20181130Petition to Intervene.pdf

John R. Hammond, Jr. - ISB No. 5470
FrsHrn Puscn I-l-p
U.S. BANK PLAZA- 7Ih Floor
l0l 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
IN THE MATTER OF'THE PETITION
OF IDAHO POWER COMPANY TO
STUDY THE COSTS, BENEFITS, AND
COMPENSATION OF NET EXCESS
ENERGY SUPPLIED BY CUSTOMER
ON-SITE GENERATION
RICfIVED
?Cifild0V 3S Pfl tr: 38
SSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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Case No. IPC-E-18-15
PETITION TO INTERVENE OF THE
SNAKE RIVER ALLIANCE
COMES NOW the Snake River Alliance (the "Intervenor") and pursuant to Rules 7l
through 73 of the Rules of Procedure of the Idaho Public Utility Commission (IDAPA 31.01.01
.71 -31.01.0.73) and, pursuant to that Petition filed on October 19,2018, and Notice of Petition
and Notice of Intervention Deadline, Order No. 34 I 89, filed on Novemb er 9, 2018, hereby
petitions the Commission for leave to intervene herein and to appear and participate as aparty,
and as basis therefore states as follows:
The name and address of each Intervenor is as follows:
SNAKE RIVER ALLIANCE
c/o Amy C. Hilton
223 N. 6th St., Ste. 317
PO Box 1731
Boise, ID 83701
Ph: [phone]
achi lton@snakeriveral liance. org
PETITION TO INTERVENE
The Intervenor will be represented by
John R. Hammond Jr.
Fisher Pusch LLP
101 South Capitol Blvd., Suite 701
Boise, Idaho 83702
[e-mail]
(208) 33r-r000
[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.
L The Intervenor is an Idaho-based non-profit organization,
established in l9l9 to address Idahoans' concems about nuclear waste and safety issues. In
2007, the Intervenor expanded its mission and became Idaho's first nonprofit clean energy
advocacy organization. The Intervenor'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 and2017 community campaigns which to date have
assisted 75 households to install net metering systems in the Idaho Power service area. The
Intervenor 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.
2. The Intervenor has 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
PETITION TO INTERVENE 2
Commission final order will impact its members who are metering customers. The Intervenor has
a history of participating before this Commission in cases relating to Idaho Power's renewable
energy programs and initiatives. In this case generally, the Intervenor will focus on issues,
including but not limited to, what is the fair value for the costs, benefits, and compensation
(credits) for net excess energy supplied by Idaho Power Company customers with on-site
generation to the utility. The Intervenor believes 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. Further, Intervenor participated as a party in Case No. IPC-E-17-13,\n the Matter
of the Application of Idaho Power Company for Authority to Establish New Schedules for
Residential and Small General Service Customer with On-Site Generation.
3. 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.
4. 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.
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.
JPETITION TO INTERVENE
DATED this of November 2018.2o(u,E-
FISHER PUSCH LLP
Hammond Jr
for Intervenor
4PETITION TO INTERVENE
I HEREBY CERTIFY that on the 30tl' day of November, 2018, I 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 83107
[e-mail]
dockets@idahopower. com
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
PO Box 70
Boise, lD 83707
ttatum@ idahopower. com
caschenbrenner@ idahopower. com
Commission Staff
Sean Costello
Idaho Public Utilities Commission
472 West Washington (83702)
Boise, lD 83720
[e-mail]. gov
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, lD 83702
[e-mail]. gov
Idahydro
clo C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Ste. LP 103
PO Box 2900
Boise, ID 83701
[e-mail]
[e-mail]
PETITION TO INTERVENE
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CERTIFICATE OF SERVICE
Benjamin J. Otto
Idaho Conservation League
710 North 611' Street
Boise, lD 83102
botto@ idahoconservation. org
Idaho Irrigation Pumpers Association, Inc
c/o Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Avenue, Ste. 100
PO Box 6119
Pocatello, ID 83205
elo(Dechohawk.com
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]
PacifiCorp d/b/a Rocky Mountain Power
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Ste. 320
Salt Lake City, UT 84116
yvonne.ho gle@pacifi corp. com
Ted Weston
Rocky Mountain Power
1407 West North Temple, Ste. 330
Salt Lake City, UT 84116
ted. we ston@paci fi c orp. c om
Briana Kobor
Vote Solar
358 South 700 East, Ste. B206
Salt Lake City, UT 84102
briana.votesolar.org
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6PETITION TO INTERVENE
David Bender
Earthjustice
3916 Nakoma Road
Madison, WI 8371I
dbende r@ earthj ust i c e. or g
Al Luna
Nick Thorpe
1625 Massachusetts Ave. NW
Ste. 702
Washington, D.C. 20036
aluna@earthj ustice. org
nthorpe@eartlt ustice. or g
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@cityofboi se. org
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John r,
7PETITION TO INTERVENE