20120504Petition to Intervene.pdf

May 3, 2012
Ken Miller
SNAKE RIVER ALLIANCE
Box 1731
Boise, ID 83701
Ph: [phone]
RECEIVED
2012 MAY AM I: 55
IDAHO PU.iLft1 'JTILTES COMMISSION'
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR A )
DETERMINATION OF 2011 DEMAND-SIDE)
MANAGEMENT EXPENDITURES AS )
PRUDENTLY INCURRED
CASE NO. IPC-E-12-15
PETITION TO INTERVENE OF
THE SNAKE RIVER ALLIANCE
COMES NOW, Snake River Alliance ("Alliance") and pursuant to the Idaho Public Utilities
Commission's Rules of Procedure Rule 71 IDAPA 31.01.01.71-075, petitions the Commission to
grant its request for intervention in the above-referenced case, IPC-E-12-15. The name and
address of this intervenor is:
Snake River Alliance
Box 1731
Boise, ID 83701
208 344-9161 (o)
208 841-6982 (c)
The Snake River Alliance is represented in this proceeding by Ken Miller. Correspondence in
this docket can be sent to the above address or via e-mail to: kmiller(snakeriveralliance.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 Alliance'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 Bonneville Power
Administration; and development of local, state, regional, and national initiatives to advance
sustainable energy policies. The Alliance is pursuing these programs on behalf of its members,
many of whom are customers of Idaho Power, who participate in existing Idaho Power demand
side management (DSM) efficiency programs and who are interested in promoting additional
energy efficiency measures and in ensuring that the DSM programs they participate are
administered in a prudent manner.
The Alliance has participated before and commented to the Commission in multiple electric
regulatory proceedings on behalf of our members and as a public interest organization
representing clean and affordable energy interests in Idaho. Petitioner Ken Miller also
participates regularly at meetings of the Idaho Power Energy Efficiency Advisory Group
(EEAG), is a member of Idaho Power's Integrated Resource Plan Advisory Council (IRPAC)
and works regularly with utilities, regulators, and policymakers on energy efficiency and related
issues.
As a lead public interest entity working toward sustainable energy policies in Idaho, the Alliance
anticipates participating in this case on our behalf of our constituents. We believe our
participation in this case will assist the Commission and the Parties in working toward a
successful outcome inasmuch as the Alliance can help bring to this case the voice of clean
energy advocates and also that of Idaho Power's residential customer class. The Alliance has
pursued clean energy initiatives longer than any non-government public interest advocate in
Idaho and has a record of participating in energy efficiency and related cases before this
Commission since 2007.
The Alliance is aware that Commission Order No. 32512 envisions this case being processed
under Modified Procedure, and is prepared to participate to the extent allowed under Rules 201-
204 of the PUC's Rules of Procedure governing Modified Procedure. However, given the
established interests of the Alliance and its membership in this docket, and given the potential for
this case to include discovery proceedings as well as hearings and arguments on the merits of the
application, the Alliance believes it is entitled to participate in those forums should they arise.
The Alliance further believes this application to participate in this case as a party is timely filed,
and also that our participation in this matter will not unduly broaden the issues identified herein.
WHEREFORE, the Alliance respectfully requests the Commission grant its request to participate
in this proceeding as an intervenor on behalf of its Idaho constituents.
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
Boise, ID
[phone]
kmi11er(snakeriveralliance.org
Applicant SNAKE RIVER ALLIANCE certifies that copies of this PETITION TO
INTERVENE have been provided to the following:
Hand Delivery
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P0 Box 83720
Boise, Idaho 83720-0074
Via E-Mail
Julia A. Hilton
Lisa D. Nordstrom
Idaho Power Company
P0 Box 70
Boise, ID 83707
E-Mail: jhilton(idahopower.com ; 1nordstromidahopower.com
Darlene Nenmich
Greg Said
Idaho Power Company
P0 Box 70
Boise, ID 83707-0070
E-Mail: dnemnich(2iidahopower.com ; gsaid(2iidahopower.com
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27th Street
Boise, ID 83702
E-Mail: [e-mail]; greg(richardsonandoleary.com
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