20230518Petition to Intervene.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Phone: (208) 391-2961
[e-mail]
Attorney for the Clean Energy Opportunities for Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPANY’S
APPLICATION FOR AUTHORITY
TO IMPLEMENT CHANGES TO
THE COMPENSATION
STRUCTURE APPLICABLE TO
CUSTOMER ON-SITE
GENERATION UNDER
SCHEDULES 6, 8, AND 84 AND TO
ESTABLISH AN EXPORT CREDIT
RATE METHODOLOGY
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CASE NO. IPC-E-23-14
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 the above-captioned matter. As discussed below, CEO has
direct and substantial interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Clean Energy Opportunities for Idaho
Courtney White & Mike Heckler
3778 Plantation River Drive, Suite 102
Boise, ID 83703
[e-mail]
[e-mail]
This Intervenor’s attorney is:
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise, Idaho 83703
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 1
IPC-E-23-14
RECEIVED
Thursday, May 18, 2023 3:23:14 PM
IDAHO PUBLIC
UTILITIES COMMISSION
Ph: (208) 391-2961
[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
conserving natural resources and reducing the costs to all parties, all documents and other filings
may be submitted via electronic mail in accordance with IPUC Rules 31.01.01.063.02-03 and
Order 35058.
2. CEO is a non-profit corporation incorporated under the laws of the State of Idaho.
3. CEO has a direct and substantial interest in this proceeding. The organization was
founded with a mission to bring problem-solving rigor and solution-focused approaches to
advance clean energy and better serve the long-term interests of Idahoans and future generations.
The need to bring these skills and approach into clean energy related dockets was an impetus for
founding the organization. CEO has intervened and actively participated in past dockets in
related subject matter, as well as filing a Petition seeking decisions on issues to be addressed in
this docket ( see IPC-E-22-12). CEO has a direct and substantial interest in continuing to
participate in these issues through this proceeding. Without an opportunity to intervene herein,
CEO would not have an adequate means of fully participating in the determination of matters
related to those issues. CEO aims to contribute from a perspective informed by collaborative
problem-solving approaches and multiple stakeholder interests.
4. CEO’s participation as an intervenor in this proceeding will not unduly broaden the
issues or delay the 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 parties in this proceeding because no other party adequately represents CEO’s interests.
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 2
IPC-E-23-14
5. CEO intends to fully participate in this matter as a party. The nature and quality of
CEO’s intervention in the proceeding is dependent upon the nature 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 pursuant to
IDAPA 31.01.01.161-165.
WHEREFORE, CEO respectfully requests the Commission grant this petition.
DATED this 18th day of May, 2023.
Respectfully submitted,
______________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 3
IPC-E-23-14
CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of May, 2023. I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Electronic Mail Delivery
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
Idaho PUC Staff
Riley Newton
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
[e-mail]
Idaho Power Company
Megan Goicoechea Allen
Lisa D. Nordstrom
[e-mail]
[e-mail]
[e-mail]
Idaho Conservation League
Marie Callaway Kellner
[e-mail]
IdaHydro
Tom Arkoosh
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman
[e-mail]
[e-mail]
_____________________________
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE 4
IPC-E-23-14