20031114Petition to Intervene.pdf

William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ID 83701
[phone]
fax: [phone]
billeddie~rmci.net
RECEIVED FILED
2003 NOV 12 AM 6:55
:.; GL\C
UTILITIES Cm.1MISSION
Express Mail:
1320 W. Franklin St.
Boise, ID 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS INTERIM
AND BASE RATES AND CHARGES FOR
ELECTRIC SERVICE
CASE NO.IPC-03-
PETITION TO INTERVENE
Pursuant to Idaho Public Utilities Commission Rules of Procedure 53 and 71
through 73, and Commission Order No. 29369, NW Energy Coalition ("Coalition
hereby seeks intervention in the above-captioned matter. As discussed below, the
Coalition has a direct and substantial interest in these proceedings, and therefore should
be granted intervention.
The NW Energy Coalition is a non-profit regional alliance of over 100 diverse
environmental, civic, consumer, low-income customer advocacy groups, energy
efficiency and renewable energy businesses, and progressive utilities in Idaho, Montana
Washington and Oregon. NW Energy Coalition s address is: 219 First Ave South, Suite
100, Seattle, W A 98104.
In Idaho, the Coalition has numerous individual members and eleven (11)
member organizations including the League of Women Voters, Idaho Rural Council
PETITION TO INTERVENE --
Idaho Rivers United, Idaho Conservation League, and various community action agencies
in Idaho.l NW Energy Coalition s members (and its members' members) include
customers of Idaho Power Company. NW Energy Coalition advocates for increased
energy conservation efforts, sustainable and ecologically-sound management of electric
generating infrastructure, increased reliance on renewable sources of energy, and
appropriate rate design policies consistent with these goals, all of which ensure low-cost
power and rate stability for all utility customers.
NW Energy Coalition is active in ongoing processes with Idaho Power Company.
Nancy Hirsh (Policy Director for the Coalition) sits on the Company s Energy Efficiency
Advisory Group. The undersigned counsel (a member ofNW Energy Coalition
Executive Board) participates in the Company s 2004 Integrated Resource Plan Advisory
Group.
NW Energy Coalition has a direct and substantial interest in this proceeding
because Idaho Power Company s requested rates and rate design will adversely impact its
interests (and the interests of its members) in ensuring appropriate incentives exist for the
Company to provide cost-effective energy efficiency services and efficient electric
portfolio management at the lowest possible costs. Further, NW Energy Coalition asserts
that reasonable changes to Idaho Power Company s proposals in this case could benefit
both the Company and its customers.
I The Community Action Partnership Association of Idaho ("Association ) also is petitioning to intervene
in this matter. The NW Energy Coalition strongly agrees that the Association should intervene separately
in this matter so as to best represent the unique issues of importance to the low-income community in
Idaho. While the Coalition may support arguments and proposals advanced by the Association in this
matter, the Coalition wishes to make clear that it is conferring closely with the Association to ensure the
primary issues and arguments raised by both groups are not duplicative. The NW Energy Coalition has a
remarkably diverse membership (including entities such as the Idaho Conservation League, and Puget
Sound Energy and Seattle City Light electric utilities), and therefore cannot exist to represent all interests
of all members in proceedings such as this one.
PETITION TO INTERVENE -- 2
The Coalition seeks intervention in order to fully participate in this matter as a
party and otherwise to present such materials as may be relevant to the Commission
decision(s) in this matter. The Coalition intends to seek intervenor funding pursuant to
RP 161 through 165.
NW Energy Coalition takes no position with respect to Idaho Power Company
request for an interim rate increase (Case No. IPC-03-13A). In so doing, the Coalition
does not waive any arguments or right to present testimony and take any position on any
issue in the broader general rate case (Case No. IPC-03-13).
PLEASE TAKE NOTICE that NW Energy Coalition requests all documents in
this matter be served to the following persons:
William M. Eddie
Advocates for the West
O. Box 1612
Boise, ID 83701
Nancy Hirsh
NW Energy Coalition
219 First Ave South, Suite 100
Seattle, W A 98104.
WHEREFORE, NW Energy Coalition respectfully requests that the foregoing
petition to intervene be granted.
Dated: November -' 2003 Respectfully submitted
~~
M. Eddie, Attorney
Advocates for the West
On behalf of NW Energy Coalition
PETITION TO INTERVENE -- 3
CERTIFICATE OF SERVICE
I hereby certify that on this \2.day of November 2003 , true and correct copies of
the foregoing PETITION TO INTERVENE were delivered to the following persons via
the method of service noted:
Via Hand-Delivery:
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Bart Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
William M. Eddie
PETITION TO INTERVENE -- 4