20060317Petition to intervene.pdf

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William M. Eddie ISB #5800
ADVOCATES FOR THE WEST
O. Box 1612
Boise, Idaho 83701
Phone: [phone], x. 3
FAX: [phone]
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Attorney for NW Energy Coalition
Express Mail Address
1320 W. Franklin Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
OF FINANCIAL DISINCENTIVES TO
INVESTMENT IN ENERGY EFFICIENCY BY
IDAHO POWER COMPANY
CASE NO.IPC- E-04-
PETITION TO INTERVENE
Pursuant to Idaho Public Utilities Commission Rules of Procedure 53 and 71
through 73, and the Commission s scheduling order of March 6 2006, the NW Energy
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 main address is: 219 First Ave South
Suite 100, Seattle, W A 98104.
PETITION TO INTERVENE --
In Idaho , the Coalition has numerous individual and organizational members
including the League of Women Voters, Idaho Rural Council, Idaho Rivers United, Idaho
Conservation League, Snake River Alliance, and various community action agencies in
Idaho. 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) participates on the Company s Energy
Efficiency Advisory Group. The undersigned counsel (a member ofNW Energy
Coalition s Executive Board) participates in the Company s 2006 Integrated Resource
Plan Advisory Group.
NW Energy Coalition has a direct and substantial interest in this proceeding. The
Coalition intervened and filed testimony in IPC-03-, which formed the basis for the
Commission s decision to order the initiation of this separate docket. The Coalition
presented the Petition to initiate this docket (per Order 29505), participated in the
workshops, and took the lead in drafting the Final Report on Workshop Proceedings
which was filed with the Commission in February 2005. NW Energy Coalition has a
direct and substantial interest 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.
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.
WHEREFORE, NW Energy Coalition respectfully requests that the foregoing
petition to intervene be granted.
Dated: March 17 , 2006 Respectfully submitted
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William M. Eddie, Attorney
Advocates for the West
On behalf ofNW Energy Coalition
CERTIFICATE OF SERVICE
I hereby certify that on this 17th day of March 2006, 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
Via u.S. Mail:
Bart Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070 J!7 ~
William M.
PETITION TO INTERVENE -- 3