20220615Petition to Intervene.pdf

Marie Kellner,ISB No. 8470
710 N 66 Street
Boise, D 83702
Ph: [phone] x220
Fax [phone]
mkellner@idahoconservation. org
IN THE MATTER OF IDAHO POWER )
COMPAI\Y'S APPLICATION FOR A )
CERTIFICATE OF PUBLIC CONYEI\IIENCE )
AI\[D NECESSITY TO ACQUIRE RESOT]RCES )
TO BE ONLII\E BY 2023 TO SECTJRE )
ADEQUATE AND RELIABLE SERVICE TO )
rTs cusToMERs )
CASE NO. IPC-E-22-I3
PETITION TO INTERVENE
OF THE IDAIIO
CONSERVATION LEAGUE
Attomey for the Idaho Conservation kague
BEFORE THE IDAIIO PTJBLIC UTILITIES COMMISSION
COMES NOW the Idaho Conservation League ("ICL") and hereby requests leave to
intervene in the above captioned matter pursuant to the Idaho Public Utilities Commission Rules
of Procedure, IDAPA 31.01.01.071-073. As discussed below, ICL has direct and substantial
interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Marie Kellner
Idaho Conservation League
710 N. 6tr St.
Boise,Idaho 83702
Ph: [phone] x220
mkellner@idahoconservation. org
Emma E. Sperry
Idaho Conservation League
710 N. 6ft St.
Boise,Idaho 83702
Ph: 208-537-7993 x230
esperry@idahoconservation. org
Please provide copies ofall pleadings, production requests, production responses,
Commission orders, and other documents to the names and address above. In the interest of
conserving natural resources and reducing the costs to all parties, please provide hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission
rPC-E-22-13
ICL PETITION TO INTERVENE 1 Jwrc 15,2022
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
2.lCL claims a direct and substantial interest in this proceeding as a customer and on
behalf of our members who are customers of Idaho Power. As Idaho's largest state-based
conservation organization, we have approximately 11,000 members most of whom are
residential customers of Idaho Power. ICL's Boise headquarters is a Schedule 9ldaho Power
customer, and our Ketchum field office is a Schedule 7 customer. ICL and our members have a
direct and substantial interest in ensuring that Idaho Power provides access to clean energy,
including energy storage options, in the most economical manner possible in order to meet our
organizational goals and our members' needs. ICL's intervention will respond directly to the
issues raised in Idaho Power's application and thus will not unduly broaden the issues.
3. ICL intends to fully participate in this matter as a party. The nature and quality of
ICL's intervention in the proceeding is dependent upon the nature and effect of other evidence in
this proceeding. If necessary, ICL may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 15th day of June,2022.
Respectfully submitted,
/s/ Marie Kellner
Marie Kellner
Idaho Conservation League
TPC-E-22-T3
ICL PETITION TO INTERVENE 2 Jvrc 15,2022
CERTIFICATE OF SERVICE
I hereby certiff that on this 1 5th day of June , 2022,I delivered tue and correct copies of
the foregoing PETIION TO INTERVENE to the following percoffr via the method of service
noted:
/s/ Marie Kellner
Marie Kellner
Electronic mail only (See Order 35058):
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
i an.nori)ruki@Fuc. idaho. eov
[e-mail]. eov
Idaho Power
Donovan E. Walker
Tim Tatum
dwalker@ idahopower. com
ttatum@ i dahopower. com
dockets@ i dahopower. com
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@ richardsonadams. com
Dr. Don Reading
dreadine@mindsprine. com
IdaHydro
Tom Arkoosh
Amber Dresslar
Arkoosh Law Offices
tom. arkoosh@ arkoosh. com
arrber. &esslar@ arkoosh. com
erin.cecil@ arkoosh. com
IPC-E-22-13
ICL PETITION TO INTERVENE 3 Jwrc 15,2022