20221221Petition to Intervene.pdf

Marie Callaway Kellner (ISB No. 8470)
710 N 66 Street
Boise,ID 83701
(208) s37-7993
[e-mail]
IN TIIE MATTER OF TIIE
APPLICATION OF ROCKY
MOUNTIAI\ POWER FOR TIIE
AUTHORITY TO IMPLEMENT
TIIE RESIDENTIAL RATE
MODERJ\IIZATION PLAII
,{ECEIVEO
illi Dt[ 2 I PH 2:53
,,''':.liir i'UELIC'-'r ,'i i':5 i,ih4Ml$SION
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMIVIISSION
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CASE NO. PAC.E.22.I5
PETITION TO INTERVENE
IDAIIO CONSERVATION LEAGUE
AI\ID NW ENERGY COALITION
COMES NOW the Idaho Conservation League ("ICL-) and the NW Energy Coalition
("NWEC") 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. This
petition is accompanied by a MOTION FOR LIMITED ADMISSION PRO HAC VICE for F.
Diego Rivas, attorney for NWEC. As discussed below, ICL and NWEC have direct and
substantial interests in these proceedings, and therefore should be granted intervention.
l. The name of this intervenor is:
Marie Callaway Kellner
Attorney for the Idaho Conservation League
710 N. 6ft St.
Boise,Idaho 83702
Phone: [phone]
Email: [e-mail]
IDAHo PUBLIC UTILIIIES CONil\4ISSION, Case No. PAC.E-22-I5
Idaho Conservation League, Petition to Intervene
Page I
F. Diego Rivas
Attorney for the NW Energy Coalition
1l0l 8ft Ave
Helena, MT 59601
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:
Brad Heusinkveld
ldaho Conservation League, Energy Associate
710 N. 6m 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 submiffed via
electronic mail in accordance with Idaho Public Utilities Commission Rule 31.01.01.063.02-03.
ICL asks to reserve the right to request hard copies of papers and documents, as may be
necessary with appropriate notice and time.
2. Idaho Conservation League and NW Energy Coalition claim a direct and substantial
interest in this proceeding on behalf of our members who are customers of Rocky Mountain
Power, a division of PacifiCorp ("Rocky Mountain Power" or "Company"). As Idaho's largest
state-based conservation organization, ICL has approximately I1,000 members, many of whom
are residential customers of Rocky Mountain Power. ICL represents its organizational interest,
the interests of its members generally, and those who are Residential Service Schedule I
customers and Electric Service Schedule 36 customers within the Company's service territory.
NWEC has over 100 organizational members throughout Idaho, Montana, Washington, and
IDAHo PUBLIC UTILITIES CoTrtuIssIoN, Case No. PAC-8.22-I5
Idaho Conservation League, Petition to Intervene
Page2
Oregon. NWEC claims an interest in this case on behalf of its eleven organizational members in
Idaho. As a result, ICL and NWEC and their members have a direct and substantial interest in
ensuring that Rocky Mountain Power provides a fair rate structure that does not unduly burden
residential and small commercial customers, and those interested in energy savings and
conservation. The Commission has consistently granted ICL's intervention in Rocky Mountain
Power dockets on similar grounds. The NWEC has also intervened in other utility dockets in
Idaho on these grounds. ICL and NWEC's intervention will respond directly to the issues raised
in the Company's application and will not unduly broaden the scope of the issues or this
proceeding. ICL and NWEC intervene jointly to avoid duplicative participation in this docket.
3. ICL and NWEC intend to fully participate in this matter as parties. The nature and quality
of ICL and NWEC'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, and cross-examine witnesses. tCL and NWEC may seek intervenor
funding pursuant to IDAPA 3 I.0 I.01. I 6 1-l 65.
WHEREFORE, ICL and NWEC respectfully request the Commission grant this petition.
DATED this 2lst day of December, 2022.
Respectfully submitted
/s/ Marie Callaway Kellner
Marie Callaway Kellner (ISB No. 8470)
Attorney for Idaho Conservation League
IDAHo PUBLIC UTILITIES COMMISSION, Case No. PAC-E-22-15
Idaho Conservation League, Petition to Intervene
Page 3
CERTIFICATE OF SERVICE
I hereby certify that on this 21st day of December, 2022,I delivered tue and cortect
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 ldaho Conservation League
710 N. 6ft St.
Boise,Idaho 83702
[e-mail]
Electonic Mail Only (See OrderNo. 35058):
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
j an.noriyuki@puc. idaho. gov
[e-mail]. gov
Commission Staff
Claire Sharp
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]
Roclcy Mountain Power
Mark Alder
1407 W. North Temple, Suite 330
Salt Lake City, UT 841l6
[e-mail]
Joe Dallas
Attomey for Rocky Mountain Power
825 NE Multnomah Street, Suite 2000
Portland, OR97232
j oseph.dallas@pacifi corp.com
IDAHo PI-IBLIC UTILITIES COvNaTSSTOT.I, Case No. PAC-E-22-I5
Idaho Conservation League, Petition to Intervene
Page 4