20231212Petition for Intervenor Funding.pdf

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 1
NW Energy Coalition Petition for Intervenor Funding
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC
SERVICE IN THE STATE OF IDAHO AND
FOR ASSOCIATED REGULATORY
TREATMENT
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CASE NO. IPC-E-23-11
PETITION FOR INTERVENOR
FUNDING
NW ENERGY COALITION
COMES NOW the NW Energy Coalition (“NWEC”) pursuant to Idaho Code § 61-617A
and IDAPA 31.01.01.161-165 with the following application for intervenor funding. NWEC is
an intervenor the above captioned docket by Order No. 35867. This application is timely
pursuant to Commission instructions and consent of parties at the November 29, 2023 technical
hearing to submit such applications by December 13, 2023. IDAPA 31.01.01-164. For the
following reasons, an award of intervenor funding is warranted.
I.Idaho Code § 61-617A and IDAPA 31.01.01.161 Utility Requirement
Idaho Power is a regulated electric and gas utility in the state of Idaho with gross intrastate
annual revenues exceeding three million and five hundred thousand dollars ($3,500,000).
II.Idaho Code § 61-617A and IDAPA 31.01.01.162 Intervenor Requirements
The requirements for an application for intervenor funding provided by I.C. § 61-617A and
IDAPA 31.01.01-162 are set forth below. In each, an award for intervenor funding to NWEC is
merited.
RECEIVED
2023 DECEMER 12, 2023 6:05PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 2
NW Energy Coalition Petition for Intervenor Funding
1. Itemized list of expenses
NWEC incurred compensable costs and expenses in this procedure. Idaho Code
empowers the Commission to award “legal fees, witness fees, and reproduction costs.” I.C. § 61-
617A. The attached Exhibit A is an itemized list of expenses incurred by NWEC in this
proceeding. Expenses include time by F. Diego Rivas, attorney for NWEC. Broadly, NWEC
reviewed the Company’s application, petitioned for and were granted intervention, reviewed
relevant discovery, participated in settlement negotiations, and prepared a letter in support of the
proposed settlement before the Commission. A more detailed account of expenses, time, and
hourly rates is included in Exhibit A. IDAPA 31.01.01-162.01. NWEC seek recovery of these
legal fees. In all these efforts NWEC focused on a limited number of issues relevant to our
interests and aimed to use our time and the time of other parties efficiently. IDAPA 31.01.01-
162.01.
2. Statement of Proposed Findings
NWEC is a party to the Stipulation and Settlement put forth before the Commission and
recommends the Commission approve the Settlement in its entirety. Throughout the proceeding,
NWEC maintained that the basic charge should be set at a level necessary to recover only the
marginal cost of adding a new customer to the grid. Setting the basic charge higher than the costs
of customer service, metering, and billing send a negative price signal for customers to invest in
energy efficiency and disproportionately hurts low-income and low-usage customers. As such,
NWEC opposed IPC’s initial proposal to increase the basic charge to $35/month. Similarly,
NWEC opposed IPC’s proposal to flatten the existing block rates. The Settlement presents a
reasonable compromise of these issues, and thus the Commission should find the Settlement to
be just and reasonable.
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 3
NW Energy Coalition Petition for Intervenor Funding
3. Statement Showing Costs
NWEC requests $2,325 in intervenor funding. Exhibit A offers a detailed account of
expenses. The hourly rates and time spent by NWEC’s staff attorney, F. Diego Rivas, is
reasonable for a complex utility rate case. Rivas has a combined 14 years of direct policy
experience and as counsel practicing before Public Utility Commissions in Idaho, Montana, and
Oregon. The hourly rate of $150 is consistent with his experience and local markets.

4. Explanation of Costs Statement
The recovery of costs in this matter supports the work of NWEC in pursuing energy
policy in the public interest. NWEC represents over 100 member organizations in the
Northwest, including eleven in Idaho, to pursue sustainable and equitable energy policy. NWEC
staff are considered an experts in rate design, providing testimony on rate design issue in Idaho,
Montana, Washington, and Oregon.
NWEC is funded through membership dues and individual donations. While NWEC
budgets prudently for programmatic efforts, this complex matter demanded considerable time
and attention for key staff to provide “full and fair representation” before the Commission as
stated in I.C. § 61-617A.

5. Explanation of Differences
Until final settlement, NWEC’s position on rate design materially differed from that of
Idaho Power and Commission Staff. Idaho Power initially proposed a modernization plan that
would see the basic charge rise to $35/month over the next five years. Through its own analysis,
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 4
NW Energy Coalition Petition for Intervenor Funding
NWEC provided the baseline figure for parties supporting a lower basic charge. NWEC
continues to believe that, based on costs provided by the Company, a reasonable basic charge
that covers the cost of providing customer service, metering, and billing is lower than the settled
upon terms. The independently determined figure was relied upon by other parties in settlement
negotiations which ultimately saw parties agree to raising the residential basic charge to
$10/month in rate year 1 and $15/month in rate year 2 of the two-year rate plan. NWEC
continues to believe that rate design generally should encourage the efficient use of electricity
and allow customers to control their utility bills through low basic charges and corresponding
volumetric charges.
NWEC also opposed Idaho Power’s request to eliminate inclining block rates, and
suggested that Idaho Power better utilize time-of-use rates as a means to ensure the efficient use
of energy at times of low overall demand.

6. Statement of Recommendation
NWEC recommends the Commission approve the all-party, all-issue settlement and
provide recovery of reasonable intervention costs for parties in this case.

7. Statement Showing Customer Class
NWEC’s members are also members of Idaho Power’s residential and small commercial
classes.

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 5
NW Energy Coalition Petition for Intervenor Funding
Conclusion
In sum, for the foregoing reasons, NWEC respectfully requests the Commission grant this
Petition for Intervenor Funding in the amount of $2,325.00.

Respectfully submitted this 12th day of December 2023.

____________________
F. Diego Rivas (appearing pro hac vice)
Regulatory Counsel
NW Energy Coalition
1101 8th Ave
Helena, MT 59601
[phone]

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 6
NW Energy Coalition Petition for Intervenor Funding
Exhibit A – NWEC Statement of Costs Incurred

Name Task Description
Time
(Hrs)
Rate
($/hr) Sum ($)
Rivas
Application
Review
Read application and relevant
testimonies, identify issues of
interest, attend parties meeting 4 150 600
Rivas Intervention
Draft and submit intervention and
pro hac petitions 0.5 150 75
Rivas
Settlement
Conferences
Prepare for and attend settlement
discussions 9.2 150 1380
Rivas
Testimony
Review Review settlement and testimonies 1.5 150 225
Rivas Hearing
Remote listening of technical
hearing 0.3 150 45

For Professional Services Rendered
($): $2,325.00
Direct Costs ($): $0.00

Total Intervenor Funding
Requested: $2,325.00

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 7
NW Energy Coalition Petition for Intervenor Funding

CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of December, 2023, I delivered true and correct
copies of the foregoing Petition for Intervenor Funding to the following persons via the method
of service noted:

/s/ F. Diego Rivas
Regulatory Counsel
NW Energy Coalition
1101 8th Ave
Helena, MT 59601
[e-mail]

Electronic Mail Only (See Order No. 35058):
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[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.
P.O. Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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]

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-11 Page 2
NW Energy Coalition Petition for Intervenor Funding

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]

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]