20130610Petition to Intervene.pdf

K&L GATES
June 10, 2013 Teresa Hill
teresa. [e-mail]
T +1 208.850.7422
By Courier
Jean D. Jewell, Secretary
ldaho Pubic Utilities Commission
472W. Washington St.
Boise, lD 83702
Re: Case No. IPC-E-13-14
IN THE MATTER OF THE CONTINUATION OF IDAHO POWER COMPANY'S A/C
COOL CREDIT, IRRIGATION PEAK REWARDS, AND FLEXPEAK DEMAND
RESPONSE PROGRAMS FOR 2014 AND BEYOND
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and seven (7) copies of
EnerNOC's Petition to lntervene.
K&L GATES LLP : ;:, -,
222 SW COLUMBIA STREET
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T *1 503 228 3200 F *1 503 248 9085 klgates.com
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Thank you,
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Teresa Hill (
K&L Gates, LLP
Enclosure: Petition to lntervene
IPUC Cover Lettor.docx ( v )
Teresa A. Hill
ISB No.6175
K&L Gates, LLP
222 Columbia St. Suite 1400
Portland, OR 97201
Telephone : [phone]
Fax: [phone]
Attorney for EnerNOC, lnc.
IN THE MATTER OF THE
CONTINUATION OF IDAHO POWER
coMPANY',S A/C COOL CREDIT,
IRRIGATION PEAK REWARDS, AND
FLEXPEAK DEMAND RESPONSE
PROGRAMS FOR 2014 AND BEYOND
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
t1i -i
:-:l' l
Case No. IPC-E-13-14
PETITION TO INTERVENE
OF ENERNOC,INC,
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ENERNOC lNC. ("EnerNOC") hereby petitions the Commission for leave to intervene in the above
titled proceeding pursuant to Rules 71 through 75 of the Commission's rule of Practice and Procedure,
IDAPA 31.01.OL.O72-O75 and the Notice of lnformal Prehearing Conference. ln support of this Petition,
EnerNOC submits the following:
1. The name and address of EnerNOC, lnc. is:
Melanie Gillette
Di rector, Regulatory Affairs
EnerNOC, lnc.
115 Hazelmere Drive
Folsom, CA 95530
Telephone: [phone]
Fax: (415) 227-L645
mgi I [e-mail]
2. EnerNOC's representative for the purpose of service of pleadings and other written materials is:
Teresa A. Hill
K&L Gates, LLP
222 Columbia St. Suite 1400
Portland, OR 97201
Telephone : (208l, 850-7 422
Fax: [phone]
teresa.hill @ klgates.com
3. EnerNOC is a leading developer and provider of clean and intelligent power solutions to
commercial, institutional, and industrial customers, as well as electric power grid operators and
utilities. EnerNOC's technology-enabled demand response and energy management solutions
help optimize the balance of electric supply and demand. EnerNOC serves demand response
customers throughout the Northeastern United States, as well as Arizona, Australia, California,
Canada, Colorado, Florida, ldaho, New Mexico, New Zealand, Oregon, the Tennessee Valley,
Texas, Utah and the United Kingdom. EnerNOC maintains 39 full time employees in its Boise,
ldaho field office.
EnerNOC contracts with ldaho Power to manage the FlexPeak Management Program
("FlexPeak Program") pursuant to a February 23,2009 Demand Response Agreement
("Agreement") (as amended pursuant to Orders 31098 and 32805), under which ldaho Power
provides a voluntary demand response program for its large commercial and industrial
customers. On May 9,2OL3, the Commission issued Order No. 32805 implementing changes to
the FlexPeak Program for the 2013 season. The Agreement expires in February 2014.
EnerNOC also provides program implementation services for the the lrrigation Peak
Reward Program ("Peak Reward Program"), which provides irrigation customers with a financial
incentive for allowing ldaho Power to turn off their irrigation pumps during periods of high
system demand during summer months. This program was suspended for the 2013 season
pursuant to Order No. 32776.
Each of these programs serves ldaho Power customers in both Oregon and ldaho.
4. EnerNOC has a direct and substantial interest in this proceeding because EnerNOC manages the
FlexPeak Program and provides program implementation services for the Peak Rewards
Program, two of the three demand response programs being considered in this docket. The
outcome of this proceeding and the continuation or modification of ldaho Power's demand
response programs for 20L4 and beyond will have a direct affect on EnerNOC's future contracts
in ldaho.
5. EnerNOC intends to monitor the proceedings as a party and, if necessary, raise issues that are
appropriate to the proceeding. No other party can adequately address EnerNOC's interests in
this proceeding.
WHEREFORE, EnerNOC respectfully requests that the Commission grant this petition to lntervene
and authorize EnerNOC to participate in the above-entitled proceeding with the full rights of a
formal party.
DATED this 10th day ofJune, 2013
K&L Gates, LLP
Teresa Hill
Attorney for EnerNOC, lnc.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of June, 2073, a true and correct copy of the foregoing
PETITION TO INTERVENE BY ENERNOC, Case No. IPC-E-13-14, was served by electronic mail and U.S.
Mail, properly addressed with postage prepaid, to:
Lisa D. Nordstrom
Regulatory Dockets
ldaho Power Company
1221West ldaho Street (83702)
PO Box 70
Boise, ldaho 83707-0070
E-mail: lnordstrom @idahopower.com
Courtney Waites
Tim Tatum
ldaho Power Company
1221West ldaho Street (83702)
PO Box 70
Boise, ldaho 83707-0070
E-mail: [e-mail]
ttatu m @ idahopower.com
Donald L. Howell,ll
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington Street (83702)
PO Box 83720
Boise, ldaho 83720
E-mail: don.howell @puc.idaho.eov
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chartered
20L E. Center Street
PO Box 1391
Pocatello, ldaho 83204-1391
E-mail: [e-mail]
Anthony Yankel
298L4 Lake Road
Bay Village, OH 44L40
E-mail: [e-mail]
Ken Miller
Snake River Alliance
PO Box 1731
Boise, ldaho 93701
E-mail: [e-mail]
Benjamin J. Otto
ldaho Conservation League
710 N. Sixth Street
Boise, ldaho 83702
E-mail : botto@ idahoconservation.org
Peter J. Richardson
Richardson & O'Leary
515 N. 27th Street
Boise, ldaho 83516
E-mail : peter@ richardsonandolearv.com
Dr. Don Reading
5070 Hill Road
Boise, ldaho 83703
E-mail: [e-mail]
%4-Z
Teresa Hill