20230612Petition to Intervene.pdf

VOTE SOLAR’S PETITION TO INTERVENE - 1

Abigail R. Germaine (ISB No. 9231) Elam & Burke, P.A.
251 E. Front St. Suite 300
P.O. Box 1539 Boise, Idaho 83701 [phone] [phone] (fax)
[e-mail]

Attorney for Vote Solar BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

FOR
-SITE 8,
CASE NO. IPC-E-23-14
VOTE SOLAR’S PETITION TO INTERVENE

COMES NOW, Vote Solar and pursuant to Rules 71 through 73 of the Rules of Procedure
of the Idaho Public Utility Commission (IDAPA 31.01.01.71 – 31.01.01.73), and pursuant to the
Application filed on May 1, 2023, and Notice of Application, Notice of Intervention Deadline,
Order No. 35790, filed on May 23, 2023, hereby petitions the Idaho Public Utilities Commission
(“Commission”) for leave to intervene herein and to appear and participate as a party, and as basis
therefore states as follows:
1. The name and address of this Intervenor is:
Vote Solar
c/o Kate Bowman, Regulatory Director, Interior West 299 S. Main St. Suite 1300, PMB 93601 Salt Lake City, UT 84111 [e-mail]
2. Copies of all pleadings, production requests, production responses, Commission
orders, and other documents should be provided to Abigail R. Germaine and Kate Bowman at:
RECEIVED
2023 JUNE 12, 2023 4:49PM
IDAHO PUBLIC
UTILITIES COMMISSION
VOTE SOLAR’S PETITION TO INTERVENE - 2

Abigail R. Germaine Elam & Burke, P.A.
251 E. Front St. Suite 300
P.O. Box 1539 Boise, Idaho 83701 [phone] [phone] (fax)
Idaho State Bar No. 9231
Email: [e-mail] Vote Solar c/o Kate Bowman, Regulatory Director, Interior West
299 S. Main St. Suite 1300, PMB 93601
Salt Lake City, UT 84111 [e-mail] In the interest of reducing costs to all parties, please provide hard copies of pleadings,
testimony, and briefs only. All other production requests, responses, notices, Commission orders
and other filings may be submitted via electronic mail in accordance with Rule 63 of the Rules of
Procedure of the Idaho Public Utility Commission (IDAPA 31.01.01.063).
3. Vote Solar is an independent 50l(c)(3) non-profit working to repower the United
States with clean energy by making solar power more accessible and affordable. Vote Solar seeks
to promote the development of solar at every scale, from distributed roof top solar to large utility-
scale plants, and works to foster economic opportunity and promote energy security by making
solar a mainstream energy resource. Vote Solar works together with partners in local communities
and engages in regulatory proceedings nationwide to implement, maintain, and enhance the
policies necessary to build robust solar markets in key states, including Idaho. Vote Solar has over
80,000 members nationally including members in Idaho Power's service territory. Vote Solar has
a direct and substantial interest in this proceeding due to the impact to its members served by Idaho
Power and to its role advocating for solar energy. Vote Solar has extensive experience with state-
level regulatory engagement in over 22 states, particularly related to the topics of clean energy
VOTE SOLAR’S PETITION TO INTERVENE - 3

resources, distributed solar, and rate design to support the adoption of clean and efficient energy
technologies. Vote Solar has also participated in Case Nos. IPC-E-17-13, 18-15, 18-16, and 19-15
and has extensive knowledge that will be valuable in examining Idaho Power’s request in this
Application.
4. Vote Solar has a direct and substantial interest in this matter as an industry advocate
for renewable energy resources in the West. Vote Solar, and many of its community partners and
represented constituents, may be negatively impacted by Idaho Power Company’s proposal to
change its on-site, self-generation tariffs, and the structure and design of its on-site generation
offering. Many of Vote Solar’s constituents are on-site generators and the changes to the Export
Credit Rate (“ECR”) and other methodologies could have negative impacts on these generators
and Idaho Power customers generally.
5. Without the opportunity to intervene herein, Vote Solar would be without any
means of participation in this proceeding which may have a negative impact on on-site generation
customers. If allowed to intervene, Vote Solar will participate in the proceedings and appear in all
matters as may be necessary and appropriate; present evidence; call and examine witnesses;
present argument; and otherwise fully participate in these proceedings.
6. Granting Vote Solar’s petition to intervene will not unduly broaden the issues, nor
will it prejudice any party to this case.
7. This Petition to Intervene is timely filed under Rule 73, IDAPA 31.01.01.073
because it is filed within the twenty-one (21) day deadline to intervene established by Order No.
35790.
8. Vote Solar intends to fully participate in this matter as a party. The nature and
quality of Vote Solar’s intervention in this proceeding is dependent on the nature and effect of
VOTE SOLAR’S PETITION TO INTERVENE - 4

other evidence in this proceeding. Vote Solar requests that the Commission issue a timely order
granting this Petition to Intervene following the seven-day opposition period set forth in IDAPA
31.01.01.075.
WHEREFORE, Vote Solar respectfully requests that this Commission grant this Petition
to Intervene.
DATED: June 12, 2023.
ELAM & BURKE, P.A.

_______________________________ Abigail R. Germaine Attorney for Vote Solar

VOTE SOLAR’S PETITION TO INTERVENE - 5

CERTIFICATE OF SERVICE
I HEREBY certify that I have on this 12th day of June, 2023 served the foregoing Petition to Intervene by electronic mail to the following:
Commission Staff Idaho Public Utilities Commission 11331 W. Chinden Blvd., Ste. 201-A Boise, ID 83714 [e-mail]
[e-mail] Chris Burdin
Deputy Attorney General Idaho Public Utilities Commission 1131 W. Chinden Blvd., Ste. 201-A
Boise, ID 83714 [e-mail]
Brad Heusinkveld Idaho Conservation League, Energy Associate
Attorneys for Idaho Conservation League 710 N. 6th St.
Boise, ID 83702 [e-mail] [e-mail]

Megan Goicoechea Idaho Power Company PO Box 70 Boise, ID 83707 [e-mail] [e-mail] [e-mail]
Idaho Irrigation Pumpers Association Echo Hawk & Olsen, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 [e-mail]
Micron Technology, Inc.
8000 South Federal Way Boise, ID 83707 [e-mail]
2623 NW Bluebell Place
Corvallis, OR 97330 [e-mail]
Law for Conscious Leadership
Clean Energy Opportunities for Idaho 920 N. Clover Dr. Boise, ID 83703 [e-mail]
Attorneys for IdaHydro
Arkoosh Law Offices 913 W. River Street, Suite 450 Boise, ID 83701 [e-mail] [e-mail]
Connie Aschenbrenner Grant Anderson Idaho Power Company PO Box 70 Boise, ID 83707 [e-mail] [e-mail]
Mike Heckler Clean Energy Opportunities for Idaho 3778 Plantation River Dr. Suite 102 Boise, ID 83703
[e-mail] [e-mail]
VOTE SOLAR’S PETITION TO INTERVENE - 6

Thorvald A. Nelson Austin W. Jensen Micron Technology, Inc. Holland & Hart, LLP 555 17th St. Suite 3200 Denver, CO 80202 [e-mail] [e-mail] [e-mail] [e-mail] [e-mail]
Boise City Attorney’s Office 150 N. Capitol Blvd. Boise, ID 83701
Boise City Attorney [e-mail] [e-mail]

_____________________________________
Abigail R. Germaine