20230508Petition to Intervene.pdf

IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-14 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 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
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
Monday, May 8, 2023 2:22:46 PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION, Case No. IPC-E-23-14 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. Many ICL members
are customer generators, or interested in becoming customer generators. ICL intervened in
forgoing dockets on Idaho Power net metering and distributed generation policy in pursuit of its
organizational goal of electric grid de-carbonization. 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-23-14 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 8th of May 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-23-14 Page 4
Idaho Conservation League, Petition to Intervene
CERTIFICATE OF SERVICE
I hereby certify that on this 8th day of May, 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]
Idaho Power Company
Lisa Nordstrom Megan Goicoechea Allen Timothy Tatum
Connie Aschenbrenner
Grant Anderson 1221 W. Idaho St., 83702 P.O. Box 70
Boise, ID 83707
[e-mail] [e-mail] [e-mail] [e-mail]
[e-mail]
[e-mail]