20170616Petition to Intervene.pdf

Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27th Street, 83702
P.O. Box 7218,83707
Boise,Idaho
Telephone : [phone]
Fax: [phone]
gre g@richardsonadams. com
Local Counsel
Irion Sanger
Sanger Law, P.C.
I I l7 SE 53'd Avenue
Portland, OP.972l5
Telephone : [phone]
Fax: [phone]
[e-mail]
Pro Hac Vice Counsel (admission pending)
Attorneysfor the Renewable Energt Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF'THE APPLICATION
OF'IDAHO POWER COMPANY TO
REVIEW THE SURROGATE AVOIDABLE
RESOURCE (SAR) METHODOLOGY FOR
CALCULATING PUBLISHED AVOIDEI)
COST RATES
CASE NO. GNR.E.I7-02
PETITION OF RENEWABLE
ENERGY COALITION FOR
LEAVE TO INTERVENE
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Pursuant to Rules 71 through 75 of the Idaho Public Utilities Commission's Rules
of Practice and Procedure,IDAPA 31.01.01. 071 et. seq., Renewable Energy Coalition
("REC") petitions the Idaho Public Utilities Commission (the "Commission") for leave to
intervene. In support of this Petition, REC states as follows:
REC PETITION TO INTERVENE Page 1
l. The name and address of REC is:
Renewable Energy Coalition
c/o John Lowe
PO Box 25576
Portland, OR 97298
E-Mail: [e-mail]
2. REC will be represented in this proceeding by Richardson Adams, PLLC.
All documents relating to these proceedings should be served on the following persons at
the addresses listed:
Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N.27th Street, 83702
Boise, tdaho
Telephone : [phone]
Fax: [phone]
gre g@richardsonadams. com
lrion Sanger
Sanger Law, P.C.
1117 SW 53'd Avenue
Portland, OR 97215
E-Mail: [e-mail]
3. REC is a coalition of Idaho and northwest small hydro qualifying facility
("QF") power producers that have power purchase agreements ("PPAs") with Idaho
investor-owned utilities, or who may seek PPAs with ldaho utilities. REC was
established in 2009, and is comprised of nearly forty members that are both small and
large QFs who own, operate or are developing approximately fifty renewable energy
generation facilities in Oregon, ldaho, Montana, Washington, Utah, and Wyoming.
Several types of entities are members of the REC, including irrigation districts, water
districts, corporations, and individuals. The majority of the individual QFs are small
REC PETITION TO INTERVENE Page2
hydroelectric projects less than 7 megawatts, but the membership includes biomass, solar,
geothermal, and waste energy. Most of the REC's members operate existing projects that
have been operating and selling to utilities for numerous years, but many of the members
are developing or planning to develop new projects. REC actively participates in
renewable energy legislation, PURPA related proceedings, IRP processes, and other
investigations in the Northwest regarding QFs.
4. REC has a direct and substantial interest in this proceeding that will not be
adequately represented by any other party, and in any Commission determination made in
connection with these proceedings that could impact avoided cost rates or contract terms
and conditions available to REC members. REC intends to participate in all aspect of this
proceeding and will not unreasonably broaden the issues, burden the record, or delay this
proceeding.
5. Without the opportunity to intervene herein, REC would be without a
manner or means of participating in the lawful determination of issues which may affect
the avoided cost rates or contract terms and conditions regarding PPAs for REC
members. This proceeding could have a material impact upon the prices REC's members
receive for sales to Idaho utilities.
WHEREFORE, REC respectfully requests that the Commission grant its petition
to intervene with full party status in this proceeding and to appear and participate in all
matters as may be necessary and appropriate; and to present evidence, call and examine
witnesses, cross-examine witnesses, present argument, and to otherwise fully participate
in the proceedings.
REC PETITION TO INTERVENE Page 3
Dated Jure 16, 2017.
M. Adams (ISB No. 7454)
RichardsonAdams, PLLC
515 N. 27th Stneet
Boise,ID 83702
Telephone: [phone]
Fa:r: 208.938.7904
[e-mail]
REC PETITION TO INTERVENE Page 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ,n"lfrurof June, a true and correct copy of the within and
foregoing PETITION TO INTERVENE BY THE RENEWABLE ENERGY COALITION in
Docket No. GNR-E-17-02 was served by electronic mail and United States Mail, postage
prepaid, to:
Diane Hanian
Idaho Public Utilities Commission
472 W . Washington Street
Boise, ID 83702
diane. holt@puc. idaho. gov
J.R. Simplot Company
c/o Peter Richardson
Richardson Adams, PLLC
515 N. 27s Street
Boise, ID 83702
peter@richardsonadams. com
Yvonne Hogle
Ted Weston
PacifiCorp
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
wonne.ho gle@pacifi corp.com
ted.weston@pacifi corp. com
Clint Kalich
Avista Corporation
1411 E. Mission Ave, MSC-7
Spokane, WA 99202
[e-mail]
Donovan Walker
Idaho Power Company
l22l W.Idatro Street
Boise,ID 83702
dwalker@idahopower. com
dockets@ idahopower. com
Michael Darrington
Idaho Power Company
l22lW.Idaho Street
Boise, ID 83702
mdarrin gton@idahopower. com
Daniel MacNeil
PacifiCorp
825 NE Multnomah Street
Portland, OR 97232
daniel.macneil@f acifi corp. com
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreadine@mindspring. com
Michael G. Andrea
Avista Corporation
l4l I E. Mission Ave, MSC-33
Spokane, WA 99202
michael.andrea@avistacorp. com
M. Adams