20130717Petition to Intervene.pdf

July 15,2013
Ken Miller
SNAKE RIVER ALLIANCE
Box 1731
Boise,ID 83701
Ph: [phone]
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF rDAHO POWER ) CASE NO. IPC-E-13-15
COMPANY'S 2OI3 INTEGRATED )
RESOURCE PLAN ) PETITION TO INTERVENE OF
THE SNAKE RIVER ALLIANCE
The Snake River Alliance, pursuant to the Idaho Public Utilities Commission's Rules of
Procedure Rule 72 andT3IDAPA 31.01.01 .072atd-.073,petitionsthe Commissionto grantits
request for intervention in the above-referenced case, IPC-E-13-15. The name and address of this
intervenor is:
Snake River Alliance
Box 1731
Boise,ID 83701
208 344-9161 (o)
208 84t-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
To reduce costs and environmental impacts of exchanging information in this case, the Alliance
requests that, pursuant to IPUC Rules, information other than that which might be deemed
confidential or otherwise must be hand-delivered be provided electronically and/or via email to
the above address.
The Snake River Alliance is an Idaho-based non-profit organization, established in 1979 to
address Idahoans' concerns about nuclear waste and safety issues. Ln2007, the Alliance
expanded the scope of its mission by becoming Idaho's first nonprofit clean energy advocacy
organization. The Alliance's energy program 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, including electric
utility rate structures and designs that promote energy conservation. The Alliance pursues these
programs on behalf of its members, many of whom are customers of Idaho Power. The Alliance
attended all meetings of the Idaho Power 2013 Integrated Resource Plan Advisory Council
(IRPAC) and participated as an IRPAC member or in other roles in the development of the four
IRPs preceding this one.
The Alliance and those it represents have a direct interest in this case for several reasons. As the
Commission is aware, the Alliance has raised a number of issues relating to Idaho Power's Coal
Unit Environmental Investment Analysis for the Jim Bridger and North Valmy Coal-Fired Power
Plants [coal study], which was filed with the Commission on Feb. 14 as part of the Company's
201I IRP Update in IPC-E-I1-l l. That study, and the data on which it is based, will be central to
the Commission's consideration of the 2013 IRP in this case.
The Alliance has also filed an application to intervene in IPC-E-13-16, Idaho Power's
application for a certificate of public convenience and necessity ICPCN] that was filed
simultaneously with this application. In that case, Idaho Power has asked the Commission to
conduct a CPCN review of its proposed investments in the Jim Bridger Units 3 and 4 coal plants.
This is important because, as the Commission is aware, the 2013 IRP is based in large part on the
continued operation of Idaho Power's rate-based coal assets, which provide approximately 40
percent of the Company's supply-side energy portfolio, depending on hydrological conditions
and other factors.
As the Alliance noted in its application to intervene in IPC-E-I3-16, the CPCN case has much in
common with this case, and with regard to Bridger Units 3 and 4 it also intersects with
PacifiCorp's 2013 tRP [PAC-E-I3-05], in which the Commission has granted the Alliance's
application to intervene. The Alliance has communicated to the Commission its concerns about
Idaho Power's 201I tRP Update and how that Update, which has received little if any public
scrutiny and critical portions of which are not available for public review, has been incorporated
into the 2013 IRP.
While the coal plant investment issues and the role of these plants in Idaho Power's generation
portfolio are important to the Alliance and its constituents, there are many other issues contained
in the 2013 IRP in which the Alliance has an interest. These include but are not limited to: Idaho
Power's policies relating to renewable energy resources, in particular solar resources, and how
they are valued for purposes of comparative portfolio modeling for use in the IRP; the status of
the Company's solar demonstration project; transmission issues; the role of demand response
programs and energy efficiency programs in meeting future load growth; carbon adder
methodologies and how an adder might impact dispatch decisions; the potential role of the
Northwest Power Pool Energy Imbalance Market to reduce region-wide dispatch costs and
address renewable energy variability concems; the Company's ongoing challenges in addressing
peak demands; and wind integration issues.
As in the companion CPCN case [IPC-E-l3-16], the Alliance believes it and those it represents
have direct interests in this case, that its participation as in intervenor will not complicate or
extend this case, and that to the extent allowed by Commission rules it will participate in this
case.
The Alliance therefore requests that the Commission grant its request to participate in this case
as an intervening party and that it be allowed to participate in this case on behalf of its
constituents.
Therefore and pursuant to Rules 72 and 73 of the Commission's Rules of Procedure, IDAPA
31.01.01.072 and073,the Alliance requests that this petition to participate in Case No. IPC-E-
13-15 be granted.
Respectfully submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
Boise,ID
[phone]
kmiller@ snakeriveralliance. org
Hand Delivered
Jean Jewell
Commission Secretary (Original and seven copies)
Idaho Public Utilities Commission
472W. Washington St.
Boise,lD 83702
By Electronic Mail
Lisa D. Nordstrom
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise,lD 83707
E-mail : [e-mail]
Jennifer Reinhardt-Tessmer
Idaho Power Company
1221 Westldaho Street (83702)
P.O. Box 70
Boise, lD 83707
E-mail : [e-mail]