20140117Petition to Intervene.pdf

January 17,2013
Ken Miller
SNAKE RIVER ALLIANCE
Box l73l
Boise,ID 83701
Ph: (208) 344-9t61
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
UPDATE ITS WIND INTEGRATION
RATES AND CHARGES
n0lJU
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-13.22
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 31.01.01.072 and -.073, petitions the Commission to grant its
request for intervention in the above-referenced case, IPC-E-13-22. 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 ldaho-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 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 ldaho'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 has participated in proceedings dealing with many of the issues presented in this
docket dating back to 2005 (Case No. IPC-E-05-22, Petition for Temporary Suspension of
PURPA Contract Obligation for Wind QFs), and also in Case No. IPC-E-07-03 (To Eliminate
the90Yolll0% Performance Band for Wind-Powered Small Power Production Facilities) and
GNR-E-11-01 (In the Matter of the Commission Investigation Into Disaggregation and an
Appropriate Published Avoided Cost Rate Eligibility Cap Structure for PURPA Qualifuing
Facilities).
Many of the issues present in this instant docket are similar in some fashion to some of those
issues in the above-referenced cases. The Alliance and those it represents have a direct interest in
this case for several reasons. As an advocate of renewable energy generation, the Alliance
believes this case will determine in part the ability of Idaho Power and of prospective ldaho wind
power developers to integrate new wind resources onto Idaho Power's system. In addition, the
Alliance remains very interested in working with Idaho Power, wind developers, and other
stakeholders to resolve some of the outstanding integration issues that will be addressed in IPC-
E-13-22. The Aliance has reviewed the direct testimony of Michael J. Youngblood and Philip
DeVol accompanying Idaho Power's application in this case and believes it can bring a distinct
perspective to Idaho Power's most recent wind integration study, which will also be central to
processing this docket.
The Alliance believes it and those it represents have direct and substantial interests in the
processing and outcome of this case. It also believes that its participation as in intervenor will not
complicate or extend this case, nor will its participation unduly broaden the issues in this case,
and that to the extent permitted by Commission rules it will actively participate in this case as an
intervenor.
Therefore and pursuant to Rules 72 and 73 of the Commission's Rules of Procedure, IDAPA
31.01.01 .072 and 073, the Alliance requests that this petition to participate as an intervenor in
Case No. IPC-E-13-22 be granted.
Respectfully submitted,
.ffi41/A
Ken Miller
Clean Energy Program Director
Snake River Alliance
Boise,ID
(208) 344-et6t
kmiller@ snakeriveralliance. org
Hand Delivered
Jean Jewell
Commission Secretary (Original and seven copies)
Idaho Public Utilities Commission
472W. Washington St.
Boise,lD 83702
Bv Electronic Mail
Donovan E. Walker
Lead Counsel
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise,lD 83707
E-mail : [e-mail]
Julia Hilton
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, lD 83707
E-mail: [e-mail]