20130129Petition to Intervene.pdf

R E(31 C /
January 29, 2013
Jean Jewell 2611 JAN 29 PM 2: 26
Commission Secretary ut3Lk. Idaho Public Utilities Commission (JTEJ11S CM•M•SX
472 W. Washington St.
Boise, ID 83702
Dear Ms. Jewell,
Please find attached four copies of the Snake River Alliance's Petition to the Public Utilities Commission
to Intervene in Case No. IPC-E-12-27.
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
Box 1731
Boise, ID 83701
208 344-8161
208 841-6982 (c)
January 29, 2013
Ken Miller
SNAKE RIVER ALLIANCE
Box 1731
Boise, ID 83701
Ph: [phone]
2013 JAN-2 PM 2: 26
IDAHO j LJii.lj!flFS
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-12-27
COMPANY'S APPLICATION FOR )
AUTHORITY TO MODIFY ITS NET ) PETITION TO INTERVENE OF
METERING SERVICE AND TO )
INCREASE THE GENERATION ) THE SNAKE RIVER ALLIANCE
CAPACITY LIMIT )
COMES NOW, Snake River Alliance and, pursuant to the Idaho Public Utilities Commission's
Rules of Procedure Rule 72 and 73 IDAPA 31.01.01.072 and -.073, petitions the Commission to
grant its request for intervention in the above-referenced case, IPC-E-12-27. 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(2isnakeriveralliance.org
The Snake River Alliance is an Idaho-based non-profit organization, established in 1979 to
address Idahoans' concerns about nuclear waste and 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 electric utilities and the
Bonneville Power Administration; and development of local, state, regional, and national
initiatives to advance sustainable energy policies. The Alliance pursues these programs on behalf
of its members, many of whom are customers of Idaho Power and who are existing Idaho Power
net metering customers or who are contemplating becoming net metering customers.
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. The Alliance has been a strong
advocate of all electric utility net metering programs, and many of our members are deeply
concerned about the possible negative impacts that could result if the application in IPC-E-12-27
is approved by the Commission. We share those concerns. More specifically, our members who
are current Idaho Power net metering customers believe that approval of this application will
eliminate most of the benefits of participating in a net metering program and that this request, if
granted, would send a powerful negative signal to other Idaho Power customers (including those
who are members of the Snake River Alliance) who are considering enrolling in the program. To
the extent this application may dampen or erode participation in net metering, we believe it poses
a threat to the continued expansion of renewable energy implementation in Idaho Power's
service territory. In addition, our members who are net metering customers have expressed
concerns that they enrolled in Idaho Power's net metering program under one set of rules
through their agreement with Idaho Power, and that the company now is seeking to dramatically
and unilaterally alter the conditions of net metering participation.
We also note that public interest is unusually high in this case, as borne out by the amount of
public comments received by the Commission to date.
The Alliance and its Idaho constituents are keenly interested in the outcome of this case, as well
as the discussions and exchanges of views by all parties as the case progresses. We believe we
bring to this case the perspective of concerned residential Idaho Power customers and program
participants who have made or who are considering making considerable investments in
residential scale solar photovoltaic systems to their property but who also believe those
investments are now at risk or are not worth pursuing.
As a lead public interest entity working toward sustainable energy policies in Idaho, we
anticipate participating in this case on our behalf of our constituents. We believe our
participation in this case will assist the Commission and the other intervening 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.
WHEREFORE, the Alliance therefore 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]
kniiller(snakeriveralliance.org