20220203Petition to Intervene.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise,ID 83703
Phone: [phone]
[e-mail]
Attorneyfor the Clean Energt Opportunities of ldaho
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BEFORE TIM IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE MATTER OF IDAHO
POWER COMPANY'S2O?I
INTEGRATED RESOURCE PLAI\I
CASE NO. IPC-E-2I43
CLEAN ENERGY OPPORII]NITIES
FOR IDAHO
PETITION TO INTERVENE
Pursuant to IDAPA 3 I .01 .01 .042, 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
courtney@c I eanenergyopportun ities. com
m ike@c leanenersvopportunities.com
This Intervenor's attorney is:
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise, ldaho 83703
Ph: [phone]
[e-mail]
Please provide copies of all pleadings, production requests, production responses,
CLEAN ENERGY OPPORTTJNITIES FOR IDAHO . PETITION TO INTERVENE
tPC-E-21-43
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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. One of CEO's principals, Michael Heckleq has participated actively as a member of
the Integrated Resource Plan Advisory Council for many years. Based on that experience as well
as upon references made in un-redacted portions of testimony submitted in IPC-E-21-42,CEO
believes that participating in and having access to reviews of the IRP data and analyses will be
essential to ensure that, in addition to participating in a thorough review of the IRP offering
itself, CEO can also effectively participate in dockets such as IPC-E-2I-40 and IPC-E-21-42that
will inherently rely heavily upon those IRP analyses and data. 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
CLEAN ENERGY OPPORTUNITIES FOR IDAHO . PETITION TO INTERVENE
rPC-E-zt-43
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in ldaho Powey'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.
5. CEO intends to fully participate in this matter as a party. 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
IDAPA 3 1.01.01. 161-165.
WHEREFORE, CEO respectfully requests the Commission grant this petition.
DATED this 3rd day of February,20Z2.
Respectfu lly submitted,
rs\k
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTI.JNITIES FOR IDAHO - PETITION TO INTERVENE
IPC-8.2143
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CERTIFICATE OF SERVICE
I hereby certiff that on this 3rd day of February,2022.I delivered true 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
Jan Noriyuki
Commission Secretary
[e-mail]. sov
Idaho PUC Staff
RileyNewton
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]. gov
Idaho Power Cotnpany
Lisa D. Nordstrom
Tim Thtum
Alison Williams
[e-mail]
awi I I [e-mail]
ttatum @idahoDower.com
doc ket s @. i da h o oower. com Kelsey Jae
Attorneyfor CEOIdaho Conservation League
Benjamin J. Otto
Emma E. Sperry
botto@ idahoconservation.org
e sperr,v @ i dah oco n servati on. org
Industrial Customers of ldaho Power
Peter J. Richardson
RichardsonAdams, PLLC
[e-mail]
Dr. Don Reading
dreading@m indspring.com
Kiki Leslie A. Tidwell, pro se
kt i d we I I 2 02 2 (D.s.ntail.com
CLEAN ENERGY OPPORTUNITIES FOR IDAHO. PETITION TO INTERVENE
[PC-E-ZI-43
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