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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