20111116Petition to Intervene.pdf

0E. C'E-I.V Dj 'i,.. J.... .-
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idaoconservation.org
ion NOV 16 PM 12:Ld
Attorney for the Idao Conservtion Leage
BEFORE lHE IDAHO PUBLIC UTITIES COMMISSION
IN lHE MAlTR OF lHE )
APPLICATION OF IDAHO POWER )
COMPNAY FOR AUlHORIT TO )
CONVRT SCHEDULE 54-FIXD )
COST ADJUSTMENT-FROM A PIWT )
SCHEDULE TO AN ONGOING, )PERMENANT SCHEDULE )
CASE NO. IPC-E-Il-19
PETITION TO INTERVENE OF TH
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservtion League ("ICL))) and hereby requests leave
to intervene in the above captioned matter pursuat to the Idao Public Utilties
Commission Rules of Procedure, IDAPA 31.01.01.071-073. As discussed below, ICLha
direct and substantial interests in these proceedigs, and therefore should be grted
intervention.
1. The name of this intervenor is:
Benjamin J. Otto
Idao Conservtion League
710 N. 6th st.
Boise, Idao 83702
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservtion.org
Please provide copies of all pleadigs, production requests, production responses,
Commission orders, and other documents to the name and address above. In the interest
of conservg natur resources and reducing the costs to al paries, please provide had
copies of pleadigs, testimony, and briefs only. Production requests, responses, notices,
ICL'S PETITION TO INTERVENE 1 November 16,2011
Commission orders, and other filgs may be submitted via electronic mai in accordace
with IPUC Rules 31.01.01.063.02-03.
2. Idao Conservation League clais a direct and substantial interest in this
proceeding arsing from the impact to its members served by Idao Power and to its long-
term role advocating for public vaues. As Idao's larest state-basd conservation
orgization, we have over 20,000 supporters many of who are cusomers of Idao Power.
In addition to representing the interest of residential customers, ICL has an interest in
expanding of energy efficiency and conservation in Idao and the Fixed Cost Adjustment
is a priar means to achieve this. Because this Commission has diected al utilties to
purue all cost effective effciency and conservation measures, ICL's intervention wi not
unduly broaden the issues in this proceedig.
3. ICL intends to fuly participate in this matter as a pary includig retaiing an
expert witness, Carl Livie of the Aspen Envionmental Group. The nature and quaity of
ICL's intervention in the proceedig is dependat upon the nature and effect of other
evidence in this proceedig. If necess ICL may introduce evidence, be heard in
arguent, and call, examine, and cross-examine witnesses. ICL intends to seek
intervenor fundig pursuat to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfuly requests the Commission grt this petition.
DATED this 16th day of November 2011.
Respectfully submitted,~~
Benjamin J. Otto
On behaf of the Idao Conservtion League
.
ICL'S PETITION TO INTERVENE 2 November 16,2011
CERTIFICATE OF SERVICE
.
I hereby certify that on this 16th day of November, 2011, I delivered true and
correct copies of the foregoing PETITION TO INTERVENE to the followig persons 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:
Jason B. Wiliams
Lisa D. Nordstrom
Idao Power Company
1221 West Idao Street
Boise, Idao 83707-0070
jwiiams ~idaopower.com
lnordstrom~idahopower.com
MichaelJ. Youngblood
Zachar 1. Hars
Idao Power Company
P.O. ox 70
Boise, Idao 83707
myoungblood~idahopower.com
zhars~idaopower.com
Nancy Hirsh
NW Energy Coalition
811 1st Ave., Suite 305
Seattle, W A 98104
Ph: [phone]
nan~nwenergy.com It~.
Benjamin 1 Otto
ICL'S PETITION TO INTERVENE 3 November 16,2011