20130129Petition to Intervene.pdf

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McDevitt & Miller LLP
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420 W. Bannock Street
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Boise, Idaho 83702
RE . .I
JAN .kDevitt
L)e.tn J . (Joe) e) NI ii icr
January 29, 2013
Via Hand Deivevy
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, Idaho 83720
Re: Case No. IPC-E-12-27
Idaho Clean Energy Association Inc.
Dear Ms. Jewell:
Enclosed for filing in the above matter, please find an original and seven (7) copies of Idaho Clean
Energy Association Inc's Petition to Intervene.
Kindly return a file stamped copy to me.
Very Truly Yours,
McDevitt & Miller LLP
Dean J. Miller
DJM/hh
Enclosures
ORIGINAL
Dean J. Miller (ISB No. 1968)
Chas. F. McDevitt (ISB No. 835)
Celeste K. Miller (ISB No. 2590)
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564-83701
Boise, ID 83702
Tel: [phone]
Fax: [phone]
joemcdevitt-miller.com
[e-mail]
[e-mail]
Attorney for Idaho Clean Energy Association Inc.
78,113 AN PM 3:32
tD,J-i UTILITE: 0M 101,01
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO MODIFY ITS NET
METERING SERVICE AND TO INCREASE
THE GENERATION CAPACITY LIMIT
Case No. IPC-E-12-27
PETITION TO INTERVENE OF IDAHO
CLEAN ENERGY ASSOCIATION INC.
COMES NOW the Idaho Clean Energy Association Inc., (ICEA) and, pursuant to RP 72-
75, Petitions to Intervene in the above matter, and in support thereof respectfully shows as
follows, to wit:
I.
ICEA is a corporation organized and existing under the laws of the State of Idaho
pursuant to the Idaho Nonprofit Corporation Act, Idaho Code 30-3-1 et. seq.
II.
Among the corporate powers of ICEA is "to advocate for the advancement of clean
energy in public policy and public discourse".
PETITION TO INTERVENE OF IDAHO CLEAN ENERGY ASSOCIATION INC.4
III.
The membership of ICEA is comprised of business enterprises dedicated to the
advancement of the clean energy industry in Idaho.
The Board of Directors of ICEA has authorized the filing of this Petition and
participation in this proceeding.
All pleadings, papers, orders and notices should be served upon:
Dean J. Miller
McDEVITT & MILLER LLP
P.O. BOX 2564-83701
Boise, Idaho 83702
[e-mail]
And
Board of Directors
Idaho Clean Energy Association Inc.
P.O. Box 1212
Boise, ID 83701
VI.
ICEA desires to participate in this proceeding with full rights of a party to, if necessary,
introduce evidence, cross examine and participate in hearings or oral argument. The exact
quantity of evidence to be introduced cannot be stated at this time, but ICEA's participation will
not unduly broaden the issues or cause delays.
VII.
ICEA claims a direct and substantial interest in the proceeding because the proposals
contained in Idaho Power's Application, if approved, would hamper the growth of the green
energy industry in Idaho.
PETITION TO INTERVENE OF IDAHO CLEAN ENERGY ASSOCIATION INC.-2
VIII.
ICEA believes that the nature and complexity of issues presented by Idaho Power
Company's Application are such that they would be best examined by a technical hearing. ICEA
requests that the Commission schedule a technical hearing, preceded by an appropriate period
during which discovery may be conducted.
Ix.
Depending on future developments, ICEA may seek intervenor funding pursuant to RP
161-165.
DATED this day of January, 2013.
IDAHO CLEAN ENERGY ASSOCIATION INC.
By UL
Dan . iller
Attorney for Idaho Clean Energy Association Inc.
PETITION TO INTERVENE OF IDAHO CLEAN ENERGY ASSOCIATION INC.-3
CERTIFICATE OF SERVICE
I hereby certify that on the Jrday of January, 2013, I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary Hand Delivered
Idaho Public Utilities Commission U.S. Mail
472 West Washington Street Fax
P.O. Box 83720 Fed. Express
Boise, ID 83720-0074 Email
[e-mail]
Lisa D. Nordstrom Hand Delivered
Matt Larkin U.S. Mail
Greg Said Fax
Idaho Power Company Fed. Express
1221 West Idaho Street (83702) Email
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]
gsaid(idahopower.com
Benjamin J. Otto Hand Delivered U
710N. 6th Street U.S. Mail U
Boise, Idaho 83701 Fax U
[e-mail] Fed. Express U
Email
Peter J. Richardson Hand Delivered
Richardson & O'Leary, PLLC U.S. Mail I.
PO Box 72l8 Fax
Boise, ID 83702 Fed. Express
[e-mail] Email
Chris Aepelbacher, Project Engineer Hand Delivered
5420 W. Wincher Road U.S. Mail U
Gleans Ferry Idaho 83623 Fax U
[e-mail] Fed. Express U
Email
BY: '1Mho
MCDEVIrF & MILLER LLP
PETITION TO INTERVENE OF IDAHO CLEAN ENERGY ASSOCIATION INC.4