Reading
dreadine@m indsprine.com
C. Tom Arkoosh
Amber Dresslar
Attorneys for ldaHydro
tom.arkoosh@arkoosh. com
amber. dresslar@arkoosh. com
erin.ceci l@,arkoosh.com
,l )i,\ttri''lNt
Abigail R. Germaine
WPTF'S PETITION TO INTERVENE - 5