20220203Petition to Intervene.pdf

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Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise,ID 83703
Phone: [phone]
[e-mail]
Aaorney for the Clean Energt Opportunities of ldaho
IN TIIE MATTER OF IDAHO )
POWER COMPAI\IY'S )
APPLICATION FORAPPROVAL OF )
SPECIAL CONTRACT AND TARIFF )
SCHEDULE 33 TO PROVIDE )
ELECTRIC SERVICE TO BRISBIE, )
LLC'S DAIA CENTER EACILITY )
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E.2142
CLEAI\I ENERGY OPPORTUNITIES
FOR IDAHO
PETITION TO INTERYENE
Pursuant to IDAPA 31.01.01 .A42, Clean Energy Opportunities for ldaho ("CEO") hereby
submits this petition to intervene in the above-captioned matter. As discussed below, CEO has
direct and substantial interests in these proceedings, and therefore should be granted intervention.
l. The name of this intervenor is:
Clean Energy Opportunities for Idaho
Courtney White & Mike Heckler
3TTSPlantation River Drive, Suite 102
Boise, ID 83703
courtnev@c leanenergvopportunities.conr
m i ke@c leanenereyopportun ities.com
This Intervenor's attorney is:
Kelsey Jae (lSB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise,Idaho 83703
Ph: [phone]
kelsev@kelsev i ae.conr
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITTON TO INTERVENE
LPC-E-zI-42
I
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the names and addresses above. In the interest of
conserving natural resources and reducing the costs to all parties, all documents and other filings
may be submitted via electronic mail in accordance with IPUC Rules 31.01.01 .063.02-03 and
Order 35058.
2. CEO is a non-profit corporation incorporated under the laws of the State of Idaho.
3. CEO has a direct and substantial interest in this proceeding. The organization was
founded with a mission to bring problem-solving rigor and solution-focused approaches to
advance clean energy and better serve the long-term interests ofldahoans and future generations.
The need to bring these skills and approach into clean energy related dockets was an impetus for
founding the organization. A key purpose of CEO's efforts is the reduction of greenhouse gas
emissions. As the first specific example of a "Clean energy your way" program implementation
and, with large portions of the direct testimony of the Idaho Power representatives redacted,
CEO believes its active participation in this docket is essential to ensure that it can effectively
participate in other related, dockets such as IPC-E-21-40. CEO aims to contribute from a
perspective informed by collaborative problem-solving approaches and multiple stakeholder
interests.
4. CEO's participation as an intervenor in this proceeding will not unduly broaden the
issues or delay the proceeding because CEO's interest is directly related to the subjects addressed
in Idaho Power's application. CEO's involvement in this proceeding will not be duplicative of
other parties in this proceeding because no other party adequately represents CEO's interests.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 2
tPC-E-zr-42
5. CEO intends to fully participate in this matter as a parly. The nature and quality of
CEO's intervention in the proceeding is dependent upon the nature and effect of other evidence
in this proceeding. If necessary, CEO may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. CEO intends to seek intervenor funding pursuant to
rDAPA 3 I .01.0 r.16l -1 65.
WHEREFORE, CEO respectfully requests the Commission grant this petition.
DATED this 3rd day of February,2022.
Respectfu lly submitted,
rs\k
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTTJNITIES FOR IDAHO. PETITION TO INTERVENE
IPC-E..2142
3
CERTIHCATE OF SERVICE
I hereby certifr that on this 3rd day of February 2022.I delivered tnre and correct copies
of the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Electronic Mail Deliverv
Idaho Public Utilities Commission
JanNoriyuki
Commission Secretary
secretary@nuc. idaho. sov
Idaho PUC Staff
RileyNewton
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]. eov
Idalro Power Company
Donavan E. Walker
Tim Tatum
dwalker@.idahooower.com
[e-mail]
dockets@ idahopower.com
r\k
Kelsey Jae
Attorneyfor CEO
CLEAN ENERGY OPPORTTJNITIES FOR IDAHO . PETITION TO INTERVENE 4
IPC-EAI.4Z