20170918Petition to Intervene.pdf

Gregory M. Adams (ISB No. 7454)
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone : [phone]
Fax: [phone]
greg@richardsonadams. com
Attorney for the Renewable Energy Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2017 INTEGRATED
RESOURCE PLAN
CASE NO. IPC.E.I7-II)
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PETITION OF RENEWABLE
ENERGY COALITION FOR
LEAVE TO INTERVENE OUT
OF TIME
Pursuant to Rules 7l through 75 of the Idaho Public Utilities Commission's Rules
of Practice and Procedure, IDAPA 31.01.01 .071 et. seq., Renewable Energy Coalition
("REC") petitions the Idaho Public Utilities Commission (the "Commission") for leave to
intervene out of time in this proceeding. In support of this Petition, REC states as
follows:
l. The name and address of REC is:
Renewable Energy Coalition
c/o John Lowe
PO Box 25576
Portland, OR 97298
E-Mail: [e-mail]
REC PETITION TO INTERVENE
rPC-E-17-11
PAGE I
2- REC will be represented in this proceeding by Richardson Adams, PLLC.
All documents relating to these proceedings should be served on the following persons at
the addresses listed:
Gregory M. Adams (lSB No. 7454)
Richardson Adams, PLLC
515 N.27th Street, 83702
Boise, Idaho
Telephone : [phone]
Fax: [phone]
greg@richardsonadams. com
3. REC is a coalition of Idaho and northwest small hydro qualifying facility
("QF") power producers that have power purchase agreements ("PPAs") with Idaho
investor-owned utilities, or who may seek PPAs with Idaho utilities. REC was
established in2009, and is comprised of nearly forty members that are both small and
large QFs who own, operate or are developing approximately fifty renewable energy
generation facilities in Oregon, Idaho, Montana, Washington, Utah, and Wyoming.
Several types of entities are members of the REC, including irrigation districts, water
districts, corporations, and individuals. The majority of the individual QFs are small
hydroelectric projects less than 7 megawatts, but the membership includes biomass, solar,
geothermal, and waste energy. Most of the REC's members operate existing projects that
have been operating and selling to utilities for numerous years, but many of the members
are developing or planning to develop new projects. REC actively participates in
renewable energy legislation, PURPA related proceedings, IRP processes, and other
investigations in the Northwest regarding QFs.
REC PETITION TO TNTERVENE
IPC-E-17-11
PAGE 2
4. REC has a direct and substantial interest in this proceeding that will not be
adequately represented by any other party, and in any Commission determination made in
connection with these proceedings that could impact avoided cost rates or contract terms
and conditions available to REC members. REC intends to participate in all aspect of this
proceeding and will not unreasonably broaden the issues, burden the record, or delay this
proceeding.
5. There is good cause for REC's intervention out of time. The Notice of
Intervention Deadline Order No. 33827 in this docket set an intervention deadline of
August 21,2017. Although that date has passed, it does not appear that there is any
schedule has yet been set for comments or other procedures in this docket. Additionally,
REC's decision to intervene in this docket is the result of changed circumstances
occurring since the time of the intervention deadline. Specifically, August 23,2077,
Idaho Power Company moved to withdrawal its pleading that initiated the generic docket
(GNR-E-17-02) where tdaho Power proposed to alter the gas-price forecast used for
calculation of standard avoided cost rates. REC had intervened in that proceeding due to
the impact Idaho Power's proposal would have had on rates that would be available to
QFs, including REC's members. It now appears that the Commission will close that
generic docket, although the Commission has not yet issued an order doing so. Due to
the overlap between Idaho Power's proposal in GNR-E-17-02 and the occasional reliance
on the IRP for inputs to avoided cost rates, REC now has a substantial interest in
participating in this IRP proceeding to protect the same interests it intended to protect in
GNR-E-17-02.
REC PETITION TO INTERVENE
IPC-E-17-l l
PAGE 3
6. Therefore, as was the case in GNR-E-17-02, without the opportunity to
intervene herein, REC would be without a manner or means of participating in the lawful
determination of issues which may affect the avoided cost rates or contract terms and
conditions regarding PPAs for REC members. This proceeding could have a material
impact upon the prices REC's members receive for sales to ldaho utilities.
WHEREFORE, REC respectfully requests that the Commission grant its petition
to intervene with full party status in this proceeding and to appear and participate in all
matters as may be necessary and appropriate; and to present evidence, call and examine
witnesses, cross-examine witnesses, present argument, and to otherwise fully participate
in the proceedings.
Dated September 1fi ZOtl.
M. Adams (lSB No. 7454)
Adams, PLLC
515 N.27th Street
Boise,ID 83702
Telephone : 208.938.223 6
Fax: [phone]
greg@richardsonadams. com
REC PETITION TO INTERVENE
IPC-E-17-11
PAGE 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the lffi of Septemb er 2017,a true and correct copy of
the within and foregoing PETITION OF RENEWABLE ENERGY COALITION FOR
LEAVE TO INTERVENE OUT OF TIME in Case No. IPC-E-17-I I was served by
United States Mail, postage prepaid, and electronic mail to:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W est Washington Street
Boise,Idaho 83702
diane.holt@puc. idaho. gov
Timothy Tatum
Michael Youngblood
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
[e-mail]
myouneblood@ idahopower. com
Peter Richardson
lndustrial Customers of Idaho Power
PO Box 7218
Boise, Idaho 83702
pete@richardsonadams. com
C. Tom Arkoosh
IDAHYDRO
PO Box 2900
Boise, Idaho 83702
tom. arkoo sh@arkoosh. com
erin. cec il @arkoosh. cenq (email only)
Gloria D. Smith
Sierra Club
2101 Webster St, Suite 1399
Oakland, California 94612
gloria. smith@sierraclub. com
REC PETITION TO INTERVENE
IPC-E-17-11
PAGE 5
Lisa Nordstrom
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83702
lnordstrom@ idahopower. com
dockets@idahopower. com
Eric Olsen
Idaho Irrigation Pumpers Assn
PO Box 6119
Pocatello,Idaho 83205
[e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Don Reading
6070 Hill Road
Boise,Idaho 83702
dreadins@mindsprin g. com
Pete Bennett
Micron Technology, Inc
8000 South Federal Way
Boise, Idaho 83706
[e-mail]
Brad M. Purdy
STOP B2H
2019 N. lTth Street
Boise, Idaho 83702
[e-mail]
Thorvald A. Nelson
Emanuel T. Cocian
Kim Stanger
Holland & Hart, LLP
6380 South Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
tnel son@ ho ll andhart. co m
etcocian@hollandhart. com
[e-mail]
khall@hollandhart. com
REC PETITION TO INTERVENE
IPC-E-17-l I
PAGE 6
Gregory M. Adams