20190313Petition to Intervene.pdf

Benjamin l. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
[e-mail]
Attorney for the NW Energy Coalition
IN THE MATTER OF THE )
APPLICATION OF rDAHO POWER )
COMPANY TO STUDY THE COSTS, )
BENEFTIS, AND COMPENSATION OF )
NET EXCESS ENERGY SUPPLIED BY )
CUSTOMER ON-SITE GENERATION )
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CASE NO. IPC-E-I8-15
PETITION TO INTERVENE OF THE
NW ENERGY COALITION
/1i !!-lll
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW the NW Energy Coalition (NWEC) and hereby requests leave to intervene
in the above captioned matter pursuant to the Idaho Public Utilities Commission Rules of
Procedure, IDAPA 31.01.01.071-073. As discussed below, NWEC has direct and substantial
interests in these proceedings, and therefore should be granted intervention.
This Petition is filed well after the intervention deadline of November 30, 2018. NWEC is
aparty to docket IPC-E-18-16 regarding Idaho Power's fixed costs that is proceeding on a parallel
track and timeline. As these dockets have progressed, it has become apparent that some issues
and information overlap between the dockets. NWEC seeks late intervention here to avoid any
issues with confidential information that may overlap between the dockets. NWEC will abide by
the established schedule and process the parties have adopted in this docket. NWEC will not
broaden the issues, delay the proceeding, or otherwise prejudice any other interest in this docket.
1. The name of this intervenor is:
F. Diego Rivas
NW Energy Coalition
1101 8'h Ave
Helena, MT 59601
Ph: (406) 46r-6632
[e-mail]
This Intervenor will be represented in this matter by:
Benjamin I. Otto
NWEC PETITION TO INTERVENE I March 13,2019
Idaho Conservation League
710 N. 6'h st.
Boise,Idaho 83702
Ph: [phone] x12
Fax [phone]
botto@idahoconservatiou. org
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the name and address above. In the interest of
conserving natural resources and reducing the costs to all parties, please provide hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
2. NWEC claims a direct and substantial interest in this proceeding on behalf of our 11
organizational members in Idaho, many of whom have individual members that are customers of
Idaho Power. 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 on proceedings regarding distributed energy resources in Idaho,
Montana, Washington and Oregon. NWEC and our organizational members have a long-
standing interest in ensuring citizens have fair access to energy choices.
3. NWEC intends to fully participate in this matter as a party. The nature and quality of
NWEC's intervention in the proceeding is dependent upon the nature and effect of other
evidence in this proceeding. If necessary NWEC may introduce evidence, be heard in argument,
and call, examine, and cross-examine witnesses. NWEC intends to seek intervenor funding
pursuant to IDAPA 3 1.01.01. 161- 165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 13th day of March 2019.
submitted,
I.
NW Energy Coalition
NWEC PETITION TO INTERVENE 2 March 13,2019
CERTIFICATE OF SERVICE
I hereby certify that on this 13'h day of March,2Ol9,I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Hand delivery:
Diane Hanian
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
[e-mail]
ttatum@idahopower. com
caschenbrenner@idahopower. c om
[e-mail]
Idaho PUC Staff
Edward Jewel, Deputy Attorney General
Idaho Public Utilities Commission
Edward.Jewell@puc. idaho. gov
Idaho lrrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen PLLC
[e-mail]
Anthony Yankel
[e-mail]
Idahohydro
C Tom Arkoosh
Arkoosh Law Offices
[e-mail]
[e-mail]
Idaho Cle an Ener 9,, Association
Preston N. Carter
Givens Pursley LLC
[e-mail]
Sierra Club
Kelsey Jae Nunez, LLC
kelsey@kel geyj aenunez.com
City of Boise
Abigail R. Germaine, Deputy City Attorney
agermaine @c ity o fb o i s e. or g
Vote Solar
David Bender, Earthj ustice
dbender@earthj ustice.com
Briana Kober, Vote Solar
[e-mail]
NWEC
Diego Rivas, NW Energy Coalition
[e-mail]
-)
.''2/a -2 (----
Benjamin I. Otto
NWEC PETITION TO INTERVENE 3 March 73,2019
ZackWaterrnan, Idaho Sierra Club
zack.w aterman @ s i errac lub. o rg
[e-mail]