20140715Petition to Intervene.pdf

luJy 15,2014
Ken Miller
SNAKE RIVER ALLIANCE
Box 1731
Boise,ID 83701
Ph: [phone]
TN THE MATTER OF THE COMMISSION'S
INQUIRY INTO IDAHO POWER'S
FIXED COST ADruSTMENT
MECHANISM
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASENO. IPC-E-14-17
PETITION TO INTERVENE OF
THE SNAKE RIVER ALLIANCE
Pursuant to the Idaho Public Utilities Commission's Rules of Procedure Rule 72 and 73 IDAPA
31.01.01 .072 and -.073, and in response to Commission Order No. 33068, the Snake River
Alliance petitions the Commission to grant its request for intervention in the above-referenced
case, [PC-E-14-17. The name and address of this intervenor is:
Snake River Alliance
Box l73l
Boise,ID 83701
208 344-9t61 (o)
208 84r-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 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 has a long history of participating before this Commission in cases relating to Idaho
Power's Fixed Cost Adjustment mechanism dating to the establishment of the FCA as a pilot
mechanism. The Alliance has been a strong supporter of Idaho Power's Demand-Side
Management programs and also the FCA as the chosen mechanism to decouple Idaho Power's
volumetric sales from the Company's fixed-cost revenues.
Given the Commission's decision to open this docket to examine Commission Staff s stated
concerns about whether the existing FCA is fulfilling its designed purpose, the Alliance has a
direct interest in the processing of this case and therefore requests that the Commission grant this
application to participate in IPC-E-14-I7 as an intervenor as the Commission, staff, and other
interested parties evaluate Staff s concerns about the FCA mechanism.
The Alliance believes 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 permiued
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-14-17 be granted.
Respectfu lly submitted,
Ken Miller
Clean Energy Program Director
Snake River Alliance
Boise,ID
(208) 344-916r
kmiller@ snakeriveralliance. org
Hand Delivered
Jean Jewell
Commission Secretary (Original and seven copies)
Idaho Public Utilities Commission
472W. Washington St.
Boise,lD 83702