20100628Petition to Intervene.pdf

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Benjamin J. Otto
ISB No. 8292
710 N 6th Street
PO Box 844
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservtion.org
ZDiOJtlM28 PM l:42
Attorney for Idao Conservtion League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TIER OF THE )
APPLICATION OF IDAHO POWER )
COMPANY FOR A PRUDENCY )
DETERMINATION OF ENERGY )
EFFICIENCY RIDER FUNDS SPENT IN )2008-2009 )
CASE NO. IPC-E-1O-09
PETITION TO INTERVENE
COMES NOW Idao Conservtion League ("ICL") and hereby requests leave to
intervene in the above captioned matter puruat to the Idao Public Utilties
Commission Rules of Procedure, IDAPA 31.01.01.071-073. As discused below, ICL has
direct and substantial interests in these proceedigs, and therefore should be grted
intervention.
1. Please send copies of all pleadigs, production requests, production responses,
Commission orders, and other documents to the Intervenor at:
Benjamin J. Otto
Idaho Conservtion League
710 N. 6th st.
P.O. Box 844
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservation .org
PETITION TO INTERVENE 1 June 28, 2010
2. Idao Conservtion League clais a diect and substantial interest in this
proceeding ansing from the impact to its members served by Idao Power and to its long-
term role advocating for public values. As Idao's largest state-based conservation
organization, we have thousands of members who are residential customers of Idao
Power. In addition to representing the interest of these residential customers, ICL has an
interest in promoting the responsible expansion of energy efficiency and renewable energy
in Idao in order to protect clean air, clean water, and vibrat open spaces. Because this
Commission has directed al utilties to pursue all cost effective effciency and conservation
measures, ICL's intervention wil not unduly broaden the issues in this proceeding.
3. ICL intends to fuly paricipate in this matter as a pary, and if necessary, may
.
introduce evidence, be heard in arguent, and ca, examine, and cross-examine witnesses
as may be relevant in this matter. The nature and quaity of ICL's intervention in the
proceeding is dependat upon the nature and effect of other evidence in this proceedig.
ICL intends to seek intervenor funding pursuat to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grt this petition.
DATED this 28th day ofJune 2010.
Respectfuly submitted,~ z;:s
Benjamin J. Otto
Idao Conservation Leagu
PETITION TO INTERVENE 2 June 28, 2010
CERTIFICATE OF SERVICE
I hereby certify that on this 28th day of June, 2010, true and correct copies of the
foregoing PETITION TO INTERVENE were delivered to the following persons via the
method of servce noted:
Han d delivery
Jean Jewell
Commission Secretary (Ongial and seven copies provided)
Idaho Public Utilties Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Lisa D. Nordstrom
Donovan E. Waler
Idaho Power Company
P.O. Box 70
Boise, ID 83707
lnordstrom~idahopower.com
dwalke~idaopower.com
Darlene Nemnich
Greg Said
Idaho Power Company
P.O. Box 70
Boise, ID 83707
dnemnich~idhaopower.com
gsaid~idaopower.com
¡¿~
Benjamin J. Otto
PETITION TO INTERVENE 3 June 28, 2010