20140121Petition to Intervene.pdf

Teresa A. Hill
lSB No.6175
K&L Gates, LLP
One SW Columbia St. Suite 1900
Portland, OR 97258
Telephone : [phone]
Fax: [phone]
Attorney for Renewoble Northwest Project and Americon Wind Energy Associotion
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY TO UPDATE ITS WIND
TNTEGRATION RATES AND
CHARGES.
r;1:' !..rr;,.! .i.;;
) Case No. IPC-E-13-22
)
) PETTTTON TO TNTERVENE
) oF RENEWABLE NORTHWEST pROJEgr AND
AMERICAN WIND ENERGY ASSOCIATION
)
i:ll i.. nqi JI Li'LJJ
Renewable Northwest Project ("RNP") and American Wind Energy Association ("AWEA") hereby
petition 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 37.07.07.072-.075. ln support of
this Petition, RNP and AWEA submit the following:
1. RNP is a non-profit regional advocacy group that works to facilitate the expansion of responsibly
developed renewable energy resources in the Northwest. RNP's unique coalition of members
includes renewable energy project developers, public and consumer interest groups, academic
institutions, turbine manufacturers, and others. The common goal of RNP's members is to
promote the development of a cost-effective, reliable, and clean energy system for the
betterment of the Northwest economy and environment. ln furtherance of this goal, RNP
monitors and actively participates in numerous forums related to the integration of wind and
PETITION TO INTERVENE OF RNP AND AWEA- 1
other variable energy resources. RNP has followed the development and review of ldaho Power
Company's ("ldaho Power" or the Company'') 2013 lntegrated Resource Plan and participated
in other forums addressing the Wind lntegration Study that underpins the Company's
Application in this proceeding. The name and address of RNP is:
Renewable Northwest Project
421 SW 6th Ave, Suite 1125
Portland, OR 97204
2. AWEA is a nationaltrade organization that represents a broad range of entities with a common
interest in encouraging the expansion and facilitation of wind energy resources in the United
States. AWEA s members include wind turbine manufacturers, component suppliers, project
developers, project owners and operators, financiers, researchers, renewable energy
supporters, utilities, marketers, customers and their advocates. AWEA also monitors and
actively participates in various forums on wind integration issues. AWEA's name and address is:
American Wind Energy Association
1501 M Street, NW
Washington, DC
3. RNP and AWEA have a direct and substantial interest in this proceeding because the
Commission's implementation of the Public Utility Regulatory Policies Act ("PURPA") has
significant impacts on investment in renewable energy in ldaho. ln addition, the Commission's
review of ldaho Power's proposed charges and rates associated with integrating wind energy,
and any policies adopted pursuant to such review, are likely to have significant impacts upon
investment in wind generation in ldaho. Both petitioning organizations share an interest in
promoting the responsible expansion of renewable energy in the Northwest, and decisions
issued in this case may impact their ability to advance that interest. Moreover, certain of RNP
and AWEA s members se!! the output of their wind energy facilities to ldaho Power; if the
Commission approves the proposals contained in the Company's Application, such proposals
PETITION TO INTERVENE OF RNP AND AWEA- 2
would have a material adverse effect upon these members' projects. Accordingly, no other
party can adequately address the interests of RNP and AWEA in this proceeding.
RNP and AWEA seek intervention in this proceeding with full rights of a party to, if necessary,
introduce evidence, cross-examine, and participate in hearings or oral argument or otherwise
present such materials as may be relevant to the Commission's decision in this matter. The
exact quantity of evidence that RNP and AWEA would introduce cannot be stated at this time,
but RNP and AWEA's participation will not unduly broaden the issues or cause delays.
RNP and AWEA believe that the nature and complexity of the issues presented by ldaho Powe/s
Application are such that they would be best examined by a technical hearing. RNP and AWEA
request that the Commission schedule a technical hearing, preceded by an appropriate period of
time during which the parties may conduct discovery.
ln accordance with IDAPA 31.01.01.063, RNP and AWEA request that the Commission direct that
service among the parties be accomplished by electronic mail for information other than that
which might be deemed confidential or othennise must be hand-delivered. RNP and AWEA
request that all pleadings, papers, orders, and notices be served upon:
Teresa A. Hill
K&L GatES, LLP
One S.W. Columbia Street, Suite 1900
Portland, OR 97258
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
And
Dina M. Dubson
Renewable Northwest Project
421SW 6th Ave, Suite 1125
Portland, OR 97204
Telephone: [phone]
Email: [e-mail]
4.
5.
6.
PETITION TO INTERVENE OF RNP AND AWEA_ 3
WHEREFORE, RNP and AWEA respectfully nequest that the Commission grant this Petition to
lntervene and authorize RNP and AWEA to participate in the above-captioned proceeding with the full
rights of a forma! party.
DATED this 21$ day of January,2OL4
K&L Gates, LLP
,,7W
Teresa Hil!
Attorneyfor RNP and AWEA
PETITION TO INTERVENE OF RNP AND AWEA- 4
CERTIFICATE OF SERVICE
I hereby certifli that on the 21'tday of January, 2OL4, atrue and correct copy of the foregoing
PETITION TO INTERVENE OF RENEWABLE NORTHWEST PROJECT AND AMERICAN WIND ENERGY
ASSOCIATION, Case No. IPC-E-13-22,was served to:
Hand Delivered
Jean Jewell
Commission Secretary
ldaho Public Utilities Commission
472W. Washington St.
Boise,lD 83702
Bv Electronic Mail
Donovan E. Walker
ldaho Power Company
1221West ldaho Street
P.O. Box 70
Boise, lD 83707
E-mail: dwal ker@ idahopower.com
Julia Hilton
ldaho Power Company
1221West ldaho Street
P.O. Box 70
Boise, lD 83707
E-mail : jhilton@ idahopower.com
DATED this 21't day of January,2Ot4
K&L Gates, LLP
Teresa Hill
Attorney for RNP and AWEA
PETITION TO INTERVENE OF RNP AND AWEA- 5