20160923Petition to Intervene.pdf

Ken Miller
SNAKE RIVER ALLIANCE
223 N. 6th St., Ste. 317
PO Box 1731
Boise, ID 83701
Ph: [phone]
[e-mail]
RECEIVED
20 15 SEP 2 3 PM I : I 2
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
PETITION TO INTERVENE IN THE MATTER OF THE APPLICATION OF IDAHO
POWER COMP ANY FOR DEFERRAL AND RECOVERY COSTS ASSOCIATED
WITH PARTICIPATION AN ENERGY IMBALANCE MARKET
CASE NiO. IPC-E-16-19
Pursuant to the Idaho Public Utilities Commission's Rules of Procedure Rule 71, IDAPA
31.01.01.071, et seq., and in response to Commission Order No. 33595, the Snake River Alliance
petitions the Commission to grant its petition for intervention in the above-referenced case, IPC­
E-16-19. The name and address of the Intervenor is:
SNAKE RIVER ALLIANCE
223 N. 6th St., Ste. 317
PO Box 1731
Boise, ID 83701
Ph: [phone]
kmiller@snakeri veralliance. org
Pending further notice to the Commission and to Parties, Ken Miller will represent the Snake
River Alliance in this proceeding. Correspondence in this docket can be sent to the above address
or via email. 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 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. In 2007, the Alliance
expanded the scope of its mission by becoming Idaho's first nonprofit clean energy advocacy
Snake River Alliance 1
Petition to Intervene -IPC-E-16-19
organization. The Alliance's energy program advocates 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 and serve the interests of residential
customers of Idaho's regulated gas and electric utilities. The Alliance pursues these programs on
behalf of its members, most of whom are customers of Idaho Power Company and who have a
direct interest in this docket.
The Alliance has a direct and substantial interest in these proceedings as the Company's request
raises policy issues of interest to the Alliance and its members and other Idaho Power customers.
With regard to this docket, the Alliance intends to demonstrate support for Idaho Power's
application and its position that an Energy Imbalance Market (EIM) has the potential to deliver
real-time and immediate benefits to Idaho Power customers by identifying least-cost energy
resources to meet immediate and real-time customer demand. EIMs are proven and effective
tools to address energy imbalances while also supporting the balancing responsibilities of
utilities participating in the EIM pool. EIM trading mechanisms have proven to be more
economic and effective than traditional two-party energy delivery agreements between utilities.
While withholding endorsement ofldaho Power's cost-recovery proposals (including the
Company's anticipated incremental costs of $15.77 million) pending the processing of this case,
the Alliance acknowledges that Idaho Power should be expected to incur EIM-related costs, as
described in its Application, and should be entitled to recovering those costs in future
proceedings.
The Alliance believes its participation as an 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, ID APA
31.01.01.072 and 073 , the Alliance requests that this petition to participate as an intervenor in
Case No. INT-G-16-02 be granted.
2 IPC-E-16-19
,
Respectfully submitted this 23rd day of September 2016.
Ken Miller
Energy Program Director
Snake River Alliance
Boise, ID
[phone]
kmiller snakeriveralliance.or
Hand Delivered
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Snake River Alliance
Petition to Intervene -IPC-E-16-19
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