20170404Petition to Intervene.pdf

Benjamin J. Otto, ISB No. 8292
Idaho Conservation League
Post Office Box 844
Boise,Idaho 83701
(208) 34s-6933 x 12
botto@idahoconseryation. org
David Bender, WI Ba# 1046102 (pro hac vice pending)
Earthjustice
3916 Nakoma Road
Madison, WI 53711
(202) 667-4s00
dbender@earthj ustice. org
)IN THE MATTER OF THE PETITION OF )
rDAHO POWER COMPANY FOR )A DECLARATORY ORDER REGARDING )PROPER CONTRACT TERMS, )
CONDITIONS, AND AVOIDED COST )PRICING FOR BATTERY STORAGE )FACILITIES )
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-T7-OI
JOINT PETITION TO INTERVENE
OF IDAHO CONSERVATION
LEAGUE AND SIERRA CLUB
Pursuant to IDAPA 31.01.01.042, Idaho Conservation League (ICL) and Siena Club
hereby submit this petition to intervene as joint parties. ICL and Sierra Club share many strategic
goals and interests. Specifically for this docket, as discussed in more detail below, both ICL and
Sierra Club have direct and substantial interests in the development of cost-effective renewable
generation resources, including those developed by qualifred facilities pursuant to the federal
Public Utilities Regulatory Policy Act.
Idaho Conservation League
1. The name and address of Idaho Conservation League is:
Idaho Conservation League
710 N. 6th st.
Boise,Idaho 83702
Ph: [phone] xl2
Fax [phone]
botto @idahoconservation. org
2. Idaho Conservation League claims a direct and substantial interest in this proceeding arising
from the impact to its members served by Idaho Power and to its long-term role advocating
for public values. As Idaho's largest state-based conservation organization, ICL represents
25,000 supporters, most of whom are residential customers of Idaho Power. ICL, as an entity,
is a small commercial customer of Idaho Power. ICL and our supporters have an interest in
ensuring Idaho Power's electric system provides reliable, fair-priced service that protects the
clean air, clean water, and stable climate that are foundational public values for Idahoans.
ICL brings a unique and valuable perspective to this proceeding because our members are
customers of Idaho Power who support the transition to clean energy resources including
battery storage. ICL's intervention represents our supporters' interest in ensuring fair and
equitable rules that allow independent clean energy providers to compete in Idaho.
Sierra CIub
3. The name and address of Sierra Club is:
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA94612
(4ts) 977-s727
4. Sierra Club is a national, non-profit environmental and conservation organization
incorporated under the laws of the State of California. The Sierra Club is dedicated to the
protection of public health and the environment. Sierra Club petitions to intervene on behalf
of itself and over 2,600 Sierra Club members who live and purchase utility services in Idaho,
many of whom are residential customers of Idaho Power. Sierra Club brings a unique and
valuable perspective to this proceeding because its members are customers of Idaho Power
who support the transition to clean energy resources including battery storage. Sierra Club's
intervention represents its members' interests in ensuring and promoting fair and equitable
rules and policies that allow clean energy, including by qualified facilities, to compete and
provide cost-effective energy in Idaho.
5. Sierra Club, on behalf of its members, has a right to participate in this proceeding to inform
the Commission of their interests, both environmental and economic, that relate to the
development of cost effective clean energy solutions in Idaho.
6. The joint intervention of ICL and Sierra Club will not unduly broaden the issues or delay the
proceeding because the interests of ICL and Sierra Club are directly related to the subjects
addressed in Idaho Power's petition.
7. Sierra Club and ICL request that all future pleadings, correspondence, discovery, and other
documents be served on the following:
Ben Otto
ISB No. 8292
Energy Associate
Idaho Conservation League
Post Office Box 844
Boise,Idaho 83701
208-345-6933 xl2
botto@idahoconservation. org
David Bender
WI Bar# 1046102 (pro hac vice pending)
Earthjustice
3916 Nakoma Road
Madison, WI 5371I
(202) 667-4s00
dbender@earthj ustice. org
WHEREFORE, ICL and Sierra Club respectfully request that the Commission issue an
order granting ICL and Sierra Club permission to appear in this matter as joint parties.
Dated this 4tr day of April,2ol7.
Resvefiilv
Z2A
submitted,H
Benjamin J. Otto
Attorneyfor ldaho Consertation League and Sierra
Club
CERTIFICATE OF SERVICE
I hereby certify that on this 4e day of April2017,I delivered true and correct
copies of the foregoing PETITION TO INTERVENE to the following persons via the method of
service noted:
Hand delivery:
Jean Jbwell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
(Original and seven copies provided)
Electronic Mail:
Idaho Power
Donovan Walker
Lead Counsel
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
dockets@idahopower. com
Franklin Enerry Storage One through
Four, LLC
Peter Richardson
Richardson Adams, PLLC
515 North 27th Street
PO Box 7218
Boise,ID 83707
Peter@richardsonadams. com
Black Mesa Enerry, LLC
Brian Lynch
Black Mesa Energy, LLC
PO Box 2731
Palo Verdes, CA 90274
[e-mail]
Benjamin J. Otto
IPC-E-17-01
MOTION FOR PRO HAC VICE