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Georgia Power Company's 2013 Rate Case ) ) ) Docket

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Georgia Power Company's 2013 Rate Case ) ) ) Docket BEFORE THE GEORGIA PUBLIC SERVICE COMMISSION STATE OF GEORGIA IN RE: ) GEORGIA POWER COMPANY’S ) DOCKET NUMBER 36989 2013 RATE CASE ) APPLICATION OF SIERRA CLUB FOR LEAVE TO INTERVENE Sierra Club hereby files this Petition for Leave to Intervene in the above-styled docket pursuant to the provisions of O.C.G.A. §§ 50-13-14, 46-2-59, Commission Utility Rule 515-2-1- .06 and the Commission’s May 22, 2013 Scheduling Order. In support thereof, Sierra Club respectfully shows the following: 1. Founded in 1892, the Sierra Club is the nation’s oldest non-profit, grassroots environmental organization with members in sixty-four chapters in all fifty states. The Sierra Club has over 600,000 members nationwide, with more than 10,000 members and supporters in the state of Georgia. The Georgia Chapter of the Sierra Club is headquartered in Decatur, Georgia and has seven local groups: the Savannah River, North Georgia, Metro-Atlanta, LaGrange, Greater Gwinnett, Coastal and Centennial Groups. The Sierra Club is a member-run organization focused on safe and healthy communities, smart energy solutions, and an enduring legacy for America's wild places. 2. Sierra Club has an interest in the 2013 Georgia Power Rate Case both on its own and on behalf of its members.1 One of Sierra Club’s top priorities is to advance smart, clean energy solutions and Sierra Club has long advocated for the use of renewable sources of energy, such as wind and solar power. Sierra Club’s Georgia members, many of whom are Georgia Power ratepayers, support the shift toward more sustainable and renewable forms of energy production. 1 The office of the Georgia Chapter of the Sierra Club uses and pays for electricity supplied by Georgia Power Company, as do many of Sierra Club’s members and supporters. As a result, Sierra Club has a legal and property interest in this proceeding. The rates at issue in this docket play a critical role in the mix and amount of electricity generated. Two examples will help to highlight this interaction: a rate structure that makes it pay to save – by utilizing volumetric over flat or declining rates – will encourage conservative use of electricity over consumption; separately, Georgia Power’s requested tariff proposed at SPS-1 will affect on-site generation of solar. As a result, Sierra Club’s members have substantial and vital interests in the outcome of this proceeding. 3. The interests of Sierra Club and its members are not adequately represented by other parties to this proceeding. Sierra Club is the only grassroots, member run, environmental non- profit in Georgia with significant membership state-wide. Its counsel, staff and outside experts, have extensive experience as well as up to date information on energy issues and rates throughout the United States. 4. Sierra Club will participate actively in this docket. Sierra Club’s participation will not unduly delay the proceedings nor prejudice the rights of parties. 5. Sierra Club designates the following persons to receive all notices, correspondence and filings in the above docket, and to be placed upon the official service list in this proceeding: Ashten Bailey GreenLaw State Bar of Georgia Building 104 Marietta St., Suite 430 Atlanta, GA 30303 (404) 659-3122 [email protected] Robert Ukeiley GreenLaw Mailing address: 507 Center Street Berea, KY 40403 Direct Line: (859) 986-5402 [email protected] Page 2 of 2 WHEREFORE, Sierra Club respectfully requests that the Commission grant its application for leave to intervene in the above-captioned docket, thereby allowing Sierra Club to participate fully as a party of record. Respectfully submitted this 9th day of August, 2013 Ashten Bailey, Ga. Bar No. 803367 Robert Ukeiley, Ga. Bar No. 721597 GreenLaw State Bar of Georgia Building 104 Marietta St., Suite 430 Atlanta, GA 30303 (404) 659-3122 Counsel for Sierra Club Page 3 of 3 STATE OF GEORGIA, FULTON COUNTY: VERIFICATION Personally appeared before me, the undersigned officer duly authorized to administer oaths, ASHTEN BAILEY, who upon being sworn deposes and states that the information contained in the within and foregoing APPLICATION OF SIERRA CLUB FOR LEAVE TO INTERVENE is true and correct. Respectfully submitted this 9th day of August, 2013 Ashten Bailey Sworn to and subscribed before me this _____ day of August, 2013 Notary Public My commission expires: ________________. Page 4 of 4 CERTIFICATE OF SERVICE I certify that I have this day caused to be served a copy of the foregoing APPLICATION OF SIERRA CLUB FOR LEAVE TO INTERVENE, which was filed with the Georgia Public Service Commission’s Executive Secretary by hand delivery. An electronic copy of same was served upon all parties listed below by electronic mail, unless otherwise indicated, as follows: Jeffrey Stair Via hand delivery Philip Smith Reece McAlister Georgia Public Service Commission Executive Secretary 244 Washington Street, S.W. Georgia Public Service Comm. Atlanta, GA 30334 244 Washington Street, SW [email protected] Atlanta, GA 30334 [email protected] Kevin Greene, Esq. Daniel Walsh Brandon Marzo Kevin Queen Office of the Attorney General Troutman Sanders Manager, Regulatory Affairs Department of Law NationsBank Plaza Georgia Power Company 40 Capital Square 600 Peachtree Street, NE Bin 10230 Atlanta, Georgia 30334 Suite 5200 241 Ralph McGill Boulevard, NE [email protected] Atlanta, GA 30308 Atlanta, GA 30308-3374 [email protected] [email protected] [email protected] G. L. Bowen, III Kyle J. Smith, Esq. Charles B. Jones, III General Attorney Randall D. Quintrell, Esq. GA Traditional Manufacturers Association Regulatory Law Office (JALS-RL/IP) Randall D. Quintrell, P.C. The Hurt Building U. S. Army Legal Services Agency 999 Peachtree Street, NE, 27th Floor 50 Hurt Plaza, Suite 985 9275 Gunston Road Atlanta, GA 30309 Atlanta, Georgia 30303 Fort Belvoir, VA 20060-5546 [email protected] [email protected] [email protected] [email protected] Jeffry C. Pollock Jim Clarkson Alan R. Jenkins J. Pollock, Inc. Resource Supply Management Jenkins at Law, LLC 12647 Olive Blvd., Suite 585 1370 Walcora Drive 2265 Roswell Road, Suite 100 St. Louis, Missouri 63141 Sumter, SC 29150 Marietta, Georgia 30062 [email protected] [email protected] [email protected] Kurt Ebersbach Katie Ottenweller Liz Coyle Robert B. Baker Southern Environmental Law Center Georgia Watch Freeman Mathis & Gary, LLP The Candler Building 55 Marietta Street, Suite 903 100 Galleria Parkway, Suite 1600 127 Peachtree SI. Suite 605 Atlanta, Georgia 30303 Atlanta, Georgia 30339 Atlanta, GA 30303-1840 [email protected] [email protected] [email protected] [email protected] Kurt J. Boehm, Esq. Kevin Higgins Jody Kyler Cohn, Esq. Dan O. Moore ENERGY STRATEGIES, LLC BOEHM, KURTZ & LOWRY Energy Services Group, LLC Parkside Towers 36 East Seventh Street, Suite 1510 1875 Old Alabama Rd., Suite 1320 215 South State Street, Suite 200 Cincinnati, Ohio 45202 Roswell, Georgia 30076 Salt Lake City, Utah 84111 [email protected] Email: [email protected] [email protected] [email protected] Page 5 of 5 This 9th day of August, 2013 Ashten Bailey Counsel for the Sierra Club Page 6 of 6 .
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