20160923Petition to Intervene.pdf

Ken Miller
SNAKE RIVER ALLIANCE
223 N. 6th St., Ste. 317
PO Box 1731
Boise, ID 83701
Ph: [phone]
kmiller@snakeri veralliance. org
2016 ~:f:P 23 PM J: / /
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
PETITION TO INTERVENE IN THE MATTER OF THE APPLICATION OF
INTERMOUNT AIN GAS COMPANY FOR THE AUTHORITY TO CHANGE ITS
RATES AND CHARGES FOR NATURAL GAS SERVICE TO NATURAL GAS
CUSTOMERS IN THE STA TE OF IDAHO
CASE NiO. INT-G-16-02
Pursuant to the Idaho Public Utilities Commission's Rules of Procedure Rule 71, ID APA
31.01.01.071 , et seq., and in response to Commission Order No. 33593, the Snake River Alliance
petitions the Commission to grant its petition for intervention in the above-referenced case, INT­
G-16-02. The name and address of the Intervenor is:
SNAKE RIVER ALLIANCE
223 N. 6th St., Ste. 317
PO Box 1731
Boise, ID 83701
Ph: [phone]
kmiller@snakeri veralliance. org
Pending further notice to the Commission and to Parties, Ken Miller will represent the Snake
River Alliance in this proceeding. Correspondence in this docket can be sent to the above address
or via email. To reduce costs and environmental impacts of exchanging information in this case,
the Alliance requests that, pursuant to IPUC Rules, information other than that which might be
deemed confidential or otherwise must be hand-delivered be priiovided electronically and/or via
email to the above address.
The Snake River Alliance is an Idaho-based non-profit organization, established in 1979 to
address Idahoans' concerns about nuclear waste and safety issues. In 2007, the Alliance
Snake River Alliance 1
Petition to Intervene -INT-G-16-02
expanded the scope of its mission by becoming Idaho's first nonprofit clean energy advocacy
organization. The Alliance's energy program includes advocacy for renewable energy resources
in Idaho; expanded conservation and demand-side management programs offered by Idaho's
regulated electric utilities and the Bonneville Power Administration; and development of local,
state, regional, and national initiatives to advance sustainable energy policies, including electric
utility rate structures and designs that promote energy conservation and serve the interests of
residential customers of Idaho's regulated gas and electric utilities. The Alliance pursues these
programs on behalf of its members, most of whom are customers of Intermountain Gas
Company.
The Alliance has a direct and substantial interest in these proceedings as the Company's request
raises policy issues of interest to the Alliance and its members and other Intermountain Gas
customers. In particular and with regard to this docket, the Alliance intends to participate in
deliberations as they relate to proposals by Intermountain Gas relating to demand-side
management (DSM) initiatives; its proposed Fixed Cost Collection Mechanism (FCCM, or
"decoupling"); and general rate design issues.
The Alliance believes its participation as an intervenor will not complicate or extend this case,
nor will its participation unduly broaden the issues in this case, and that to the extent permitted
by Commission rules it will actively participate in this case as an intervenor.
Therefore and pursuant to Rules 72 and 73 of the Commission's Rules of Procedure, IDAPA
31.01.01.072 and 073, the Alliance requests that this petition to participate as an intervenor in
Case No. INT-G-16-02 be granted.
Respectfully submitted this 23rd day of September 2016.
Ken Miller
Energy Program Director
Snake River Alliance
Boise, ID
[phone]
[e-mail]
Hand Delivered
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83 702
Snake River Alliance
Petition to Intervene -INT-G-16-02
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