20150220Petition to Intervene.pdf

i; 1:: i-: i:r i "
ffBriltl'?* ?',15 rr* 20 $'i{ l1: 3h
EnergyAssociate ii;,i- ,..,r.IdahoConservationleague ..J.'li_i'i"l :.1 r-,,,'',i.i:r'':r\'r:
PO Box 844, Boise,ID 83701
Email : [e-mail]
P: 208-345-6933 x 12
Matt Vespa
CA Bar #222265 (Pro Hac Vice pending)
Siena Club
85 Second St.,2nd Fl.
San Francisco, CA 94105
Email : [e-mail]
P:415-977-5753
F:415-977-5793
Attorneysfor ldaho Consertation League and Sierra Club
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-15-01
COMPANTY'S PETITION TO MODIFY )
TERMS AND CONDITTONS OF ) PETITION OF STERRA CLUB TO
PROSPECTIVE PURPA ENERGY SALES ) INTERVENE AND JOIN PARTIESAGREEMET{TS ) WITH IDATIO CONSERVATION
) LEAGUE
)
Pursuant to IDAPA 3 I .0 I .01 .042, Sierra Club hereby submits this petition to intervene
and to join parties with Idaho Conservation League (*ICL') in the above captioned matter. On
February 4,2OI5,ICL requested leave to intervene in the above captioned matter pursuant to the
Idaho Public Utilities Commission Rules of Procedure, IDAPA 31.01.01 .O7l-O73.On February
6,2015, in the Commission's Notice of Petition and Notice of Intervention Deadline, OrderNo.
33222, the Commission gmnted ICL's intervention. Sierra Club and ICL share many strategic
goals and interests and believe it would be most effrcient for all parties and the Commission, for
Sierra Club to appear and join parties with ICL.
PETITION OF SIERRA CLUB TO INTERVENE AND JOIN PARTIES WITH ICL .1
Sierra Club is a national, non-profit environmental and conservation organization
incorporated under the laws of the State of California. The Sierra Club is dedicated to the
protection of public health and the environment. Siena Club submits this notice to appear
and join parties with ICL on behalf of itself and nearly 2,400 Sierra Club members who
live and purchase utility services in Idaho, many of whom are residential customers of
Idaho Power. The name and address of Sierra Club is:
Sierra Club
85 Second Street. 2nd Floor
San Francisco, CA 94105
Sierra Club's Idaho members have a direct and substantial interest in this proceeding.
Idaho Power's January 30, 2015 Application with the Commission seeks to drastically
alter terms and conditions of prospective PURPA energy sales agreements by reducing
conffact length from twenty to two years. Such a change would have a detrimental
impact to additional solar deployment in Idaho and limit the environmental, health and
economic benefits of decarbonization of the energy system. This proceeding therefore
has environment, health and economic consequences for Sierra Club members who are
customers of ldaho Power. These Sierra Club members have a right to participate in this
proceeding to inform the Commission of their interests, both environmental and
economic, that relate to the impacts of modifring prospective PURPA energy sales
agreements.
Siena Club's Beyond Coal campaign seeks rapid replacement of fossil-fueled generating
units with cleaner forms of energy to eliminate or reduce global climate change
emissions, reduce utility bills, and generate renewable energy. Sierra Club's work
includes advocating for the implementation of robust incentive programs that assist its
members and utilily consumers generally to generate their own renewable energy and
increase energy efficiency. The Siena Club's work includes intervening in dockets at
public utility commissions nationwide, submitting comments in numerous state and
federal agency energy-related proceedings and rulemakings, 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.
1.
2.
J.
PETITION OF SIERRA CLUB TO INTERVENE AND JOIN PARTIES WITH TCL .2
Sierra Club members have worked tirelessly to promote clean energy altematives and
energy efficiency measures.
Sierra Club has a specific interest in this docket because its members who live within
Idaho Power's service territory are ratepayers and have a pecuniary and tangible interest
in the outcome of the proceeding. Sierra Club members have a direct interest in ensuring
fair, accurate rates and charges for clean energy sources in order to foster clean energy
development in Idaho Power's serice territory. Siena Club is concemed that the
proposed change is needlessly draconian and fails to consider solutions that will allow
continued growth of solar in Idaho.
Sierra Club and ICL were both recently parties in IPC-E-I4-18, In the Matter of Idaho
Power Company's Application to Implement Solar Integration Rates and Charges, which
ultimately resulted in a settlement. In assessing this proceeding, Sierra Club and ICL
determined that joint participation would be more effrcienl
By joining parties with ICL, Sierra Club 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 with ICL in this proceeding will not be duplicative of other
parties in this proceeding because no other party adequately represents Sierra Club's
interests. In fact, joining with ICL is intended to avoid what otherwise would be
duplication of efforts.
Sierra Club and ICL request that all future pleadings, correspondence, discovery, and
other documents be served on the following:
Matt Vespa
CA Bar #222265 (Pro Hac Yice pending)
Sierra Club
85 Second St., 2nd Fl.
San Francisco, CA 94105
Email: [e-mail]
P:415-977-5753
F:415-977-5793
Benjamin J. Otto
ID Bar #8292
Energy Associate
Idaho Conservation League
Post Office Box 844
Boise,Idaho 83701
Email: botto@ idahoconservation.ors
P: 208-345-6933 x12
4.
5.
7.
ilt
ilt
t/t
PETITION OF SIERRA CLUB TO INTERVENE AND JOIN PARTIES WITH ICL .3
WHEREFORE, Sicrra Club respocffirlly rcqucse thnt &c Commtssion issE an ordcr
grandng Siem Club'c pcnnission to interuene in &is mattcr and to join partios with ICL.
Datcd this Zfl day of Fcbruary, 2015
ID Bar#8292
Energy Associate
Idaho Cpnscwation Leaguc
Post Officc Box 844
Boisq ldaho 83701
Email : bottot0idahoconservation.orq
P:20&345{933 x 12
CABsr#?22265 (Pro Hac Wce pendtng)
SienaClub
.85 Second St., 2nd Fl.
San Francisco, CA 91105
Email: [e-mail]+
P:415-9Tl-5753
F:415-977-5793
Attorneysfor ldaho Consentation League and Ste'ra Club
PETITTON OF SIERRA CLI.IB TO INTERVENE AND JOIN PARTIES WITH ICj- 4
CERTTFICATE OF SERVICE
I hereby certiff that on this 20th day of February, 2015, I caused to be served, via e-mail,
a true and correct copy of the foregoing PETITION TO INTERVENE to the following persons
via the method of service noted:
Hand Delivery:
Jean Jewell
Commission Secretary
(Original and seven copies provided)
Idaho Public Utilities Commission
42TW.Washington St.
Boise, ID 83702-5983
Electronic Mail:
Idaho Power J.R. Simplot Corp & Cleanvater Paper
Donovan E. Walker Peter J. Richardson
Regulatory Dockets Gregory M. Adams
Idaho Power Company Richardson Adams, PLLC
1221 West ldaho Street 515 N.27rh Sheet
P.O. Box 70 Boise,ID 83702
Boise,ID 83707 [e-mail]@idahopower.com [e-mail]
[e-mail]
Dr. Don ReadingAvista 6070 Hill Road
Michael G. Andrea, Senior Counsel Boise,ID 83703
Clint Kalich [e-mail]
Avista Corporation
1411 E. Mission Ave, MSC-23 Carol Haugen, Clearwater Paper
Spokane, WA99202 [e-mail]
[e-mail]@avistacorp.com Twin Falls Canal, Northside Canal,
American Falls Reservoir Distict No 2.
Roclcy Mountain Power C. Tom Arkoosh
Daniel Solander Arkoosh Law Offices
Ted Weston 802 W. Bannock St Ste. 900
Rocky Mountain Power P.O. Box 2900
201 S. Main Sfteet, Ste 2400 Boise,ID 83701
Salt Lake City, UT 8411I [e-mail]@pacificorp.com [e-mail]
[e-mail]
[e-mail]
PETITION OF SIERRA CLUB TO INTERVENE AND JOIN PARTIES WITH ICL -5
Intermountain Energt Partners
Dean J. Miller
McDevitt& MillerLLP
420W. Bannock Street
PO Box 2564-83701
Boise,ID 83702
j oe@mcdevitt-miller. com
LeifElgethun" PE, LLE AP
Intermountain Energy Partners
PO Box 7354
Boise,ID 83707
[e-mail]
Idaho lrrigation Pumpers Association
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey,
Chartered
P.O. Box 1391
201E. Center
Pocatello,ID 83204
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
[e-mail]
Idaho Conservation League & Sierra Club
Benjamin J. Otto
Idaho Conservation League
710 N.6th st.
Boise, Idaho 83702
botto@idahoconservation org
Matt Vespa
Siena Club
85 Second St.,2nd Fl.
San Francisco, CA 94105
matt. vespa@sierraclub. org
SnakB River Alliance
Kelsey Jae Nunez
Ken Miller
Snake River Alliance
223 N.6h St., Ste.3l7
PO Box l73l
Boise,lD 83701
knunez@snakeriverall iance.org
kmil ler@snakeriveralliance. org
(sender of service docs)
PETITION OF SIERRA CLT.JB TO INTERVENE AI{D JOIN PARTIES WITH ICL .6