20230803Petition to Intervene.pdf

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PARSONS BEHLE & LATIMER Norman M. Semanko, ISB No. 4761 800 West Main Street, Suite 1300 Boise, Idaho 83702 Telephone: [phone] Email: [e-mail] PARSONS BEHLE & LATIMER Justina A. Caviglia, pro hac vice pending 50 West Liberty Street, Suite 750 Reno, Nevada 89502 Telephone: [phone] Email: [e-mail] Attorneys for Walmart Inc.

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 ACCOUNT TREATMENT.
CASE NO. IPC-E-23-11 PETITION TO INTERVENE OF WALMART INC.
Pursuant to Rules 71-75 of the Idaho Public Utilities Commission’s Rules of Practice and
Procedure, and the Notice of Intervention Deadline (Order No. 35825), Walmart Inc. (“Walmart”)
petitions the Idaho Public Utilities Commission (“Commission” or “IPUC”) for leave to intervene
in the above-captioned matter. In support of this petition, Walmart states as follows:
1. The names and addresses of the representatives of Walmart are:
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
Telephone: [phone]
[e-mail]

Justina A. Caviglia, pro hac vice pending
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
RECEIVED
Thursday, August 3, 2023 4:12:43 PM
IDAHO PUBLIC
UTILITIES COMMISSION

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Reno, Nevada 89502 Telephone: [phone] [e-mail]
Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
Telephone: [phone]
[e-mail]

Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the names and addresses above. In the interest of
conservation and cost reduction, please provide hard copies of pleadings, testimony, and briefs
only. All other documents may be provided via electronic mail in accordance with IPUC Rules
31.01.01.063.01-.02.
2. Walmart is an American multinational retail corporation with stores in all fifty (50)
states and Puerto Rico. Walmart operates 27 retail units and employs over 9,000 associates in
Idaho. In the fiscal year ending 2023, Walmart purchased over $553 million worth of goods and
services from Idaho-based suppliers, supporting over 8,000 supplier jobs.1 Walmart is also a large
commercial customer of Idaho Power Company (“Idaho” or “Company”), owning and operating
approximately 16 retail store and related facilities in the Company’s territory. Collectively, these
facilities consume over 50 million kWh of electricity annually.
3. Walmart was not able to timely respond to the Idaho Power’s Application due to
its internal review process. After thoroughly reviewing the application and the potential impact
on Walmart’s power costs, Walmart determined that it would be in its best interest to intervene in
this case. Walmart believes that its intervention will not prejudice any parties to this matter or

1 https://corporate.walmart.com/about/idaho

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otherwise delay this matter. Walmart agrees to accept the record and the schedule for this case as
it stands.
4. Walmart has a direct, immediate, diverse and substantial interest in the outcome of
this case, and the interests of Walmart will not be adequately represented by any other party to this
proceeding. A Commission decision in this proceeding will have a direct, material impact on the
electric rates and terms and conditions of service Walmart will be subject to as a result of this case.
5. Walmart anticipates participating in this matter to the extent necessary to ensure its
interests in Idaho are protected, with full rights of a party to perform discovery, submit testimony,
examine witnesses, participate in hearings and present evidence on any issues raised in this matter.
6. Walmart has not yet determined the extent of its participation or the precise nature
of the relief it will request but the interests of justice and the orderly and prompt conduct of this
proceeding will not be impaired by the grant of Walmart’s petition to intervene. Neither will
Walmart’s participation unnecessarily broaden the issues or burden the record in this proceeding.
WHEREFORE, Walmart respectfully requests that the Commission grant its Petition to
Intervene in this matter with full party status.

DATED this 3rd day of August 2023.

PARSONS BEHLE & LATIMER

/s/ Justina A. Caviglia
Norman M. Semanko, ISB No. 4761
Justina A. Caviglia, Pro Hac Vice

Attorneys for Walmart, Inc.

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CERTIFICATE OF SERVICE (Case Nos. IPC-E-23-11)
I hereby certify that on this 3rd day of August 2023, I caused to be served by e-mail, a true
and correct copy of the foregoing document, PETITION TO INTERVENE OF WALMART
INC., to the following:
IDAHO PUBLIC UTILITIES COMMISSION
Jan Noriyuki: [e-mail]
[e-mail]

IDAHO DEPUTY ATTORNEY GENERAL
Dayn Hardie: [e-mail]
Chris Burdin: [e-mail]

IDAHO POWER COMPANY
Lisa D. Nordstrom: [e-mail]
Donovan E. Walker: [e-mail]
Megan Goicoechea Allen: [e-mail]
Timothy Tatum: [e-mail]
Connie Aschenbrenner: [e-mail]
Matthew T. Larkin: [e-mail]
[e-mail]

CLEAN ENERGY OPPORTUNITIES FOR IDAHO
Michael Heckler: [e-mail]
Courtney White: [e-mail]

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
Eric L. Olsen: [e-mail]
Lance Kaufman, Ph.D.: [e-mail]

INDUSTRIAL CUSTOMERS OF IDAHO POWER
Peter J. Richardson: [e-mail]
Dr. Don Reading: [e-mail]

MICRON TECHNOLOGY, INC.
Jim Swier: [e-mail]
Austin Rueschhoff: [e-mail]
Thorvald A. Nelson: [e-mail]
Austin W. Jensen: [e-mail]
[e-mail]
[e-mail]

. . .

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IDAHYDRO
Tom Arkoosh: [e-mail]
[e-mail]

CITY OF BOISE
Ed Jewell: [e-mail]
Darrell Early: [e-mail]
Wil Gehl: [e-mail]
[e-mail]

IDAHO CONSERVATION LEAGUE
Marie Callaway Kellner: [e-mail]
Brad Heusinkveld: [e-mail]

U.S. DEPARTMENT OF ENERGY
Peter Meier: [e-mail]
Dwight Etheridge: [e-mail]

NW ENERGY COALITION
F. Diego Rivas: [e-mail]

/s/ Roni L. Shaffer
Employee of Parsons Behle & Latimer