20130805Petition to Intervene.pdf

Thomas H. Nelson, Attomey at Law
PO Box 1211
Welches, OR 97067
Phone: [phone]Fax [phone]
Email: [e-mail]; [e-mail]
Attorney for Renewable Energy Coalition
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Renewable Energy Coalition's
Petition to lntervene
Nancy Esteb, Ph.D.
PO Box 490
Carlsborg, WA 98324
Email : betseesteb@qwest. net
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA I CASE NO. PAC.E-13-05
ROC}fi MOUNTAIN POWER'S 2013
I NTEGRATED RESOURCE PLAN
Pursuant to the ldaho Public Utilities Commission Rules of Procedure, IDAPA
31.01.01.071-073, Renewable Energy Coalition ("Coalition"), a coalition of renewable
energy projec{ owners and developers, hereby petitions the ldaho Public Utilities
Commission ("Commission") to intervene as a party in this proceeding. ln support of this
petition, Renewable Energy Coalition represents as follows:
1. The business address of Renewable Energy Coalition is:
John Lowe, Director
Renewable Energy Coalition
12O5O SW Tremont St.
Portland, OR 97225
Phone: [phone]Fax [phone]
Email: [e-mail]
2. The Coalition will be represented in this proceeding by:
Thomas H. Nelson, Attomey at Law
PO Box 1211
Welches, OR 97067
Emai I : [e-mail]
3. Please provide copies of all pleadings, production requests, production
responses, Commission orders, and other documents to the three names and
Page 1 * Case No. PAC-E-13-05: Renewable Energy Coalition's Petition to lntervene
addresses above. ln accprdance with IPUC Rule 31.01.01.063, electronic copies only
are requested; hard copies need not be provided of any documents filed in this docket.
4. The Coalition daims a direct and substantial interest in this proceeding
arising from the impact to its present and future members served by Rocky Mountain
Power, and the Coalition thus has a direct and substantial interest in ensuring that the
lntegrated Resource Plan contains an accurate and thorough analysis of Rocky
Mountain Powe/s future resource needs. The Coalition's intervention will not unduly
broaden the issues in this proceeding.
5. The Coalition intends to fully participate in this matter as a party. The
nature and quality of the Coalition's intervention in the proceeding is dependent upon
the nature and effect of other evidence in this proceeding. lf necessary the Coalition
may advocate for a technical hearing and introduce eMdence, be heard in argument,
and call, examine, and cross-examine witnesses.
WHEREFORE, Renewable Energy Coalition respectfully requests that the
Commission grant its petition to intervene as a party in this proceeding.
Dated this 1"t day of August, 2013.
Respectfully submitted,
rlw+na* H. Ne{r,o*,
THOMAS H. NELSON
Attomey for Renewable Energy Coalition
Page2 - Case No. PAC-E-13-05: Renewable Energy Coalition's Petition to lntervene
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this'tst day of August, 2013, I caused to be served
a true and conect copy of the foregoing document to each of the following via the
method so indicated:
Jean D. Jewell, Secretary (original and 7)
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 8372UAO74
jjewell@puc. state. id.us
Ted Weston
Daniel E. Solander
Mark C. Moench
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 8411 I
ted.weston@ pacificorp. com
Da niel. solander@ pacifi corp. com
Mark. moen ch@ pacifi corp. co m
Benjamin J. Otto
ldaho Conservation League
710 N. 6th Street
Boise, lD 83702
botto@idahocon servati on. org
Ken Miller
Clean Energy Program Director
Snake RiverAlliance
Box 173
Boise, lD 83701
k mi I ler@ sn akeriveral li ance. o rg
Mail and Electronic Mail
Electronic Mail
Electronic Mail
Electronic Mail
Page 3 - Case No. PAC-E-13-05: Renewable Energy Coalition's Petition to lntervene