HomeMy WebLinkAbout20190808Petition to Intervene.pdfPreston N. Carter (ISB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise,ID 83702
Telephone: (208) 388-1200
Facsimile: (208) 388-1300
prestoncarter@ givenspursley. com
1476477 5 _l.docx I I 523-l ]
Attorneys for ldaho Clean Energt Association
IN THE MATTER OF ROCKY
MOUNTAIN POWER TO CLOSE THE
NET METERING PROGRAM TO NEW
SERVICE & IMPLEMENT A NET
BILLING PROGRAM TO
COMPENSATE CUSTOMER
GENERATORS FOR EXPORTED
GENERATION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. PAC-E-19-fB og
REOEIVED
tillg AUG -8 PH Z: 37
lili:'iiri FiJIiLICrl {l I llk;t COlv{MISSION
ORIGINAL
IoaHo CleeN ENeRcv AssocrerroN's
PeurroN To INTERVENE
Idaho Clean Energy Association, Inc. ("ICEA"), petitions the Commission for leave to
intervene in this case pursuant to Rule 71 , IDAPA 3 1 .01 .01 .7 I .
Intervention
l. The name and address of the intervenor is:
Idaho Clean Energy Association, Inc.
P .O. Box 2264
Boise,Idaho 83701
ICEA,S PETITIoN To INTEnVPNE - I
2. Please provide copies of all pleadings, production requests, production responses,
Commission orders and other documents as follows:
Preston N. Carter
Givens Pursley LLP
601 West Bannock Street
Boise, Idaho 83702
Email: prestoncarter@ givenspursley.com
kendrah@ givenspursley. com
3. This Intervenor, ICEA, is a nonprofit organization dedicated to the advancement
of renewable energy, energy efficiency and their associated technologies in the State of Idaho. Its
members currently sell products that are subject to the schedules at issue in this matter.
Therefore, ICEA claims a direct and substantial interest in this proceeding in that the prices its
members receive for electrical sales and costs they pay to Rocky Mountain Power may be
affected by the outcome of this proceeding.
4. ICEA 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 this Intervenor will introduce is dependent upon the nature
and effect of other evidence in this proceeding.
5. Without the opportunity to intervene herein, this Intervenor would be without any
means of participation in this proceeding, which may have a material impact on the prices it
receives for electric sales and costs it pays to Rocky Mountain Power.
For these reasons, ICEA respectfully requests:
1. That the Commission grant its Petition to Intervene in this case and that ICEA be
entitled to appear and participate as a party; and
2. That the Commission order any other such relief as the Commission considers just
and reasonable.
ICEA,S PETITIoN TO INTERVENE - 2
Dated: August 8,2019.
GIVENS PURSLEY LLP
Preston N. Carter
Givens Pursley LLP
Attorneys for ldaho Clean Energt Association, Inc.
ICEA'S PETTIoN To INTERVENE - 3
CERTIFICATE OF SERVICE
I certify that on August 7,2019, a true and correct copy of Ioeuo CLeaN ENpncy
AssocrartoN's PETlloN To INTERVENE was served upon all parties of record in this proceeding
via the manner indicated below:
Commission Staff
Diane Hanian, Commission Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
Boise, ID 83702
Diane.holt@puc.idaho. gov
(Original andT copies provided)
Hand Delivery
Via Electronic Mail
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
ted. we ston@ pacifi corp. com
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 841l6
yvonne. ho gl e @paci ficorp. com
Preston N. Carter
ICEA'S PerrrroN To INTERVENE - 4