20110725Petition to Intervene.pdf

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for a clean and affordable energy future 281 f JUL 25
PJ1 3: 05
July 22,2011
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Dear Ms. Jewell,
Pursuant to Commission Order 32272, please find attached the NW
Energy Coalition's Petition for Late Intervention to the Public
Utilties Commission in Case No. IPC-E-ll-08. This petition is
being filed electronically to the Commission and all. other paries in
the Case. Four copies are being submitted to the Commission via
maiL.
Nancy Hirsh
Policy Director
NW Energy Coalition
8111st Ave., Suite 305
Seattle,'WA 98104
Seattle: 811 1st Avenue, Suite #305, Seattle, WA 98104. [phone] · [phone] fax
Salem: [phone]. [phone] fax
.~" www.nwenergy.org. nweclQnwenergy.org 0
July 22, 2011
Nancy Hirsh.
NW Energy Coalition
811 1st Ave., Suite 305
Seattle, WA 98104
Ph: [phone]
RECEI r\L~)-
20il JUL 25 Pif 3: 05
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELEClRIC
SERVICE IN IDAHO
CASE NO. IPC-E-11-08)
)
)
)
)
)
PETITION FOR LATE
INTERVENTION
NW ENERGY COALITION
COMES NOW, The NW Energy Coalition ("Coalition") and pursuant to this Commission's
Rules of Procedure, Rule 71 IDAPA 31.01.01.071 and 073 hereby requests permission for late
intervention in the above- referenced case, IPC-E-11-08. The name and address of this
intervener and our interests in this case are presented as follows: .
A. The Coalition's business address is:
NW Energy Coalition
811 lt Ave
Suite 305
Seattle, WA 98104
206-621-0094
B. The Coalition wil be represented in this proceeding by Nancy Hirsh, Policy Director of the
Coalition. Correspondence in this docket can be sent to the above address or via email to:
nancy(gnwenergy.org. Ms. Hirsh's cell phone is: 206-409-9217
C. The Coalition is a non-profit organization under section 50l(c)(3) of the Internal Revenue
Code. The Coalition has 11 organizational members located in Idaho, representing more than
100,000 citizens. The Coalition's primary purpose is to promote an energy future that is clean,
reliable, affordable, and equitable. Due to its historic and ongoing work with utilty companies
and others to achieve these goals, the Coalition possesses unique interest in the outcome of this
proceeding.
D. The Coalition has a special interest in this proceeding for the following reasons: (1) Coalition
members wil be directly affected by rate changes for the residential class; (2) the fixed cost
recovery mechanism and rate design modifications that are proposed in this proceeding may
PETITION FOR LATE INTERVENTION July 22,2011
affect customer investment in energy efficiency and affordabilty for low-income customers; and
(3) treatment of demand response incentives as power supply expenses could impact overall
commitments to energy efficiency and the strategy for DSM investments. The Coalition intends
to examine these and other issues in this proceeding. We believe that our parcipation in this
proceeding will assist the Commission and the Paries in working toward a successful outcome
by bringing our considerable energy effciency and rate design expertise to the case to protect its
interest in ensuring adequate and effective DSM investments thoughout the Pacific Northwest
region.
E. The Coalition offers this pròcess considerable expertise arising from its long-term role in
advocating for DSM investments in Idaho and across the region. The Coalition has been a
member of the Idaho Power Energy Effciency Advisory Group since 2003. Petitioner, Nancy
Hirsh, has participated in Commission sponsored workshops on DSM incentives and is a
member of the Idaho Energy Efficiency Task Force. The Coalition has previously been granted
intervener status in cases regarding Idaho Power before the Idaho Public Utilities Commission,
including a rate case (Docket No. IPC-E-03-13).
F. The Coalition applies for late intervention under IDAPA 31.01.01.073 due to a death in the
family of Ms. Hirsh and an extended absence from the office. The Coalition has no intention of
unreasonably broadening the issues, burdening the record or delaying the proceedings through its
intervention.
G. To further support the PUC and other partes in this case and to speed responsiveness of the
Coalition, the Coalition requests Electronic Service Only for document distribution in this
proceeding.
For the foregoing reasons, the Coalition requests the Commission grant its Petition for Late
Intervention in this matter.
July 22,2011
Respectfully submitted,
Nancy Hirsh, Policy Director
NW Energy Coalition
81118( Ave, Suite 305
Seatte, WA 98104
206-621-0094
nancy (g nwenergy .org
PETITION FOR LATE INTERVENTION July 22, 2011