20140603Petition to Intervene.pdf

I|vf.ay 29,2014
Ken Miller
SNAKE RIVER ALLIANCE
Box l73l
Boise, ID 83701
Ph: (208) 344-9t61
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO
TEMPORAzuLY SUSPEND ITS PURPA
OBLIGATION TO PURCHASE ENERGY
GENERATED BY SOLAR POWERED
QUALIFYING FACILITIES (QFS)
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?0llt{AY 29 PH 3: l6
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. rPC-E-r4- 13
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 and 73 IDAPA 3 I .0 I .0 I .07 l-073 , petitions the Commission to grant its
request for intervention in the above-referenced case, [PC-E-14'l3,The name and address of this
intervenor is:
Snake River Alliance
Box 1731
Boise,ID 83701
208 344-9t61 (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. 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 [daho; 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
initiatives on behalf of its members, many of whom are customers of Idaho Power. Snake River
Alliance members have participated in prior Commission dockets dealing with many of the
issues raised in this case.
The Alliance has participated in proceedings dealing with many of the issues presented in this
docket, including Idaho Power's net-metering application, Case No. IPC-E-12-27.
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 Idaho solar power developers to integrate new
solar resources onto Idaho Power's system.
In addition, the Alliance remains very interested in working with Idaho Power, solar energy
developers, and other stakeholders to resolve many of the issues before the Commission in [PC-
E-14-09. The Alliance has reviewed the testimony of Mr. Randy Allphin and Mr. Philip DeVol
accompanying Idaho Power's Petition and believes it can bring a distinct perspective to ldaho
Power's Petition in this case and one that is important in the Commission's processing of 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 arrd 073, the Alliance requests that this Petition to participate as an intervenor in
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Case No. IPC-E-I$.{Z be granted.
Respectfrrlly submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
Boise,ID
(208) 344-et6t
kmiller@ snakeriveralliance. or g
I hereby certifr that on this 29th day of May,2Ol4,I delivered seven (7) true and correct copies
of the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Hand Delivered
Jean Jewell
Commission Secretary (Original and seven copies)
Idaho Public Utilities Commission
472W. Washington St.
Boise,lD 83702
By Electronic Mail
Donovan E. Walker
Lead Counsel
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise,lD 83707
E-mail : dwalker(Eidahopower.com
Donald L. Howell II
Kristine A. Sasser
Idaho Public Utilities Commission
472W. Washington
PO Box 83702
Boise,lD 83702
Don.howell@puc. idaho. gov
Kris. [e-mail]. eov
Peter Richardson
Robert Paul
Richardson & Adams, PLLC
515 North 27th Street
Boise,lD 83702
peter@,richardsonadams.com
Robertpaul8@ smail.com
Benjamin Otto
Idaho Conservation League
710 N. 6th Street
Boise,ID 83701
botto@ idahoconservation. org