20181130Petition to Intervene.pdf

Kelsey Jae Nunez (ISB No. 7899)
KELSEY JAE NUNEZLLC
920 N. Clover Dr.
Boise, ID 83703
Phone: [phone]
kelsey@kelseyj aenun ezsom
Attorneyfor the Idaho Sieta Club
Zack Waterman
IDAHO SIERRA CLUB
503 W Franklin St
Boise, ID 83702
Telephone: [phone]
zack. waterman@ s ierraclub. org
IN THE MATTER OF THE )
APPLTCATTON OF rDAHO POWER )
COMPANY TO STUDY THE COSTS, )
BENEFITS, AND COMPENSATION )
oF NET EXCESS ENERGY )
SUPPLIED BY CUSTOMER ONSITE )
GENERATION
RHCEIVED
M$ t{0Y 30 frH il: Z l
,l-J /1r tl-'l,rr,^r^rnrr, i{, l\,iiiv'll
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E.18.15
PETITION TO INTERVENE
OF THE IDAHO SIERRA CLUB
Pursuant to IDAPA 3 1.01.01 .042, the Idaho Sierra Club ("Sierra Club") hereby submits
this petition to intervene in the above captioned matter. As discussed below, Sierra Club has
direct and substantial interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Idaho Sierra Club
ZackWaterman
Mike Heckler
503 W Franklin St
Boise, Idaho 83702
Ph: [phone]
zack. waterman@ sierraclub. org
michael.p.heckler@gmail. com
Sierra Club - Petition To Intervene - IPC-E- I 8- l5 - I
This Intervenor will be represented by:
Kelsey Jae Nunez, ISB No. 7899
Kelsey Jae Nunez LLC
920 N Clover Dr
Boise, Idaho 83703
Ph: (208) 391-296r
kelsey@kelseyj aenun ez.com
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the names and addresses above. Production
requests, responses, notices, Commission orders, and other filings via electronic mail are
preferred and allowed in accordance with IPUC Rules 31.01.01 .063,02-03.
2. Sierra Club is a national, non-profit environmental and conservation organization
incorporated under the laws of the State of California, duly qualified to do business in the State
of Idaho. Sierra Club has 3,600 members who live and purchase utility services in Idaho, and
many of those Sierra Club members are customers of Idaho Power Company.
3. Sierra Club's Idaho members have a direct and substantial interest in this proceeding
Sierra Club's work includes advocating for the implementation of programs that assist its
members and utility consumers generally to access renewable energy and increase energy
efficiency. The Sierra Club's work includes intervening in dockets at public utility commissions
nationwide, submitting comments in numerous state and federal agency energy-related
proceedings and rule-makings, attending and speaking at public hearings, speaking to students
and civic and other organizations, and holding seminars and symposia - all in support of policies
to reduce the impact of climate change and other air pollution by promoting clean energy
alternatives and energy efficiency. Sierra Club members have worked tirelessly to promote clean
energy alternatives and energy efficiency measures in Idaho.
Sierra Club - Petition To Intervene - IPC-E-18-15 - 2
4. Sierra Club's participation as an intervenor in this proceeding will not unduly broaden
the issues or delay the proceeding because Sierra Club's interest is directly related to the subjects
addressed in Idaho Power's application. Sierra Club's intervention will focus on the fair
valuation of costs, benefits, and compensation of net excess energy supplied by customer onsite
generation. Sierra Club's involvement in this proceeding will not be duplicative of other parties
in this proceeding because no other party adequately represents Sierra Club's interests.
5. Sierra Club intends to fully participate in this matter as a party. The nature and quality
of Sierra Club's intervention in the proceeding is dependant upon the nature and effect of other
evidence in this proceeding. If necessary Sierra Club, may introduce evidence, be heard in
argument, and call, examine, and cross-examine witnesses. Sierra Club intends to seek intervenor
tunding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, Sierra Club respectfully requests the Commission grant this petition.
DAIED this 30th day of November 2018.
Respectfully submitted,
"tr "wNtutx*W*"t"iJ
Kelsey Jae Nunez
Attorney for Sierra Club
Sierra Club - Petition To Intervene - IPC-E-18-15 - 3
CERTIFICATE OF SERVICE
On this 30th day of Novembeq 2018, I delivered true and correct copies of the foregoing
PETITION TO INTERVENE to the following persons via the method of service noted:
Hand deliverv:
Jean Jewell, 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
lnordstrom@idahopower. com
ttatum@idahopower. com
c as ch e nbre nner @idahop ower. c om
dockets@idahopower. com
Idaho PUC Staff
Sean Costello, Deputy Attorney General
sean. costello@puc. idaho. gov
Idahohydro
C. Tom Arkoosh
Arkoosh Law Offices
tom. arkoosh@arkoosh. com
erin. cecil@arkoosh. com
Idaho lrrigation Pumpers Associatton
Eric L. Olsen
Echo Hawk & Olsen PLLC
[e-mail]
Anthony Yankel
[e-mail]
Idaho Clean Energlt Association
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
[e-mail]
den@givenspursley. com
Idaho Cons ervation League
Benjamin J. Otto
botto@idahoconservation. org
Vote Solar
David Bender
Earthjustice
dbender@earthjustice. com
Briana Kober
Vote Solar
[e-mail]
Boise City Attorney's Office
Abigail R. Germaine
Deputy City Attorney
[e-mail]
Roclqt Mountain Power
Ted Weston
ted.weston@pacifi corp. com
Yvonne R. Hogle
Rocky Mountain Power
yvonne. ho g le @p ac ifrcorp. c om
Y"rluu. fu Nd;ykfi',J
Kelsey Jae Nunez
Attorney for Sierra Club
Sierra Club - Petition To Intervene - IPC-E-18-15 - 4