20230928ICL Petition to Intervene.pdf

Matthew A.Nykiel (ISB No.10270)
710 N.6th St.
Boise,Idaho 83702
Phone:[phone]
Email:[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY
MOUNTAIN POWER’S
APPLICATION FOR A DEFERRED
ACCOUNTING ORDER RELATED
TO INSURANCE COSTS
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CASE NO.PAC-E-23-18
PETITION TO INTERVENE
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League (“ICL”)to hereby request leave to intervene in
the above captioned matter 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:
Matthew Nykiel
Attorney for 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 name and address above.Please provide the same
documents to the following:
IDAHO PUBLIC UTILITIES COMMISSION,Case No.PAC-E-23-18 Page 1
Idaho Conservation League –Petition to Intervene
RECEIVED
Thursday, September 28, 2023 2:08:57 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 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 claims 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 11,000 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 customers within the Company’s service territory.The Company’s
substantial deferral request results from increased wildfire risk due to land management and
development practices across the west,exacerbated ongoing and accelerating ecological stress
caused by climate change.ICL has long engaged in both land management and climate advocacy
in Idaho.The requests in this application also beg complex questions of cost allocation between
PacifiCorp's six territory jurisdictions.ICL is party alongside the Commission Staff to the
PacifiCorp Multistate Settlement Process (“MSP”)with the purpose to coordinate the Company's
interstate regulatory affairs.As a result,ICL and its members have a direct and substantial interest
in ensuring that Rocky Mountain Power fairly and prudently manages its insurance costs and
allocations between territory states so as to best serve customers and responsibly manage wildfire
IDAHO PUBLIC UTILITIES COMMISSION,Case No.PAC-E-23-18 Page 2
Idaho Conservation League –Petition to Intervene
risk.The Commission has consistently granted ICL’s intervention in Rocky Mountain Power
dockets on similar grounds.
3.ICL’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.
4.ICL intends to fully participate in this matter as parties.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,
and cross-examine witnesses.ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE,ICL respectfully requests the Commission grant this petition.
DATED this 28th day of September,2023
Respectfully submitted
/s/Matthew A.Nykiel
Matthew A.Nykiel (ISB No.10270)
Attorney for Idaho Conservation League
IDAHO PUBLIC UTILITIES COMMISSION,Case No.PAC-E-23-18 Page 3
Idaho Conservation League –Petition to Intervene
CERTIFICATE OF SERVICE
I hereby certify that on this 28th day of September,2023,I delivered true and correct
copies of the foregoing PETITION TO INTERVENE to the following persons via the method of
service noted:
/s/Matthew A.Nykiel
Matthew A.Nykiel (ISB No.10270)
Attorney for Idaho Conservation League
Electronic Mail Only (See Order No.35058):
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
[e-mail]
Rocky Mountain Power
Mark Alder
1407 W.North Temple,Suite 330
Salt Lake City,UT 84116
[e-mail]
Joe Dallas
Attorney for Rocky Mountain Power
825 NE Multnomah Street,Suite 2000
Portland,OR 97232
[e-mail]
[e-mail]
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION,Case No.PAC-E-23-18 Page 4
Idaho Conservation League –Petition to Intervene