20020405Conservation Groups Petition to Intervene.pdf

William M.Eddie (ISB#5800)
LAND AND WATER FUND OF THE ROCKIES
P.O.Box 1612 rn 4 b
Boise,ID 83701 ÛRI
[phone] Ogfax:[phone]
[e-mail]
Express Mail:
1320 W.Franklin St.
Boise,ID 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AN ENERGY COST )
FINANCING ORDER AND AUTHORITY TO )CASE NOS.IPC-E-02-2
INSTITUTE AN ENERGY COST BOND CHARGE )IPC-E-02-3
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY TO )
IMPLEMENT A POWER COST ADJUSTMENT RATE )
FOR ELECTRIC SERVICE FROM MAY 16,2002 )
THORUGH MAY 15,2003 )
PETITION TO INTERVENE
Pursuant to Idaho Public Utilities Commission Rules of Procedure 53 and 71 through 73,
and Commission Order No.28988,Idaho Rivers United,Idaho Rural Council,NW Energy
Coalition,and Mary McGown ("Petitioners")hereby seek intervention in the above-captioned
matters.As discussed below,each Petitioner has a direct and substantial interest in these
proceedings,and therefore should be granted intervention.
Idaho Rivers United (IRU)is a non-profitmembership conservation organization with
approximately 2000 members,most of whom reside in Idaho and are Idaho Power residential
ratepayers.IRU's office address is:2600 Rose Hill,Suite 207,Boise,ID 83705.IRU advocates
for the protection and restoration of Idaho's rivers.Because a significant amount of the power
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produced in Idaho comes from hydropower sources,IRU also advocates for improved energy
conservation and efficiency efforts.IRU has a direct and substantial interest in this proceeding
because the issues at stake herein are closely tied to IRU's organizational mission to protect and
restore Idaho's rivers.
Idaho Rural Council (IRC)is a non-profitorganization with a membership consisting of
small farmers,ranchers,rural residents,and other persons interested in enhancing the social,
economic and environmental well-being of rural Idaho,protecting family farms and renewing
rural communities in a sustainable manner.Most of IRC's members are Idaho Power residential
or irrigation rate payers.IRC's address is:P.O.Box 118,Bliss,ID 83314.Because many rural
residents utilize electric space heating,and therefore suffer high electric bills,IRC and its
members have a direct and substantial interest in increasing and improving demand-side
management programs available through Idaho Power Company.Further,conservation of
energy is consistent with IRC's organizational mission to advocate for sustainable management
of natural resources.
The NW Energy Coalition is a non-profitregional alliance of over 95 diverse
environmental,civic,consumer,low income advocacy groups,energy efficiencyand renewable
energy businesses,and progressive utilities in Idaho,Montana,Washington and Oregon.The
Coalition has 10 member organizationsin Idaho,includingIRU and IRC.NW Energy Coalition
advocates for increased energy conservation efforts,sustainable and ecologically sound
management of electric generatinginfrastructure,and increased reliance on renewable sources of
energy.NW Energy Coalition's address is:219 First Ave South,Suite 100,Seattle,WA 98104.
NW Energy Coalition and its members have a direct and substantial interest in this proceeding
because increasing demand-side management in consistent with NW Energy Coalition's
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organizational mission to conserve natural resources and ensure the region enjoys an efficient
and sustainable energy supply.
Mary McGown is an Idaho Power residential ratepayer,and IdaCorp shareholder.Her
address is:262 S.Mobley Ln.,Boise,ID 83712..Ms.McGown is Chair of the Board of
Directors of the NW Energy Coalition (described above).Ms.McGown has long been active in
energypolicy matters in Idaho and other Northwest states,includingby advocating for increased
conservationmeasures and increased reliance on renewable sources of energy.Ms.McGown
has a direct and substantial interest in this proceeding as a ratepayer,and because effective
conservation of energy will stabilize electric rates and help conserve public resources.
Petitioners seek intervention in order to fully participate in this matter as parties and
otherwise present such materials as may be relevant to the Commission's decision in this matter.
Petitioners intend to seek intervenor fundingpursuant to RP 161 through 165.
PLEASE TAKE NOTICE that service of documents upon Petitioners in this proceeding
can be made through service of a single copy upon the undersignedcounsel.
WHEREFORE,Petitioners respectfullyrequest that the foregoing petition to intervene be
granted.
Dated:April 5,2002 Respectfullysubmitted,
William M.Eddie,Attorney
Land and Water Fund of the Rockies
On behalf of:
Idaho Rivers United
Idaho Rural Council
NW Energy Coalition
Mary McGown
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CERTIFICATE OF SERVICE
I hereby certify that on this 5th day April 2002,true and correct copies of the
foregoing PETITION TO INTERVENE were delivered to the followingpersons via the
method of service noted:
Via Hand-Delivery:
Commission Secretary
Idaho Public Utilities Commission
427 W.Washington St.
Boise,ID 83702-5983
Via U.S.Mail:
Larry D.Ripley
John R.Gale
Idaho Power Company
P.O.Box 70
Boise,ID 83707-0070
William M.Eddie
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