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Home My WebLink About20090731Intervenor Funding.pdf~ Betsy Bridge BarNo. 8111 Idaho Conservation League POBox 844 710 N 6th Street Boise,ID 83701 Ph: (208) 345-6933 x 12 Fax: (208) 344-0344 bbridge(?wildidaho.org RECEIVED 2009 JUl 31 AH 9: 38 IDAHO PUBLIC UTILITIES COMMISSION BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION IN THE MATTER OF THE IDAHO POWER COMPANY'S APPLICATION FOR A CERTIFICATE OF PUBLIC CONVENIENCE AN NECESSITY FOR TH LANGLEY GULCH POWER PLANT ) ) ) ) ) ) CASE NO. IPC-E-09-03 IDAHO CONSERVATION LEAGUE'S APPLICATION FOR INTERVENOR FUNING COMES NOW, Applicant the Idao Conservation League ("ICL") and, pursuat to Idaho Code § 61-617A and Rules 161-165 of the Commission's Rules of Procedure, IDAPA 31.01.01, petitions this Commission for an award of intervenor fuding. A. Rule 161 Requirements Idaho Power Company ("Company") is a regulated, electrc public utilty with gross Idaho intrastate, anual revenues exceeding thee milion, five hundred thousand dollars ($3,500,000.00). B. 162(01) Itemizd list of Expenses Consistent with Rule 162(01) of the Commission's Rules of Procedur, an itemized list of all expenses incured by ICL in this proceeding is attched hereto as Exhibit "A." C. 162(02) Statement of Proposed Findings ICL APPLICATION FOR INTERVENOR FUNING -- 1 ~ The proposed findings and recommendations of ICL are set fort in the Joint Motion to Stay by the intervenors. In review, ICL asserts authorization of the CPCN for the Langley Gulch plant should be delayed until completion of Idaho Power's 2009 Integrated Resource Plan ("IRP"). ICL has thee specific concerns. First, Idao Power's shareholders recently passed a resolution directing I~o Power to develop a plan for reducing its emissions of greenhouse gases ("GHG"). Idaho Power agreed to prepare a GHG reduction strategy report by September 30,2009. Durg the technical hearg Karl Bokenkp testified that this strtegy wil be incorporated into the IRP, which could significantly alter decisions made in the IR process. Langley Gulch, which would emit greenhouse gases, may not be the best fit to meet the Company's energy needs. Second, Idao Power has delayed its 2009 IRP in order to incorporate the economic downtu into its load forecast. The curent economic conditions wil undoubtedly have a substantial effect on the Company's energy needs. In addition, the Company has not incorporated the effect of its new DSM progrms into its load forecasts. The new load forecast and the effect of new DSM should be incorporated into the 2009 IR before Idaho Power moves forward with the Langley Gulch plant. Third, energy policy has changed. Factors, such as, impending federal regulations involving GHG emissions, adoption ofIdaho's 2007 Energy Plan, and increasing energy costs favor implementing all cost effective effciency and DSM programs and the acquisition of renewable energy before building any more fossil fuel generation facilties. In summary, there are many issues involving environmental regulation and futue energy need that are uncertain. Several of these issues wil be resolved in the next few months, which ICL APPLICATION FOR INTERVENOR FUNING -- 2 wil allow Idaho Power to properly consider these factors in the IRP process. The Commission should delay decision on Langley Gulch until the 2009 IR is complete. D. 162(03) Statement Showing Costs ICL submits that the costs and fees incured in this case, and set fort in Exhibit A, are reasonable in amount. Idaho Power's application for a CPCN for Langley Gulch was fully litigated, with a thee-day technical hearng, foureen witnesses, and numerous exhibits. ICL made a concerted effort to minimize expenses and seeks reimbursement for only attorney's fees. In addition, ICL reduced the number of attorney hour in order to account for this being counsel's first time before the Commission. ICL is not seekig recovery for 20% of attorney time because some time was spent coming up to speed on commission procedure. E. 162(04) Explanation of Cost Statement ICL is non-profit corporation working to protect Idaho's clean water, clean air, and wilderness. Though our energy program, we advocate for energy effciency and renewable resources in order to mitigate the effect climate change wil have on Idaho and its citizens. ICL's fuding comes from a varety of sources, mostly our individual members and donations from private foundations. Its energy program is fuded by one foundation and is, therefore, limited in its energy advocacy. Due to moneta limitations, ICL has only one staff member committed to energy issues. Therefore, the amount of time and resources devoted to this proceeding was a significant hardship to the organization. The availabilty of intervenor fuding makes it more likely ICL wil be able to paricipate in proceedings before the Commission. F. 162(05) Statement of Difference ICL provides a unique perspective due to its expertise in environmental regulation, ICL APPLICATION FOR INTERVENOR FUNING -- 3 impending federal climate change legislation, and energy efficiency opportities. First, ICL challenged Idaho Power's assertion it is puring all cost effective energy efficiency and DSM progrs. Second, ICL addressed the need for the shareholder resolution to adopt a greenhouse gas reduction strtegy to be incorporated into the 2009 IR. Even though Staff provided valuable insight,. Staff did not address the greenhouse gas resolution and had a different opinion on whether the Company is puruing all cost effective effciency. G. 162(06) Statement of Recommendation ICL's position addressed issues of concer to the general body ofIdao Power users or customers. Energy effciency and DSM programs are the cheapest and safest way to address energy demand. Furermore, impending federal regulation will increase the cost of any fossil fuel generation resources. The curent regulatory climate makes energy effciency and renewable energy the least risk resources options. In addition, reducing demand for energy and choosing clean energy resources benefits all Idaoans by preserving a clean environment. H. 162(07) Statement Showing Class of Customer ICL has individual members who are customers Idao Power. Therefore, to the extent ICL represents a specific customer class of the Company, it is the residential class. Dated: July 31, 2009 Respectfully submitted, ICL APPLICATION FOR INTERVENOR FUNING -- 4 . . CERTIFICATE OF SERVICE I hereby certify that on this 31 st day of July, 2009, tre and correct copies of the foregoing APPLICATION FOR INTERVENOR FUNING were delivered to the following persons via the method of service noted: Jean Jewell Commission Secretar Idaho Public Utilties Commission 427 W. Washington St. Boise, il 83702-5983 jjewellØ2lmc.state.id. us ~ Hand Delivery U.S. Mail, postage pre-paid ~ Electronic Mail Facsimile Lisa Nordstrom Baron L. Kline Idaho Power Company POBox 70 Boise, ID 83707-0070 Inordstrom(iidahopower.com bklineØ2idahopower.com Hand Delivery _ U.S. Mail, postage pre-paid ~ Electronic Mail Facsimile Scott Woodbur Deputy Attorney General Idao Public Utilties Commission 427 W. Washington St. Boise, il 83702-5983 Scott. woodburCiuc.idaho.gov ~Hand Delivery _ U.S. Mail, postage pre-paid x Electronic Mail Facsimile Pete Richardson, Esq. Richardson & O'Lear 515 N. 27th Street PO Box 7218 Boise, ID 83702 peter§richardsonandoleaiy.com Hand Delivery ~ U.S. Mail, postage pre-paid ~ Electronic Mail Facsimile Don Reading 6070 Hil Road Boise, il 83703 dreading§mindsvring.com Hand Delivery _ U.S. Mail, postage pre-paid ~ Electronic Mail Facsimile ICL APPLICATION FOR INERVENOR FUNING -- 5 Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Chtd. 201 E. Center PO Box 1391 Pocatello, il 83204-1391 eloØ2racinelaw.net Anthony Yanel 29814 Lake Road Bay Vilage OH 44140 tonyØ2yanel.net Ken Miler Clean Energy Program Director Snake River Allance POBox 1731 Boise, ID 83701 kmillerØ2snakeriverallance.org Brad M. Purdy Attorney at Law 2019 N. 17th St. Boise, il 83702 bmpurdvØhotmail.com Susan Ackerman 9883 NW Nottage Dr. Portland, OR susan.k.ackerman§comcast.net Robert Kah rkahncmippc.org . _ Hand Delivery _ U.S~ Mail, postage pre-paid ~ Electronic Mail Facsimile _ Hand Delivery _ U.S. Mail, postage pre-paid 2- Electronic Mail Facsimile _ Hand Delivery _ U.S. Mail, postage pre-paid ~ Electronic Mail Facsimile _ Hand Delivery ~ U.S. Mail, postage pre-paid 2- Electronic Mail Facsimile _ Hand Delivery ~ U.S. Mail, postage pre-paid ~ Electronic Mail Facsimile _ Hand Delivery _ U.S. Mail, postage pre-paid ~ Electronic Mail Facsimile ICL APPLICATION FOR INERVENOR FUNING -- 6 .. EXHBIT "A" ITEMIZED EXPENSES Fees: Legal (Betsy Bridge - 68.60 (85.75hr - 20% (l7.15)hours) ($140.00/h)) Total Fees $9,604.00 Total Expenses $9,604.00 ICL APPLICATION FOR INTERVENOR FUNING -- 7