20101129Petition to Intervene.pdf

Benjamin Otto (ISB No. 8292)
710 N 6th Street
PO Box 844
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
bottotPidaoconservation.org
RECEt\/
2010 NOV 29 PM 2: 00
Attorney for the Idao Conservtion League, the Northwest Energ Coalition, and the Snake River
Allance
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATIR OF IDAHO POWER )
COMPANY'S REQUEST TO MODIFY )
RECOVERY OF INCENTIVES PAID TO )
SECURE DEMAND-SIDE RESOURCES )
CASE NO. IPC-E-1O-27
PETITION TO INTERVENE OF THE CONSERVATION PARTIS
COMES NOW the Idaho Conservtion League (((ICL"), the NW Energ Coalition
(((Coalition"), and the Snake River Allance (((Allance"), herein after the ((Conservtion Paries,"
and hereby requests leave to intervene in the above captioned matter pursuat to the Idao Public
Utilities Commission Rules of Procedure, IDAPA 31.01.01.071-073.
1. Ths Intervenor is an unincorporated group of three organizations that can be referred
to as the ((Conservtion Paries." The Conservation Paries request that al pleadig;, production
requests, production responses, Commission orders, and other documents be submitted to their
Represen tative:
Benjamin J. Otto
Idaho Conservtion League
710 N. 6th st.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
bottotPidaoconservtion.org
PETITION TO INTERVENE 1 November 29,2010
In addition to the Representative, copies of al pleadigs, production requests, production
responses, Commission orders and other documents should be provided to the paries individualy,
via electronic mai, at:
Nancy Hirsh
NW Energy Coalition
811 1st Ave, Suite 305
Seattle, W A 98104
Ph: [phone]
Fax: [phone]
nancy(fnwenergy.org
Ken Miler
Snake River Allance
350 N 9th St # B610
Boise, il 83702-5473
Ph: [phone]
Fax: [phone]
kmiller(fsnakeriveralliance.org
2. As detaied below, the Conservation Paries clai a diect and substantial interest in this
proceedig both jointly and as individua orgiztions. In thi proceedig, Idaho Power intends
to alter the manner and amount of its Demand Side Management (((DSM") activity and
investments. The Conservation Paries reguarly work together to protect and promote the
interests of their members and their orgaizations who place a priary emphasis on DSM
investments throughout the region. By joining as the Conservtion Paries, each group can
protect its individua interests whie reducing the administrative burden arsing from multiple
intervenors.
The Idao Conservtion League clais a direct and substantial interest in this proceedig
arsing from the impact to its members served by Idao Power .and to its long-term role
advocating for public values statewide. As Idao's largest state-based conservation organization,
we have thousds of members who are residential customers of Idao Power, each of whom
contribute to the company's DSM progrs, which is a primar subject of this proceedig. Many
of our members participate in the A/C Cool Credit program, which is also a primar subject of this
proceedig. In addition, ICL and its members have a broader interest in promoting DSM activity
in Idao by all customer classes because increased DSM efforts can reduce electrical costs for all
PETITION TO INTERVENE 2 November 29,2010
ratepayers regardless of their individua paricipation in programs. As contributors of funds for
DSM progrs, paricipants in DSM programs, and because of the impact DSM activity can have
on electrical rates; ICL and its members have a direct and substantial interest in this proceedig.
Unless granted intervener status, ICL and its members wil be unable to protect their interests in
the administration of Idaho Power's DSM portfolio as rased in this proceedig.
The NW Energy Coalition claims a direct and substantial interest in this proceedig arsing
from its long-term role in advocating for DSM investments in Idao and across the region. The
Coalition has been a member of the Idao Power Energ Efficiency Advisory Group since 2003.
The Coalition has previously been granted intervener status in cases regadig Idao Power before
the Idao Public Utilties Commission. The Coalition is comprised of 100 environmental, civic,
and human service organizations, progressive utilties, and businesses from across the region.
Born out of the passage of the Pacific Nortwest Electrc Power Planing and Conservation Act,
the Coalition has a track record of almost thirt years of effective advocacy for DSM
investments and activities. DSM investments by Idaho Power can affect the regional electrcal
system by limiting peak demand levels, reducing transmission congestion, and contributing to
market transformation - all of which are direct and substatial interests of the Coalition. Unless
granted intervener status in this proceeding, the Coalition wil be unable to protect its interest in
ensuring adequate and effective DSM investments thoughout the Pacific Nortwest region.
The Snake River Allance claims a direct and substatial interest in this proceeding
arising from the impact to its members served by Idao Power and to its long-term role
advocating for public values statewide. Allance members contribute to Idao Power's DSM
progrs, participate in DSM programs, and have an interest in promoting DSM investments
more broadly because this can reduce electrical costs for all ratepayers. Whe these interests are
similar to ICL, there are individuas members unique to each group who have a diect and
PETITION TO INTERVENE 3 November 29,2010
substantial interest in fundig and administration of Idao Power's DSM portfolio. Unless
grted intervener status, the Allance and its members wi be unable to protect their interests in
the administration of Idao Power's DSM portfolio.
3. Because each of the Conservation Paries clai a diect and substantial interest in this
proceedig, by petitioning as joint intervenors, they wi not unduly broaden the issues, rather
present a unified position that should help to narrow and fully iluminate the issues.
4. The Conservation Paries intend to fuly paricipate in this matter, and if necessar,
may introduce evidence, be heard in arent and cal, examine and cross-examine witnesses as
may be relevant in this matter. The nature and quaity of the Conservation Paries' intervention
in the proceeding is dependat upon the nature and effect of other evidence in this proceeding.
The Conservation Paries intend to seek intervenor fundig puruat to IDAPA 31.01.01.161-
165.
WHEREFORE, The Conservation Paries respectfully request the Commission grt the
foregoing petition to intervene.
DATED this 29th day of November 2010.Re~;;
Benjamin J. Otto
~
On behalf of the Idao Conservation League,
the NW Energy Coalition, and the
Snake River Allance
PETITION TO INTERVENE 4 November 29,2010
CERTIFICATE OF SERVICE
I hereby certify that on this 29th day of November, 2010 true and correct copies of E f
the foregoing PETITION TO INTERVENE were delivered to the followig persons via tlillJNfJV2method of servce noted: . 9 Ph.2
Hand delivery
Jean Jewell
Commission Secretar (Origial and seven copies provided)
Idao Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
Electronic Mai:
Lisa D. Nordstrom
Donovan E. Walker
Idao Power Company
1221 West Idaho Street
Boise, Idao 83707-0070
InordstromtPidahopower.com
dwale¡€idaopower.com
Dr. Don Readig
6070 Hil Road
Boise, Idao 83703
Telephone: [phone]
Fax: [phone]
dreadi~mindsprig.com
John R Gale
Darlene Nemnich
Idao Power Company
P.O. Box 70
Boise, Idao 83707
rgaletPidahopower.com
dnemnichtPidaopower.com
Peter J. Richardson
Gregory M. Adams
Richardson & O'lear, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702
Telephone: [phone]
Fax: [phone]
petertPrichardsonandolear.com
gre~richardsonandolear.com
/À~
Benjamin J. Otto
Idao Conservtion League