20091217Petition to Intervene.pdf

Betsy Bridge
Idao Conservtion League
PO Box 844
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
bbridgeØ)idaoconservtion.org
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BEFORE 1H IDAHO PUBliC UTIIJES COMMISSION
IN THE MATfROFTHE IDAHO POWER )
COMPANY'S APPliCATION TO MAKE )
THE FIXED COST ADJUSTMENT PERMANENT)
)
CASE NO. IPC-E-09-28
PETITION TO INTERVENE
Puruat to Idao Public Utilties Commission Rules of Procedure 53 and 71
throug 73, the Idao Conservtion League ("ICL") hereby seeks intervention in the
above-captioned matter. As diused below, ICL has diect and substantial interess in
these proceedigs, and therefore should be grted intervntion.
For thiy-four year, ICL has been Idao's voice for clean water, clean air, and
wildernessvaues that ar the foundation to Idao's extraordiar quaty of life. ICL
works to protect these vaues through citizen action, public education, and profesional
advocacy. As Idao's larest state-bad conservtion orgaization we represnt over 9,500
members, many of whom have a deep personal interest in protecting our clean ai, clean
water, and quaity of life. ICL's address is PO Box 844, 71 0 North Sixth St, Bois, Ida
83701.
ICL has direct and substantial interests in this proceedig becaus investments in
energ efficiency progrs and impacts on the envionment may be affeced by the
PETITION TO INRVENE BY ICL -- 1
outcome of this proceedig. Under traditional rate-makg practices a utilty compay's
revenues are tied to its saes. Ths creates a financial disincentive for companies to
promote aggessive energy effciency. ICL has an interest in promoting the responsible
expansion of energ efficiency in Idaho, and decisions issued in this ca may impact its
abilty to advace that interest. Moreover, ICL has individua members who ar cusomers
of the Idao Power Company.
ICL apologies for missing the deadline to intervene and wil be more prompt in
the future. ICt seeks intervention in order to fully paicipate in this matter as a pary and
otherwse to present such materials as may be relevt to the Commission's decision(s) in
this matter. ICL intends to seek intervnor fundig puruat to RP 161 thfug 165.
PLEASE TAKE NOTICE that ICL requests al documents in this matter be served
to the followig persons:
Betsy Bridge
Idao Conservtion League
PO Box 844
710 North Sixth Street
Boise, Idao 83701
bbridge(Pidahoconservation.org
WHEREFORE, ICL respectfully requests that the foregoing peition to intervne be
grted
Dated: December 17, 2009 Respectfully submitted,
PETITION TO INERVENE BY ICL -- 2
CERTIFICATE OF SERVICE
I hereby certify that on this 17th day of December, 2009, true and corrct copies of
the foregoing PETITION TO INTRVENE were delivered to the followig persns via the
method of servce noted:
Hand delivery
Jean Jewell
Commission Secretar (Origial and seven copies provided)
Idao Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
Electronic Mai:
Baron L. Kline
Donovan E. Waler
Idao Power Company
1221 West Idao Street
Boise, Idaho 83707-0070
BKlin e(Pidahopower. com
Scott D. Spar
John R Gale
Idao Power Company
P.O. Box 70
Boise, Idao 83707
ssparks(Pidaopower.com
rgale(Pidahopower.com
Brad M. Purdy
Attorney at Law .
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
bmpurdy(hotmail.com
Ken Miler
Clean Energ Progam Director
Snake River Allance
PO Box 1731
Boise, ID 83701
kmiler(snakeriveraliance.org
PETITION TO INRVENE BY ICL -- 3
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PETITION TO INTERVENE BY ICL -- 4