20230630Petition to Intervene.pdf

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 1
Idaho Conservation League, Petition to Intervene
Marie Callaway Kellner (ISB No. 8470)
710 N 6th Street
Boise, ID 83701
[phone]
[e-mail]

Attorney for the Idaho Conservation League

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMANY FOR AUTHORITY IN
INCREASE ITS RATES AND CHARGES
FOR ELECTIC SERVICE IN THE STATE
OF IDAHO AND FOR A SSOCIATED
REGULATORY ACCOUNT
TREATMENT
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CASE NO. IPC-E-23-11

PETITION TO INTERVENE

IDAHO CONSERVATION LEAGUE

COMES NOW the Idaho Conservation League (“ICL”) and hereby requests leave to
intervene in the above captioned matter to 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 Callaway Kellner
Attorney for the Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]

Please provide copies of all pleadings, production requests, production responses, Commission
orders, and other documents to the names and addresses above. Please provide the same
documents to the following:
RECEIVED
Friday, June 30, 2023 11:40:35 AM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 2
Idaho Conservation League, Petition to Intervene
Brad Heusinkveld
Idaho Conservation League, Energy Associate
710 N. 6th St.
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]

In the interest of reducing costs to all parties, pleadings, testimony, briefs, production
requests, responses, notices, Commission orders, and other filings may be submitted via
electronic mail in accordance with Idaho Public Utilities Commission Rule 31.01.01.063.02-03.
ICL reserves the right to request hard copies of papers and documents, as may be necessary with
appropriate notice and time.
2. Idaho Conservation League claims direct and substantial interest in this proceeding in its
organizational capacity and on behalf of our members who are customers of Idaho Power. As
Idaho’s largest state-based conservation organization, ICL has approximately 11,000 members,
many of whom are residential customers of Idaho Power. ICL’s Boise headquarters and Ketchum
office are respectively Idaho Power Schedule 84 and Schedule 7 customers. One of ICL’s chief
organizational goals is supporting energy decarbonization sufficient to mitigate the worst effects
of climate changes. Idaho Power’s operations and decarbonization plans are implicated in this
proceeding. As a result, ICL and its represented members claim a direct and substantial interest
in ensuring Idaho Power provides a fair compensation rate for exported solar and maintains
policies that do not unduly burden distributed energy customers. ICL’s intervention will respond
directly to the issues raised in Idaho Power’s application and will not unduly broaden the scope
of this docket.
3. ICL intends to fully participate in this matter as a party. The nature and quality of ICL’s
intervention in this proceeding is dependent upon the nature and effect of other evidence in this
proceeding. If necessary, we may introduce evidence, be heard in argument, and call, examine,
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 3
Idaho Conservation League, Petition to Intervene
and cross-examine witnesses. ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE, the Idaho Conservation League respectfully requests the Commission grant
this petition.

DATED this 30th day of June, 2023.

Respectfully submitted

/s/ Marie Callaway Kellner
Marie Callaway Kellner (ISB No. 8470)
Attorney for Idaho Conservation League

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 4
Idaho Conservation League, Petition to Intervene
CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of June, 2023, I delivered true and correct copies of
the foregoing PETITION TO INTEVENE to the following persons via the method of service
noted:

/s/ Marie Callaway Kellner

Marie Callaway Kellner (ISB No. 8470)
Attorney for the Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
[e-mail]

Electronic Mail Only (See Order No. 35058):

Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
[e-mail]

Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]

Idaho Power Company
Lisa Nordstrom
Megan Goicoechea Allen
Donovan E. Walker
1221 W. Idaho St., 83702
P.O. Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
[e-mail]
[e-mail]

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 5
Idaho Conservation League, Petition to Intervene

Timothy Tatum
Connie Aschenbrenner
Matt Larkin
[e-mail]
[e-mail]
[e-mail]

Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise , ID 83703
[e-mail]

Mike Heckler
Courtney White
3778 Plantation River Dr., Ste. 102
Boise, Idaho 83703
[e-mail]
[e-mail]

IIPA
Erik L. Olsen
Echo Hawk & Olsen, PLLC
P.O. Box 6119
Pocatello, ID 83205
[e-mail]

Lance Kaufman, Ph.D
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]

ICIP
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St.
Boise, ID 83702
[e-mail]

Dr. Don Reading
280 Silverwood Way
Eagle, ID 83616
[e-mail]

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 6
Idaho Conservation League, Petition to Intervene

Micron Technology, Inc.
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]

Austin Reuschhoff
Thorvald Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]