20200914Petition to Intervene.pdf

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Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise,ID 83703
Phone: [phone]
kelsey@kel seyj aenune z.com
Attorneyfor the ldaho Sierra Club
Lisa Young
Idaho Sierra Club
503 W. Franklin St.
Boise,lD 83702
Telephone: Q08) 384-1023
[e-mail]
IN THE MATTER OF IDAHO
POWER COMPAITY'S
APPLICATION FOR AUTHORITY
TO ESTABLISH TARIFF 68,
INTERCONNECTIONS TO
CUSTOMER DISTRIBUTED
ENERGY RESOURCES
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.2O-30
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.
l. The name of this intervenor is:
Idaho Siena CIub
Lisa Young and Mike Heckler
503 W Franklin St
Boise,Idaho 83702
Ph: [phone]
I i sa. vouns @.sierrac I u b. orp
michae [e-mail]
IDAHO SIERRA CLUB PETITION TO INTERVENE
IPC-E-20-30
I
This Intervenor's attorney is:
Kelsey Jae (ISB No. 7899)
Law for Conscious Leadership
920 N. Clover Dr.
Boise, tdaho 83703
Ph: [phone]
kelsey@kel seyj aenunez. com
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 ldaho, 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, submifiing 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
rPC-E-20-30
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to reduce the impact of climate change and other air pollution by promoting clean energy
alternatives and energy efficiency.
Sierra Club has actively participated in a series of dockets related to the rights of
customers to self-generate some or all of their electricity needs and related system impact and
valuation issues. As intervenors in IPC-E-17-l3,IPC-E-18-15, IPC-E-18-l6,IPC-E-19-15, and
IPC-B 20-26, we view the matters raised by ldaho Power for consideration under IPC-E-20-30 as
the latest in a long series of related dockets in which we have actively participated. Our members
have a direct and substantial interest in policy changes that may impact Schedule 84 customers'
ability to self-generate electricity, how those customers interconnect to the grid or choose not to
export, whether they use storage technologies, and what the best altematives are for providing
and valuing the power quality/voltage support opportunities that inverter technology provides.
Each of those matters could be affected by the IPC-E-20-30 docket.
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
argument, and call, examine, and cross-examine witnesses. Sierra Club intends to seek intervenor
funding pursuant to IDAPA 3 1.01.01. I 6 l -165.
IDAHO SIERRA CLUB PETITION TO INTERVENE
rPC-E-20-30
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WHEREFORE, Sierra Club respectfully requests the Commission grant this petition.
DATED this 14th day of September 2020.
Respectfully submitted,
rs\e
Kelsey Jae
Attorney for Sierra Club
IDAHO SIERRA CLUB PETITION TO INTERVENE
rPC-E-20-30
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CERTIFICATE OF SERYICE
I hereby certi$ that on this l4th day of September 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
Jan Noriyuki
Commission Secretary
secr etary @puc. idaho. gov
Idaho PUC Staff
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
edward j ewell @puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Idaho Conservation League
Ben Otto
[e-mail]
r$\k
Kelsey Jae
Attorney for Sierra Club
IDAHO SIERRA CLUB PETITION TO INTERVENE
rPC-E-20-30
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