20181123Petition to Intervene.pdf

Yvonne R. Hogle, ISB #8930
Rocky Mountain Power
1407 West North Temple, Suite 320
Telephone No. [phone]
vvo nne. h o s le (d.o acifrc orc. c o m
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY TO STUDY THE COSTS,
BENEFITS, AND COMPENSATION
OF NET EXCESS ENERGY SUPPLIEI)
BY CUSTOMER ON.SITE
GENERATION
ITECEIVED
20101{0V 23 PH p: r+T
CASE NO.IPC-E-18-15
PETITION OF ROCKY MOUNTAIN
POWER FOR LEAVE TO
INTERVENE
0qeLlIt
Attorney.for Roclry Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW, PacifiCorp, dba Rocky Mountain Power, and pursuant to Rules 7l
through 73 of the Rules of Procedure of the Idaho Public Utilities Commission (the
"Commission"), hereby petitions the Commission for leave to intervene and participate as
a party in the matter captioned above.
The grounds for the petition are as follows:
l. Rocky Mountain Power is a division of PacifiCorp. PacifiCorp is an Oregon
corporation that provides electric service to retail customers through its Rocky Mountain
Power division in the states of Idaho, Utah, and Wyoming, and through its Pacific Power
division in the states of California, Oregon, and Washington.
2. Rocky Mountain Power is authorized to do business in the state of Idaho as
a public utility providing retail electric service to approximately 77,000 customers. Rocky
Mountain Power is a public utility subject to the jurisdiction of the Commission pursuant
to Idaho Code $ 61-129.
I
3. Rocky Mountain Power and its customers have significant interest in the
above-captioned matter and their interests may be substantially affected by the outcome of
this proceeding through the potential establishment of new policies. Without the
opportunity to intervene herein, Rocky Mountain Power would be excluded from
participating in the lawful determination of the costs, benefits, and compensation of net
excess energy supplied by customer on-site generation and related issues that could set a
precedent for its own treatment of these and related issues. In addition, Rocky Mountain
Power could also provide information that would aid the Commission in evaluation of the
evidence in this proceeding.
4. Rocky Mountain Power's intervention and participation in this matter will
not materially impair the prompt and orderly conduct of this proceeding. If intervention is
authorized Rocky Mountain Power would not seek access to any confidential material
Idaho Power may deem proprietary. Rocky Mountain Power requests that copies of all
notices and filings in this docket be served on:
Ted Weston
Rocky Mountain Power
1407 WestNorth Temple, Suite 330
Salt Lake City, Utah 841l6
E-mail : ted.weston@oacifi corp.com
Yvonne R. Hogle
Rocky Mountain Power
1407 WestNorth Temple, Suite 320
Salt Lake city, utah 84116
E-mail: [e-mail]
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
approve Rocky Mountain Power's leave to intervene in this proceeding and to appear and
participate in all matters as may be necessary and appropriate; and to present evidence, call
2
and examine witnesseso present argument, and otherwise fully participate in the above-
captioned docket to the full extent allowed by law.
Dated this 23'd day of November 2018.
Respectfully submitted,
ROCKY MOUNTAIN POWER
R. Hogle
for Roclqt Mountain Power
J
CERTIFICATE OF SERVICE
I hereby certify that on this 23'd of November,2018, I caused to be served, via e-mail, a
true and correct copy of the foregoing document in IPC-E-18-15 to the following:
Lisa D. Nordstrom
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,ID 83707
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise,Idaho 83702
botto@ idahoconservation.org
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
E-mail: [e-mail]
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise,lD 83707
ttatum@ idahopower.com
Eric L Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Suite 100
P.O. Box 6l 19
Pocatello, Idaho 83205
[e-mail]
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 841l6
E-mail: [e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah Street, Suite 2000
Portland, Oregon 97232
datarequest@pac ifi corp.com
Ve,
Katie Savarin
Coordinator, Regulatory Operations