20200721Petition to Intervene.pdf

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Phone: [phone]
[e-mail]
Attorney for the Idaho Sierra Club

Lisa Young
Idaho Sierra Club
503 W. Franklin St.
Boise, ID 83702
Telephone: [phone]
[e-mail]

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO
POWER COMPANY’S
APPLICATION FOR AUTHORITY
TO MODIFY SCHEDULE 84’s
METERING REQUIREMENT AND
TO GRANDFATHER EXISTING
CUSTOMERS WITH TWO
METERS.

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CASE NO. IPC-E-20-26

IDAHO SIERRA CLUB
PETITION TO INTERVENE

Pursuant to IDAPA 31.01.01.042, 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
Lisa Young and Mike Heckler
503 W Franklin St
Boise, Idaho 83702
Ph: [phone]
[e-mail]
[e-mail]

IDAHO SIERRA CLUB PETITION TO INTERVENE 1
IPC-E-20-26
RECEIVED
2020 July 21, PM 4:25
IDAHO PUBLIC
UTILITIES COMMISSION
This Intervenor’s attorney is:

Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise, Idaho 83703
Ph: [phone]
[e-mail]

Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the names and addresses 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. 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.
For many years, the Sierra Club has advocated 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
IDAHO SIERRA CLUB PETITION TO INTERVENE 2
IPC-E-20-26
to reduce the impact of climate change and other air pollution by promoting clean energy
alternatives and energy efficiency.
Sierra Club was active as an intervenor in recent related dockets, including IPC-E-18-15,
IPC-E-18-16 and IPC-E-19-15, and has actively participated in ongoing workshops to address
matters affecting customer-owned generation systems connected to the grid and the recovery of
fixed and variable costs.
Our members have a direct and substantial interest in policy changes that may impact
Schedule 84 customers' ability to self-generate electricity, which is affected by this docket and
this docket’s inherent relationship to the IPC-E-19-15 proceeding. Examples of unresolved
matters which could potentially be affected by the IPC-E-20-26 docket include the
cost/requirements for metering and other generating system components, the maximum size of
Schedule 84 customer systems, and how the price provided for energy in excess of the
customer’s consumption and the time value of customer exports is reflected in demand charges.
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 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 dependent upon the nature and effect of other
evidence in this proceeding. If necessary Sierra Club may introduce evidence, be heard in
IDAHO SIERRA CLUB PETITION TO INTERVENE 3
IPC-E-20-26
argument, and call, examine, and cross-examine witnesses. Sierra Club intends to seek intervenor
funding pursuant to IDAPA 31.01.01.161-165.

WHEREFORE, Sierra Club respectfully requests the Commission grant this petition.
DATED this 21st day of July, 2020
Respectfully submitted,

______________________________
Kelsey Jae
Attorney for Sierra Club
IDAHO SIERRA CLUB PETITION TO INTERVENE 4
IPC-E-20-26
CERTIFICATE OF SERVICE

I hereby certify that on this 21st day of July, 2020, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:

Electronic Mail Delivery (See Order No. 34602)

Idaho Public Utilities Commission
Diane Hanian
Commission Secretary
[e-mail]

Idaho PUC Staff
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]

Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Idaho Irrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen PLLC
[e-mail]

Anthony Yankel
[e-mail]

Idaho Conservation League
Ben Otto
[e-mail]

_____________________________
Kelsey Jae
Attorney for Sierra Club

IDAHO SIERRA CLUB PETITION TO INTERVENE 5
IPC-E-20-26