20170907Petition to Intervene.pdf

FISHER PUSCH LLP
John R. Hammond, Jr,
Via Hand Delivery
Diane Hanian
Secretary
Ioeuo Puet-rc Uulrtms CovvrssroN
4l2W.Washington St.
Boise,Idaho 83720
ATTORNEYS AND COUNSELORS AT LAW
September 1,2017
[e-mail]
Re
'Enclosed for filing in'the above matter, please find an original and eight (8) copies of
Petition to Intervene of the Snake River Allidnce and NW Energy Coalition. If you have any
questions, please do not hesitate to contact me. Kindly return a file stamped copy to me.
Sincerely,
FISHER PUS
R. Hammond, Jr
JRH/nj
Enclosures
cc: Client
IPC-E-17-13; In the'Matter of ldaho Power Company's Petition to Modify
Terms and Conditions of i'rospective PURPA Enerry Sales Agreements
T208.331.1000 'F 208.331 .2400 ' P.O. Box 1308 Boise,ld 83701 'Suile 701, US Bonk Plozo l0l S. CopitolBlvd. Boise,lD83702
I
John R. Hammond, Jr.- ISB No. 5470
Frsusn Puscu lt p
U.S. BANK PLAZA- 7th Floor
101 S. Capitol Blvd., Suite 701
P.O. Box 1308
Boise, ID 83701
Telephone: [phone]
Facsimile: 208.331.2400E-mail: [e-mail]
Attorneys for the Snake River Alliance and NW Energ,, Coalition
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO MODIFY
TERMS AND CONDITIONS OF
PROSPECTIVE PURPA ENBRGY
SALES AGREEMENTS
Case No.IPC-E-I7-13
' a nl! !rl. I -,i -J lt;i/-. lJ
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
PETITION TO INTERVENE OF THE
SNAKE RIVER ALLIANCE AND NW
ENERGY COALITION
.-.i \,-- I 1*, I l
)
)
)
)
)
)
)
COMES NOW the Snake River Alliance and the NW Energy Coalition (collectively the
"Interyenor") pursuant to the Idaho Public Utilities Commission's Rules of Procedure Rule 71,
IDAPA 31.01.01 .0J1, et seq., and petition the Commission to grant their petition to appear
collectively as an intervenor in the above-referenced case. The Intervenor asks leave to
intervene herein and to appear and participate as a party herein, and as basis therefor states as
follows:
1. The name and address of each Intervenor is as follows:
SNAKE RIVER ALLIANCE
223 N. 6th St., Ste. 317
PO Box 1731
Boise, ID 83701
Ph: [phone]
wwilson@snakeriveralliance. org
And
PETITION TO INTERVENE
ORIGINAL
I
NW Energy Coalition
I l0l 8rh Ave
Helena, MT 59601
Ph 406-461-6632
[e-mail]
The Intervenor will be jointly represented by
John R. Hammond Jr.
Fisher Pusch LLP
101 South Capitol Blvd., Suite 701
Boise, Idaho 83702
[e-mail]
[phone]
[phone]
To reduce costs and environmental impacts of exchanging information in this case, the
Intervenor requests that, pursuant to IPUC Rules, information other than that which might be
deemed confidential or otherwise must be delivered via mail be provided electronically and/or
via email to the Intervenor's and Mr. Hammond's respective email addresses above.
2. The Snake River Alliance (the "Alliance") is an Idaho-based non-profit organization,
established in 1979 to address Idahoans' concerns about nuclear waste and safety issues. In
2001, the Alliance expanded its mission and became Idaho's first nonprofit clean energy
advocacy organization. The Alliance's energy program includes advocacy 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 leading the
"Solarize the Valley" 2016 arrd2}ll community campaigns which to date have assisted 75
households to install net metering systems in the Idaho Power service area. The Alliance pursues
these programs on behalf of its members, most of whom are customers of Idaho Power and many
of whom are clean energy generators and net metering customers.
PETITION TO INTERVENE 2
3. The NW Energy Coalition ("NWEC") has more than 110 member organizations
throughout Washington, Oregon, Montana, and Idaho. NWEC claims an interest in this case on
behalf of its l1 organizational members in Idaho. NWEC promotes development of renewable
energy and energy conservation, consumer protection, low-income energy assistance, and fish
and wildlife restoration on the Columbia and Snake Rivers. NWEC has been aparty in cases
before the Idaho Utilities Commission and has been active in proceedings on net metering and
rate design issues in Idaho, Montana, Washington and Oregon.
4. The Alliance and NWEC have a direct and substantial interest in these proceedings as
the Company's request raises significant policy issues of interests, specifically with regard to
ensuring equitable rate design for net-metered customers. Further, these proceedings and
Commission final order will impact its members who are metering customers. The Alliance and
NWEC both have a history of participating before this Commission in cases relating to Idaho
Power's renewable energy programs and initiatives. The Alliance and NWEC believe their
participation as intervenors 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.
5. The Intervenor intends to participate herein as a party, and if necessary, to
introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
argument. The nature and quality of evidence which the Intervenor will introduce is dependent
upon the nature and effect of other evidence in this proceeding.
6. Without the opportunity to intervene herein, the Intervenor would be without a
manner or means of participating in the lawful determination of issues which may affect its
interests and the interests of the members of each organization.
JPET]TION TO INTERVENE
WHEREFORE, the Intervenor respectfully requests that this Commission grant its
Petition to Intervene in these proceedings and to appear and participate in all matters as may be
necessary and appropriate; and to present evidence, call and examine witnesses, present
argument and to otherwise fully participate in these proceedings.
DATED this 7 day of September 2017.
FISHER PUSCH LLP
Jr
for Intervenor
J
4PETITION TO INTERVENE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ,n" furof Septemb er,20l7,l served a true and
correct copy of the foregoing by delivering the same to each of the following individuals by
electronic mail, addressed as follows:
Lisa Nordstrom
Regulatory Dockets
Idaho Power Company
PO Box 70
Boise, lD 83707
lnordstrom@idahopower. com
dockets@idahopower. com
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
PO Box 70
Boise, ID 83707
ttatum@idahopower. com
caschenbrenner@idahopower. com
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472West Washington
Boise, lD 83702
diane.holt@puc. idaho. gov
Idahydro
clo C. Tom Arkoosh
Arkoosh Law Offices
PO Box 2900
Boise, ID 83701
[e-mail]
erin.cecil@arkoosh. com
Matthew A. Nykiel
Idaho Conservation League
PO Box 2308
102 S. Euclid#207
Sandpoint, ID 83864
mnykiel@idahoconservati on. org
tr U.S. Mail
E Facsimile
E Overnight Mail
n Hand Delivery
I Electronic Mail
tr U.S. Mail
E Facsimile
E Overnight Mail
n Hand Delivery
X Electronic Mail
tr U.S. Mail
E Facsimile
E Overnight Mail
I Hand Delivery
E Electronic Mail
n U.S. Mail
E Facsimile
E Overnight Mail
n Hand Delivery
E Electronic Mail
tr U.S. Mail
E Facsimile
n Overnight Mail
n Hand Delivery
E Electronic Mail
5PETITION TO INTERVENE
Idaho Irrigation Pumpers Association, Inc
cio Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Avenue, Ste. 100
PO Box 61 19
Pocatello, ID 83205
[e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]
Elias Bishop
Auric Solar, LLC
2310 s. 1300 w.
west valley city, uT 841l9
elias.bishop@auricsolar. com
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
Telephone: [phone]
Facsimile: [phone]
agermaine@cityofboise. org
tr U.S. Mail
fl Facsimile
E Overnight Mail
E Hand Delivery
I Electronic Mail
tr U.S. Mail
! Facsimile
n Overnight Mail
tr Hand Delivery
E Electronic Mail
n U.S. Mail
E Facsimile
E Overnight Mail
tr Hand Delivery
I Electronic Mail
tr U.S. Mail
E Facsimile
n Overnight Mail
! Hand Delivery
I Electronic Mail
John Jr
6PETITION TO INTERVENE