20221208Petition to Intervene.pdf

t.T,UEIVED
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise,ID 83703
Phone: [phone]
[e-mail]
Attorney for the Clean Energy Opportunities of ldaho
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOI.]NTAIN POWERFOR
AUTHORITY TO IMPLEMENT
TTIE RESIDENTIAL RATE
MODERNIZATION PLAI\
,in!l [rrt -8 PH 12: 33
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BEFORE TIIE IDAHO PUBLIC UTILMES GOMMISSION
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cAsE NO. PAC-E-22-15
CLEAN ENERGY OPPORTTJNTflES
FOR IDAIIO'S PETITION TO
INTERVENE
Pursuant to IDAPA 31.01.01.042, Clean Energy Oppornrnities for Idaho ('CEO') hereby
submis 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 Eneryy Opportunities for Idaho
Courtney White & Mike Heckler
3778 Plantation River Drive
Suite 102
Boise, ID 83703
co u nne.y@cleanenerqy opDortun ities. com
Itles.com
This Intervenor's attorney is:
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr., Boise, Idaho 83703
Ph: [phone]
[e-mail]
CLEAN ENERGY OPPORTUNITIES FOR IDAHO. PETITION TO INTERVENE - 1.
PAC-E-22-15
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, please serve hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
2. CEO is a nonprofit corporation incorporated under the laws of the State of tdaho.
3. CEO has a direct and substantial interest in this proceeding. One CEO priority is to
expand customer choice in effecting the emission characteristics of the energy they consume.
Issues associated with rate design, such as monthly fixed fees and time-varying rates, have an
impact on customer choices for managing their electricity needs and are integral to this docket.
CEO aims to contribute from a perspective informed by collaborative problem-solving
approaches and multiple stakeholder interests, consistent with the organization's goals for
advancing clean energy and better serving the long-term interests of ldahoans and future
generations.
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 Rocky Mountain 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.
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
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITTON TO INTERVENE - 2
PAC-E-22-15
tn this prccecding. If nccessary, CEO nay inuo&rcs sldcrrcG, bG hrrd ln argumcrrg and csll,
examine, ad croos{romine wimscs" CEO intenda to soek intervenor funding purtumtto
IDAPA 31.01.01.161-165.
WHEREFORE, CEO receecduUy rcquess the Commisoioa tr.Dt Ods pedtiou.
DAf,ED ffs eh dly of ncdcr, 2022.
Respcdutly cubniuc4
rs\&u
Kefucy Jac
Attorqyfor CEO
CLEAN ENERGY OPPORTI.IMTXES FOR IDATIO - PETITION TO INTERII/ENE.3
PAC-8"22-15
CERTIFICAIE OF SERVICE
I hereby certify that on this 8th day of December, 2022,1delivered tue and correct
copies of the foregoing PETffiON TO INTERVENE to the following persons via the method of
service notd:
Electonic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
secretary@puc. idaho. gov
Idaho PUC Stoff
Riley Newton
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]. gov
Roclcy MountainPower
Mark Alder 1407 West North Temple, Suite
330 Salt Lake Ciry, UT 84116
mark.alder@pacif icorp.com
Joe Dallas 825 NE Multromah Street, Suite
20fi) Portland, OR 97232
i [e-mail]
r\e
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - PETITION TO INTERVENE.4
PAC-E-22-15