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Home My WebLink About20191127Petition for Intervenor Funding.pdfIN THE MATTER OF THE PETITION OF IDAHO POWER COMPANY TO STUDY COSTS, BENEFITS, AND COMPENSATION OF NET EXCESS ENERGY SUPPLIED BY CUSTOMER ON-SITE GENERATION Il,rgo Cle,u ENERCY AssoctA'noN, INc.'s PETrrroN FoR INTERvENoR FT]NDING RECEIVED : i,{0Y 27 il'l l0: 50"1i Attorneys.for ldaho Clean Energt Associalion 'O iUELIC .;-c0Mh!lssl0N Idaho Clean Energy Association, Inc. ('ICEA"), by and through its attorneys ofrecord, Givens Pursley LLP, and pursuant to Idaho Code $ 6l-617.A and IDAPA 31.01.01.161 - 165, respectfully applies to the Idaho Public Utilities Commission ("Commission") for intervenor funding. Pursuant to Commission Rule 164, this application is timely, as it is made within fourteen days of the date of the last deadline for submitting briefs which was November 27, 2019.1 I Petitions for intervenor funding must be filed within fourteen days "after the last evidentiary hearing in a proceeding or the deadline for submitting briefs, proposed orde6, or statements ofposition, whichever is last." IDAPA 3 1.01.164. Technically, the Commission is holding a public hearing on December 3, and therefore the rules appear to allow petitions on or before December 17. ICEA files this petition well before the deadline out of an abundance ofcaution. ICEA's R-EerJEsT FoR INTERVENoR FUNDING - I ORIGINAL Preston N. Carter (lSB No. 8462) Givens Pursley LLP 601 W. Bannock St. Boise, ID 83702 Telephone: (208) 388-1200 Facsimile: (208) 388-1 300 prestoncarter@ givenspursley.com 14906410 2.docx U 1523-31 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION Case No. IPC-E-18-15 REQUEST FOR INTERVENOR FUNDING l. List of Expenses. As required by Commission Rule 162.01 , attached to the Affidavit of Preston N. Carter, and filed herewith, is an itemized list of expenses ICEA requests to recover. 2. Statement of Proposed Findings. ICEA actively participated in every settlement conference in this case. Without disclosing the contents of settlement discussions, which are confidential, ICEA's participation is reflected in the settlement agreement submitted to the Commission ior approval. As such, ICEA's proposed findings are included in the settlement agreement. In addition, ICEA has submitted briefing and factual material to the Commission on how to treat cusl.omers that participate in the Net Metering Program. In this briefing, ICEA proposed that the Commission find that customers under the Net Metering Program made different choices. and configured their systems differently, than customers that u'ill participate in the newly proposed Net Hourly Billing Program. ICEA also proposed that the Commission find that customers that participated in the Net Metering Program be allowed to continue under that program for twenty years, and other specifics regarding treatment of cuslomers under the Net Melering Program set forth in detail in ICEA's Brief Regarding Treatment of Existing Customers (filed November 13, 2019). 3. Statement Showing Reasonableness of Costs. See the accompanying Affidavits of Preston N. Carter and Kevin King. 4. Explanation of Cost Statement. See the Affidavit of Kevin King, which explains why the costs described constitute a significant financial hardship for the intervenor. ICEA's REQUEST FoR INTERVENoR FUNDING - 2 5. Statement of Difference. During settlement discussions (without disclosing confidential information), ICEA presented the perspective ofbusinesses involved in the renewable energy industry, a perspective unavailable to Staff. ICEA also brought to the table the perspective of customers that had purchased onsite generation systems, and those that would purchase onsite generation, and specifically how customers are likely to interpret, understand, and react to various components ofthe new Net Hourly Billing Program. ICEA also provided expertise in the existing and potential future technologies associated with onsite generation; the details of smart inverters; and practical challenges associated with installing and operating onsite generation systems. In the proceeding regarding existing customers, ICEA was able to present factual material and legal argument based on its members' firsthand experience interacting with customers that were considering onsite generation. ICEA fully recognizes. and appreciates, Staffs technical expertise and insight into various components ofonsite generation that ICEA lacks. ICEA submits that its on-the-ground interaction with customers, experience in installing and working under existing regulations, and experience with existing and future technologies results in different positions, and different information, than that taken and provided by Commission staff 6. Statement of Recommendation. Again without disclosing confidential information regarding positions taken during settlement, ICEA presented information and positions that assisted the parties in ensuring that the proposed settlement agreement reflected practical concems that would increase customer understanding ofthe terms contained in the agreement, and procedures that would reduce costs for potential future customers. ICEA's ICEA'S REQUEST ToR INTERvF]NOR FUNDINC - 3 briefing and factual information regarding existing customers addresses concems of existing customers, as well as potential future customers interested in onsite generation. 7. Statement Showing Class of Customers. Present and future net meter customers affected by the proceeding are currently members of Schedule 6 and 8. ICEA's participation in the settlement discussions also assisted in evaluating the benefits ofonsite generation provided to all classes of customers. ICEA would like to emphasize the expense ofparticipating in these proceedings. This was a complicated proceeding, involving no less than eight settlement conferences, many of which took all day. ICEA relies on volunteers, who volunteered their time to attend the conference. ICEA's attorney also reduced his rate and wrote offsignificant amounts of time to allow full participation in the case. Finally, this case was only one of./oar ongoing cases, three of which were instituted by Idaho Power, that touch on onsite generation. The requirement to participate in all four proceedings further strained ICEA's resources. This is further explained in the accompanying affidavits of Kevin King and Preston Carter. For these reasons, ICEA respectfully requests that the Commission grant its petition for intervenor funding in the amount of $22,776, as noted and explained in further detail in the accompanying affi davits. Dated: November 27, 2019. GIVENS PURSLEY LLP / - *-r Preston N. Carter Givens Pursley LLP Attorneys for ldaho Clean Energt Association ICEA's RTQUEST FoR INTERVI.NoR FUNDING - 4 CERTIFICATE OF SERVICE I certiff that on November 27, 2019, a true and correct copy ofthe foregoing comments were served upon all parties ofrecord in this proceeding via the manner indicated below: Commission Staff Diane Hanian, Commission Secretary ldaho Public Utilities Commission I l33l W. Chinden Blvd., Bldg. 8, Ste. 201 -A Boise. ID 83714 Diane.holt@nuc.idaho.sov Hand Delivera & Electronic Mail Edward Jewell, Deputy Attomey Ceneral ldaho Public Utilities Commission I 1331 W. Chinden Blvd., Bldg. 8, Ste. 201 -A Boise, lD 83714 Edward.Jewell@Duc.idaho.sov Electronic Mail Via Electronic Mail Lisa D. Nordsrom Regulatory Dockets Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, ID 83707 lnordstrom@idahopower.co!D dockets@idahopower.com Benjamin J. Otto ldaho Conversation League 710 North 66 Street Boise, Idaho 83702 idahocon n.or Timothy E. Tatum Connie Aschenbrenner Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, ID 83707 ttatum@idahopower.com caschenbrenn idahopower.com Idaho Irrigation Pumpers Association, Inc. c/o Eric L. Olsen Echo Hawk & Olsen, PLLC 505 Pershing Avenue, Suite 100 P.O. Box 61 19 Pocatello, Idaho 8305 elo@echohawk.com ldahydro c/o C. Tom Arkoosh Arkoosh Law Offices 802 W. Bannock Street, Suite LP 103 P.O. Box 2900 Boise, ID 83701 Tom.arkoosh@arkoosh. com Erin.cecil@arkoosh.com Idaho Irrigation Pumpers Association, Inc. c/o Anthony Yankel 12700 Lake Avenue, Unit 2505 Lakewood, Ohio 44107 tonv@yankel.net ICEA,S REQT]EsT ToR IN,I.ERVENOR FUNDINC - 5 ICEA,S REQUESl.IoR INTERVENOR FUNDINC - 6 Yvonne R. Hogle Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake City, UT 841 16 yvonne.ho gle@pacifi com.com David Bender Earthjustice 3916 Nakoma Road Madison, WI 537,l I dbender@earthi ustice.ore Nick Thorpe nthorpe@earthi ustice.org Idaho Sierra Club c/o Kelsey Jae Nunez Kelsey Jae Nunez LLC 920 N. Clover Drive Boise, ID 83703 kelsey@kelseyi aenunez.com F. Diego Rivas NW Energy Coalition 1101 8th Avenue Helena, MT 59601 diego@nwenergy.org Industrial Customers of Idaho Power c/o Peter J. Richardson Richardson, Adams, PLLC 515 N. 27s Street P.O. Box 7218 Boise. Idaho 83702 oeler@ri chardsonadams.com Ted Weston Rocky Mountain Power 1407 West North Temple, Suite 330 Salt Lake City, UT 84116 ted.weston@oacifi corp.com Briana Kober Vote Solar 358 S. 700 E., Suire 8206 Salt Lake City, UT 84102 briana@votesolar.org Al Luna Aluna@earthjustice.org Abigail R. Germaine Boise City Attomey's Office 105 N. Capitol Blvd. P.O. Box 500 Boise, ID 83701-0500 aeermaine@cityofboise.ore Zack Waterman Mike Heckler Idaho Sierra Club 503 W. Franklin Street Boise, ID 83702 zack.waterman@sierraclub.org Michael.p.heckler@gmail.com NW Energy Coalition c/o Benjamin J. Otto Idaho Conservation League 710 N. 6th Street Boise, ID 83702 botto@idahoconservation. org Micron Technology, Inc. c/o Austin Rueschhoff Thorvald A. Nelson Holland & Hart, LLP 555 Seventeenth Street, Suite 3200 Denver, CO 80202 darueschho ff@hollandhart. com tnelson@hollandhart.com Jim Swier Micron Technology, Inc. 8000 S. Federal Way Boise, ID 83707 iswier@micron.com Industrial Customers of Idaho Power Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 dreadin g@mindsprine.com Russell Schiermeier 29393 Davis Road Bruneau, Idaho 83604 buvhav@gmail.com /-5--< Preston N. Carter ICEA's RreuEsr FoR IN'n-.RVr.NoR FUNDINC - 7