20220711Petition to Intervene.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise,ID 83703
Phone: [phone]
[e-mail]
Attorney for the Clean Eneryy Opporfrmities of ldoho
IN THE MATTER OF IDAHO
POWER GOMPANY'S
APPLICATION TO COMPLETE
THE STUDY REVIEW PI{ASE OF
THE COMPREIIENSryE STUDY
OF COSTS AND BENEFITS OF
ON.SITE CUSTOMER
GENERATION & FOR
AUTHORITY TO IMPLEMENT
CTIANGES TO SCIIEDULES 6,8,
AND 84
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
)
)
)
CASE NO. IPC.E-22-22
CLEAN ENERGY OPPORTUNITIES
FOR IDAHO PETITION TO
INTERVENE
Pursuant to IDAPA 31.01.01.042, Clean Energy Opportunities for Idaho (*CEO") hereby
submits this petition to intervene in ttre above-captioned matter. As discussed below, CEO has
direct and subsantial interests in ttrese proceedings, and therefore should be granted intervention.
L. The name of this intervenor is:
Clean Energy Oppornrnities for Idaho
Courhey White & Mike Heckler
3778 Plantation River Drive
Suite 102
Boise,ID 83703
courtney(-d cleanenerqyopportunities. com
mike@ cleanenergyopportunities. com
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 1
rPC-E-22-22
-1 :! r, 4. I. ,.ir i l' (., !
This lntervenor's attomey is:
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise, Idaho 83703
Ph: [phone]
[e-mail]
Please provide copies of all pleadings, production requesB, 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, please serve hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission orders,
and other filings may be submitted via elecnonic mail in accordance with IPUC Rules
3r..01.01.063.02-03.
2. CEO is a nonprofit corporation incorporated under the laws of the State of ldaho.
3. CEO has a direct and substantial interest in this proceeding. A key focus of CEO's
efforts is the reduction of greenhouse gas emissions. One CEO priority is to expand customer
choice in effecting the emission characteristics of the energy they consume. The issues associated
with expanding customer alternatives for clean energy are integral to this docket. CEO aims to
contribute from a perspective informed by collaborative problem-solving approaches and multiple
sakeholder interests, consistent with the organization's goals for advancing clean energy and better
serving the long-term interests of Idahoans and future generations.
4. CEO's participation as an intervenor in this proceeding will not unduly broaden the
issues or delay ttre 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 panies in this proceeding because no other party adequately rcpresents CEO's interests.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETTTTON TO INTERVENE 2
IPC-E-22-22
5. CEO intends o fully participate in ftis matter as a party. The nature and quality of
CEO's intervention in the proceeding is dependent upon ttre natre 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 pusuant to
IDAPA 31.01.01.161-165.
WHEREFORE, CEO respectfully requess the Commission granttds petition.
DAIED this 11ft day of Ju1y,2022.
Respectfu lly submitted,
lil\k
Kelsey Jae
Atorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 3
IPC-E-22-22
CERTIFICATE OF SERVICE
I hereby certify that on this 11& day of July, I delivered tue and comct copies of tre
foregoing PETITION TO INTERVENE to tre following persons via the method of service noted:
Electonic Mail Delivery (See Order No. 34,602)
Idoho Public Utflities Commission
Jan Noriyuki
Commission Secrctary
secretary@puc. idaho. gov
Idaho PUC Staff
Riley Newton
Deputy Atomey General
Idaho Public Utilities Commission
[e-mail]. gov
Idoho Power Company
Lisa D. Nordsuom
Megan Goicoectrea Allen
[e-mail]
mgoicoecheaallen@idahopower. com
dockets@ idahopower. com
rs\e
Kelsey Jae
Anorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO . PETITION TO INTERVENE 4
IPC-E-22-22