20140806Petition to Intervene.pdf

(208) 343-7s00
[phone] (Fax)
McDevitt & Mille, LLlt E c f; ltr r: i;
Lawverc zorr' AUG -E Pr{ l: ro
420 West Bannock SteqOAHti rlri-,.r,,,,
P.O. Box 2s64-a3uillllTl ES f;0F l lvl l$sIol{
Boise,Idaho 83702
Chas. F. McDevitt
DeanJ. (oe) Miller
Celeste I(" Miller
Via lfand Delivery
JeanJewell, Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise,Idaho 83720
Re: Siera Club/ IPC-E-14-18
Dear Ms.Jewell:
Enclosed for filing in the above matter, please
Intervene of the Sierra CIub.
Kindly rehrn a file samped copy to me.
DJM/hh
Enclosures
August 6,2074
find an original and seven copies of a Petition to
Very Truly Youts,
McDevitt & Miller LLPqAW=
DeanJ. Miller
ORIGINAL
Dean J. Miller (ISB No. 1968)
MoDEVITT & MILLER LLP
420 West Bannock Sheet
P.O. Box 256/.-83701
Boise,ID 83702
Tel: [phone]
Fax: [phone]
i [e-mail]
Matt Vespa
CA Bar #222265 (Pro Hac Vice pending)
Sierra Club
85 Second St.,2'd Fl.
San Francisco, CA 94105
matt.vespa@sierraclub. ore
Tel: [phone]
Fa,r: 415.977.5793
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20lE AUG -5 Pll l: I 0
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Attorneys for Sierra Club
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN Tr{E MATTER OF IDAHO POWER ) CASE NO.IPC-E-14-18
COMPANY'S APPLICATION TO )
IMPLEMENT SOLAR INTEGRATION ) PETITION TO INTERVENE OF
RATES AI\ID CHARGES. ) SIERRA CLUB
)
)
Sierra Club hereby petitions the Commission for leave to intervene in the above-titled
proceeding pursuant to the Commission's Rules of Practice and Procedure, IDAPA
31.01.01.071-.75. As discussed below, Sierra Club has a direct and substantial interest in these
proceedings, and therefore the Commission should grant intervention.
1. Sierra Club is a national, non-profit environmental and conservation organization
incorporated under the laws of the Sate of California. The Sierra Club is dedicated to the
protection of public health and the environment. Sierra Club petitions to intervene in this
proceeding on behalf of itself and the more than 2,800 Sierra Club members who live and
PETITION TO INTERVENE OFSIERRA CLTJB.l
|,
purchase utility services in Idaho, many of whom are residential customers of Idaho Power. The
name and address of Petitiouer Sierra Club is:
Sierra Club
85 Second Street. 2nd Floor
San Francisco, CA 94105
2. Sierra Club's Idaho members have a direct and substantial interest in this
proceeding because strategic issues related to Idaho Power's July l, 2014 Application with the
Commission seeking to implement solar integration rates and charges will have environmental,
health and economic consequences for Sierra Club members who are customers of Idaho Power.
These Sierra Club members have a right to participate in this proceeding to inform the
Commission of their interests, both environmental and economic, that relate to the impacts of
implementing solar integration rates and charges.
3. Sierra Club's Beyond Coal campaign seeks rapid replacement of fossil-fueled
generating units with cleaner forms of energy to eliminate or reduce global climate change
emissions, reduce utility bills, and generate renewable energy. Sierra Club's work includes
advocating for the implementation of robust incentive programs that assist its members and
utility consumers generally to generate their own renewable energy and increase energy
efficiency. The Sierra Club's work includes intervening in dockets at public utility commissions
nationwide, submitting comments in numerous state and federal agency energy-related
proceedings and rulemakings, attending and speaking at public hearings, speaking to students
and civic and other otganizationso and holding seminars and symposia - all in support of policies
to reduce the impact of climate change and other air pollution by promoting clean energy
alternatives and energy efficiency. Sierra Club members have worked tirelessly to promote clean
energy alternatives and energy efficiency measures.
PETITION TO INTERYENE OF SIERRA CLIIB -2
4. Sierra Club has a specific interest in this docket because its members who live
within Idalro Power's service territory are ratepayers and have a pecuniary and tangible interest
in the outcome of the proceeding. Sierra Club members have a direct interest in ensuring fair,
accurate rates and charges for clean energy sources in order to foster clean energy development
in Idaho Power's service tenitory. Sierra Club is concemed thatthe proposed charge may be
excessive, fail to account for the grid benefits of solar, and improperly stifle deployment of solar
in Idaho and displacement of carbon-intensive generation.
5. Intervention by Sierra Club will not unduly broaden the issues or delay the
proceeding because Sierra Club's interest is directly related to the subjects addressed in Idaho
Power's application.
6. Sierra Club's involvement in this proceeding will not be duplicative of other
parties in this proceeding because no other party adequately represents Sierra Club's interests.
While other environmental groups have petitioned to intervene in this proceeding, those groups
have different expertise than Siena Club. Sierra Club is therefore uniquely suited to representing
the interests of itself and its members in this proceeding. Sierra Club will also endeavor to
coordinate with other environmental groups to avoid any potentially duplicative efforts.
7 . At this time, Sierra Club does not know the nature and quantity of evidence it will
be presenting. Sierra Club will work with the other parties to ensure that the proceeding is
conducted in an efficient manner, and Siena Club will abide by all time limits to be established
or determined in this matter.
8. Sierra Club's petition to intervene is timely and consistent with the Commission's
Notice of Application, dated luly23,2014.
PETITION TO INTERVENE OF SIERRA CLUB.3
9. Sierra Club requests that all pleadings, correspondence, discovery, and other
documents be served on the following:
Matt Vespa
CA Bar #222265 (Pro Hac Yice pending)
Sierra Club
85 Second St.,2nd FI.
San Francisco, CA 94105
matt.vespa@sierraclub. org
Tel: [phone]
Fax: [phone]
Dean J. Miller (ISB No. 1968)
MoDEVITT & MLLER LLP
420 West Bannock Steet
P.O. Box 25&-83701
Boise,ID 83702
i [e-mail]
Tel: [phone]
Fax [phone]
WHEREFORE, Sierra Club respectfully requests that the Commission issue an order
granting its Petition to Intervene in the above-titled proceeding.
Dated this 6tr day if August,2Ol4
Matt Vespa (CA Bar #222265)
(Pro Hac Vice pending)
SrennaCLue
Attorneys for Sierra Club
PETITION TO INTERVENE OF SIERRA CLI'8.4
I hereby certiff that on *r. ffauy of Augus! 2Ol4,I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Hand Delivered K
U.S. Mail !i
Far
Fed. Express
Email
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Hand Delivered
U.S. Mail
Fa>r
Fed. Express
Email
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
CERTIFICATE OF SERVICE
Jean Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Steet
P.O. Box 83720
Boise,ID 83720-0074
ij ewell@puc. state.id.us
Donovan E. Walker
Greg Said
Michael f. Youngblood
Regulatory Dockets
Idaho Power Company
l22l West Idaho Street
P.O. Box 70
Boise, ID 83707
dwalker@idahopower. com
[e-mail]
myoun gblood@idahopower. com
dockets@idahopower. com
Idaho Conservation League
c/o Benjamin J. Otto
710 N.6th St.
Boise,Idaho 83702
botto@idahoconservation. org
Ken Miller
Snake River Alliance
Boise,ID
kmiller@ snakeriveralliance. org
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PETITION TO INTERVENE OF SIERRA CLUB.5