20130122Petition to Intervene.pdf

March 3, 2013
Ken Miller 2 SNAKE RIVER ALLIANCE au'.J JAN 22
Box 1731 UJAHU
Boise, ID 83701 JiLHE C0
Ph: [phone]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE ) CASE NO. IPC-E-12-29
APPLICATION OF IDAHO POWER )
COMPANY FOR AUTHORITY TO ) PETITION TO INTERVENE OF
TEMPORARILY SUSPEND ITS )
A/C COOL CREDIT AND IRRIGATION ) THE SNAKE RIVER ALLIANCE
PEAK REWARDS DEMAND )
RESPONSE PROGRAMS )
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-12-29. 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: [e-mail]
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 participate in one or both
of the two demand response incentive programs at issue in this docket.
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 also supported
maintaining and expanding Idaho Power's A/C Cool Credit and Irrigation Peak Rewards demand
response programs in earlier dockets before this Commission. We are one of the few public
interest groups appearing regularly before this Commission that has advocated for robust
implementation of these demand response programs as well as other demand side management
programs implemented by Idaho Power.
The Alliance and its Idaho constituents have an ongoing interest in the preservation of these two
demand response measures, or at a minimum the preservation of the infrastructure needed to
support these programs in the event they are interrupted for one or more years and then placed
back into service. We believe we bring to this case the perspective of residential and irrigation
Idaho Power customers and program participants whose concerns might not otherwise be heard
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. We further
believe our participation in this case is fortified and informed by our long-running participation
in Idaho Power's Integrated Resource Plan Advisory Council and its Energy Efficiency Advisory
Committee proceedings over the past several years. Thanks to our participation in these and
other settings, we are very familiar with the changes in Idaho Power's load growth forecasts that
have precipitated this Idaho Power application.
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]
kmiller@snakenveralliance org