20110701Petition to Intervene.pdf

--e
BNAICERIVERLLIANCE
RECEIVED
¿on JUL -I PH I: '-6
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Dear Ms. Jewell,
IDAHO'S NUCLEAR WATCHDOCi
& CLEAN ENERCiY ADVOCATE
ww.snakeriverallance.org
July 1, 2011
Pursuant to Commission Order 32272, please find attached. four copies of the Snake River Allance's
Petition to the Public Utilities Commission to Intervene in Case No. IPC-E-11-08.
Respectfully submitted,
Ken Miler
Clean Energy Program Director
Snake River Allance
Box 1731
Boise, ID 83701
208 344-8161
208841-6982 (c)
e e
July 1,2011
Ken Miler
SNAK RIVER ALLIANCE
Box 1731
Boise, ID 83701
Ph: [phone]
RECEIVED
2011 JUL -I PH 2: 05
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION) CASE NO. IPC-E-11-08
OF IDAHO POWER COMPANY FOR )
AUTHORITY TO INCREASE ITS RATES ) PETITION TO INTERVENE OF
AND CHARGES FOR ELECTRIC )
SERVICE IN IDAHO ) THE SNAKE RIVER ALLIANCE
COMES NOW, Snake River Alliance and pursuant to the Idaho Public Utilties Commission's
Rules of Procedure Rule 71 ID AP A 31.01.01.71, petitions the Commission to grant 'is request
for intervention in the above-referenced case, IPC-E-11-08. The name and address ofthis
intervenor is:
Snake River Allance
Box 1731
Boise, ID 83701
208344-9161 (0)
208841-6982 (c)
The Snake River Allance is represented in this proceeding by Ken Miler. Correspondence in
this docket can be sent to the above address or via e-mail to: kmilertßsnakeriverallance.org
The Snake River Alliance is an Idaho-based non-profit organization, established in 1979 to
address Idahoans' concerns about nuclear safety issues. In early 2007, the Alliance expanded the
scope of its mission by launching its Clean Energy Program. The Allance's energy initiative
includes advocacy for renewable energy resources in Idaho; expanded conservation and demand-
side management programs offered by Idaho's regulated utilities and the Bonnevile Power
Administration; and development of local, state, regional, and national initiatives to advance
sustainable energy policies. The Allance is pursuing these programs on behalf of its members,
many of whom are customers of Idaho Power and who are interested in advancing progressive
energy policies. In paricular, the Allance and those we represent, primarily residential
customers of Idaho Power, are interested in promoting energy effciency and conservation
through such mechanisms as electric utilty rate designs; and promoting clean energy resource
decisions, which in this case wil deal in par with Idaho Power's proposed futue participation in
the operation of coal-fired generation fleets in Wyoming and Nevada. These are but two issues
identified in Idaho Power's application in which the Allance and our constituents have an
interest that we believe merits consideration in this general rate case.
"e
The Allance has paricipated before and commented to the Commission in multiple regulatory
proceedings on behalf of our members and as a public interest organzation representing clean
and affordable energy interests in Idaho. Petitioner Ken Miler has participated in prior Idaho
Power general rate cases, among other dockets before the Commission.
The Allance works closely on regulatory, policy, and economic issues dealing with energy
effciency and renewable energy development in Idaho and on issues dealing with integrating
those resources into existing utility systems. The Alliance and its Idaho constituents support
development of appropriately sited renewable energy projects, and have an interest in ensuring
that integrating these resources is done in a way that provides environmental benefits while also
maintaining reasonable customer rates, utility system reliability, and resource adequacy.
The Allance also supported the bulk of Idaho Power's proposal to establish the curent tiered
rate structure that is in place today. We are also interested in exploring additional rate-design
energy conservation and efficiency measures, including time-of-day pricing and other
mechanisms that will be examined in this and future general rate cases. And we have been
involved in supporting establishment of a permanent fixed-cost adjustment (decoupling)
mechanism for Idaho Power, which is seeking to make its curent pilot FCA mechanism
permanent. We have also supported in principle Idaho Power's prior request to the Commission
to revise the regulatory treatment of some of its demand-side management (DSM) incentive
payments, including the inclusion of some of those payments in base rates. The Commission
determined that request should be best handled in this general rate case, and we anticipate
continuing our paricipation in the DSM issues in this case.
As a lead public interest entity working toward sustainable energy policies in Idaho, we
anticipate paricipating in this case on our behalf of our constituents. We believe our
paricipation in this case wil assist the Commission and the Paries in working toward a
successful outcome inasmuch as the Allance can help bring to this case the voice of clean
energy advocates and also that of Idaho Power's residential customer class. Mindful of
Commission orders, the Alliance wil not engage in cross-examination of witnesses in this case
as we are not represented by legal counsel. However, we believe our paricipation in the fact-
finding and negotiation aspects of this case will help represent the interests of the hundreds of
conservation-minded residential utility customers we represent.
WHEREFORE, the Allance therefore respectfully requests the Commission grant its request to
paricipate in this proceeding as an intervenor on behalf of its Idaho constituents.
Respectfully submitted,
Ken Miler
Clean Energy Program Director
Snake River Allance
Boise,ID
[phone]
kmiler($snakeriveralliance.org