20130717Petition to Intervene.pdf

July 17,2013
Ken Miller
SNAKE RIVER ALLIANCE
Box 1731
Boise,ID 83701
Ph: [phone]
ll
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-13-16
COMPANY'S APPLICATION FOR A )
CERTIFICATE OF PUBLIC CONVENIENCE ) PETITION TO INTERVENE OF
AND NECESSITY FOR THE )
INVESTMENT IN SELECTIVE ) THE SNAKE RIVER ALLIANCE
CATALYTIC REDUCTION CONTROLS )
ON JIM BRIDGER UNITS 3 AND 4 )
The Snake River Alliance, pursuant to the Idaho Public Utilities Commission's Rules of
Procedure Rule 72 andT3IDAPA 31.01.01 .072and-.073,petitionsthe Commissionto grantits
request for intervention in the above-referenced case, IPC-E-I3-16. 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]
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. In2007, the Alliance
expanded the scope of its mission by becoming ldaho's first nonprofit clean energy advocacy
s2
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
progrirms on behalf of its members, many of whom are customers of ldaho Power.
The Alliance and those it represents have a direct interest in this case for several reasons. As the
Commission is aware, the Alliance has expressed myriad concems regarding the intent of Idaho
Power and its largest coal plant partner, PacifiCorp, to undertake significant investments in their
jointly owned assets at the Jim Bridger coal plant in Wyoming. Idaho Power's 2013 IRP [IPC-E-
13-15] is based in part on the continued operation of this rate-based asset through the duration of
this IRP planning horizon. For that to happen, as the Company points out in its application and
accompanying testimonies of Lisa Grow, Michael Youngblood, and Tom Harvey, Idaho Power
would need to make significant capital investments in Bridger Units 3 and 4 in order for those
units to comply with existing state and federal environmental regulations and statutes.
The Alliance has a long history of advocacy on utility coal plant issues. Its staff members met
with the Commissionin2012 specifically to discuss this and related issues. It has advocated
before the Commission and directly with Idaho Power to encourage the Company to ensure that
it consider all options when evaluating the future of its coal assets. Following the Company's
filing with this Commission its 2011 IRP Update on Feb. 14,2014, in IPC-E-11-l l, the Alliance
on March 1l filed a detailed response [SRA ADDITIONAL COMMENTS]. These two filings
remain in IPC-E-11-11, contained in the Commission's "Closed Cases" files.
As have stakeholders in other jurisdictions where Idaho Power and PacifiCorp have filed 2013
IRPs or related dockets that contained confidential material relating to each utility's coal plant
analysis, the Alliance was concerned upon the filing of the 201I IRP Update that it would be
difficult if not impossible to fully evaluate the Company's conclusions without also being able to
assess the excised material. Rather than burden the Commission and Idaho Power by pursuing
the confidential material in IPC-E-I1-11, and confident that this CPCN application would be
filed in proximity to the filing of the 2013 IRP, and wanting avoid duplication, the Alliance
opted instead to await the filing of IPC-E-I3-16, which contains the same confidential material
as well as other information not disclosed in the Application or accompanying testimonies and
exhibits.
The Alliance seeks status as a party to this case to enable it to review the merits of tdaho Power's
CPCN request for Bridger Units 3 and 4. While Commission rules prohibit the Alliance from
participating in certain areas of the case requiring the benefit of counsel, the Alliance's
experience with the issues at hand position it well to otherwise participate as a party.
Furthermore, the Alliance and its members are directly involved in the issues that will be
addressed in this case and, of course, in its outcome. We believe our participation in this case
will assist the Commission and intervening parties in the administration of this docket inasmuch
as the Alliance helps bring the voice of clean energy advocates to this case. We believe our
participation will not burden the Commission, the Company and other parties.
We believe this case will present the Commission with many of the issues that will be addressed
in PacifiCorp's 2013 IRP [PAC-E-13-05] for which the Alliance has been granted permission to
intervene and in which it has provided executed protective agreements to Rocky Mountain
Power in order to be able to review similarly confidential materials relating to Bridger Units 3
and 4, among other issues. For that matter, Idaho Power's 2013 IRP [IPC-E-13-15] is equally
intertwined with this Application as is PacifiCorp's 2013 IRP. Each of the three cases involves
Bridger Units 3 and 4 to some degree, and the outcome of this case might have profound impacts
on resource planning by both utilities.
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 arrd 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. PAC-E-
13-05 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,ID 83707
E-mail : [e-mail]
Jennifer Reinhardt-Tessmer
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise,ID 83707
E-mail: [e-mail]