20060531Petition to intervene.pdf

William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
O. Box 1612
Boise, ID 83701
[phone] x 3
fax: [phone]
billeddie~rmci.net
., (" " "
, L;: 51
" ~
J \,
" . ,
, \ i ", i
~ '
' j i' i\",.J
' .
Express Mail:
1320 W. Franklin St.
Boise, ID 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR
MODIFICATION OF THE LOAD GROWTH
ADJUSTMENT FACTOR WITHIN THE POWER)
COST ADJUSTMENT (PCA) METHODOLOGY
CASE NO.IPC-06-
PETITION TO INTERVENE
Pursuant to Idaho Public Utilities Commission Rules of Procedure 53 and 71
through 73, and Commission Order No. 30044, 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 main address is: 219 First Ave South
Suite 100, Seattle, WA 98104.
In Idaho, the Coalition has numerous individual and organizational members
including the League of Women Voters, Idaho Rural Council, Idaho Rivers United, Idaho
PETITION TO INTERVENE --
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) sits on the Company s Energy Efficiency
Advisory Group. The undersigned counsel (a member ofNW Energy Coalition
Executive Board) participates in the Company s 2006 Integrated Resource Plan Advisory
CounciL
NW Energy Coalition has a direct and substantial interest in this proceeding
because Idaho Power Company s requested adjustment to the annual power cost
adjustment (PCA) methodology may 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.
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.
PETITION TO INTERVENE -- 2
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: May 30, 2006 Respectfully submitted
William M. Eddie, Attorney
Advocates for the West
On behalf ofNW Energy Coalition
PETITION TO INTERVENE -- 3
CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of May 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
Greg Said
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
i'I'l iam M. Eddie
PETITION TO INTERVENE -- 4