20170828Petition to Intervene.pdf

IDAHO
CONSERVATION
LEAGUE
I
208.265.9565 . PO Box 2308, Sandpoint, lD 83864 . www.idahoconservation,org
ldaho Public Utilities Commission
472 W. Washington Street
Boise, lD 83702
August 21,2017
RE: ldaho Power New Schedules For Customers With On-Site
Generation
Dear Commissioners:
Enclosed is the original and seven copies of ldaho Conservation League's Petition to
lntervene regarding ldaho Power's proposed new schedules fro customer with on-site
teneration, case number IPC-E- !7- 13. Our Certificate of Service is enclosed as well.
lf there are any questions regarding the enclosed documents, please contact Matt Nykiel
at [phone] or via email at [e-mail].
Sincerely,
_il.k(,(
Matthew Nykiel
Conservation Associate
Matthew A. Nykiel (lSB No. 10270)
P.O. Box 2308
102 S. Euclid #207
Sandpoint, ID 83864
Ph: (208) 265-956s
Fax: [phone]
mnykiel@ idahoconservation.org
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-I7-13
PETITION TO INTERVENE OF
IDAHO CONSERVATION LEAGUE
The Idaho Conservation League ("ICL") petitions the Commission to intervene in this matter on
behalf of itself and its members who are customers of Idaho Power Company ("ldaho Power") pursuant to
the ldaho Public Utilities Commission Rules of Procedure,IDAPA 31.01.01.071-073. As discussed below,
ICL has direct and substantial interests in these proceedings, and therefore should be granted intervention.
l. The name of this intervenor is:
Matthew A. Nykiel
Idaho Conservation League
P.O. Box 2308
102 S. Euclid #207
Sandpoint, ID 83864
Ph: (208) 26s-956s
Fax: [phone]
[e-mail]
In the interest ofconserving natural resources and reducing the costs to all parties, please provide
hard copies of pleadings, testimony, and briefs only to the name and address above. Production requests,
responses, notices, Commission orders, and other filings may be submitted via electronic mail in
accordance with IDAPA 3 I .01 .01 .063 .02-03.
ICL's direct and substantial interest in this proceeding arises from the impact to our members
served by Idaho Power and our long-term role advocating for public values. As ldaho's largest
state-based conservation organization, ICL represents 25,000 supporters, many ofwhom are
residential customers of Idaho Power, as well as participate in net metering. ICL, as an entity, is a
small commercial customer of ldaho Power and participates in Idaho Power's net metering
program by generating electricity from solar panels installed on our Boise office roof. In addition,
ICL and our supporters have an interest in responsibly expanding renewable energy in ldaho,
2
ICL,s PETITION TO INTERVENE August 21,2017I
, .lt I
while ensuring Idaho Power's electric system provides reliable, fair-priced service. ICL brings a
unique and valuable perspective to this proceeding because our members are customers of Idaho
Power who support renewable energy. ICL's intervention will represent our supporters' interest in
fair rates that promote and encourage renewable energy. ICL's intervention will not unduly
broaden the issues in this proceeding.
3. ICL intends to fully participate in this matter as a party. The nature and quality of ICL's
intervention in the proceeding is dependent on the nature and effect of other evidence in this
proceeding. ICL has not fully determined the specific positions it will take or the relief it will
seek. ICL seeks to intervene for purposes of protecting its interests as they arise. ICL may seek
intervenor funding pursuant to IDAPA 3 1 .0 1 .0 I . 1 6 I - I 65.
WHEREFORE, ICL respectfully requests the Commission grant this petition
DATED this 2l't day of August 2017
Respectfu lly submitted,
A.
Idaho Conservation League
2ICL,s PETITION TO INTERVENE August 21,2017
CERTIFICATE OF SERVICE
I hereby certify that on this 2l't day ofAugust,2OlT, I delivered true and correct copies ofthe
foregoing PETITION TO INTERVENE OF IDAHO CONSERVATION LEAGUE to the following person
via the method of service noted:
FedEx:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise,ID 83702
diane.holt@puc. idaho. gov
(Original and seven copies provided)
Electronic Mail:
Lisa D. Nordstrom
Idaho Power Company
l22l West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
l22l West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
ttatum@ idahopower. com
[e-mail]
Idahydro
c/o C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
P.O. Box 2900
Boise,ID 83701
[e-mail]
[e-mail]
Matthew A. N
JICL,s PETITION TO TNTERVENE August 21,2017