20121119Petition to Intervene.pdf

RECEIVED
Benjamin J. Otto (ISB No. 8292)
710 N 6 th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
Nov 19 PM2:Ot
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APLICATION OF IDAHO POWER )
COMPANY FOR AUTHORITY TO ) CASE NO. IPC-E-12-24
IMPLEMENT RATES FOR ELECTRIC )
SERVICE TO INCLUDE CAPITALIZED ) PETITION TO INTERVENE OF THE
CUSTOM EFFICIENCY INCENTIVE IDAHO CONSERVATION LEAGUE
PAYMENTS.
COMES NOW the Idaho Conservation League ("ICL") and hereby requests leave
to intervene in the above captioned matter pursuant to the Idaho Public Utilities
Commission Rules of Procedure, IDAPA 31.01.01.071-073. As discussed below, ICL has
direct and substantial interests in these proceedings, and therefore should be granted
intervention.
1. The name of this intervenor is:
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the name and address above. In the interest
of conserving natural resources and reducing the costs to all parties, please provide hard
ICL PETITION TO INTERVENE 1 November 19, 2012
copies of pleadings, testimony, and briefs only. Production requests, responses, notices,
Commission orders, and other filings may be submitted via electronic mail in accordance
with IPUC Rules 31.01.01.063.02-03.
2.Idaho Conservation League claims a direct and substantial interest in this
proceeding arising from the impact to us and on behalf of our members as customers of
Idaho Power. ICL has an interest as a small commercial customer of Idaho Power taking
service under schedule 7. As Idaho's largest state-based conservation organization, we
represent over 20,000 supporters, most of whom are residential customers of Idaho
Power. On behalf of our organization and our members, ICL has a long-standing interest
in expanding cost effective energy efficiency and conservation in Idaho. This interest
includes being a pai'ty to, and joining the stipulation in, the prior iteration of this case,
IPC-E- 10-27. As a small commercial customer, on behalf of our residential customer
members, and as a long-standing advocate for energy efficiency in Idaho, ICL brings a
unique and valuable perspective to this proceeding. Because this Commission has
directed all utilities to pursue all cost effective efficiency and conservation measures, ICL's
intervention will not unduly broaden the issues in this proceeding.
3.ICL intends to fully participate in this matter as a party. The nature and quality
of ICL's intervention in the proceeding is dependant upon the nature and effect of other
evidence in this proceeding. If necessary ICL may introduce evidence, be heard in
argument, and call, examine, and cross-examine witnesses. ICL intends to seek
intervenor funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 19th day of November, 2012.
Respectfully submitted,
Benjamin J. Otto
Idaho Conservation League
ICL PETITION TO INTERVENE 2 November 19, 2012
CERTIFICATE OF SERVICE
I hereby certify that on this 19th day of November, 2012, I delivered true and
correct copies of the foregoing PETITION TO INTERVENE to the following persons via
the method of service noted:
Hand delivery:
Jean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Lisa D Nordstrom
Regulatory Dockets
Matt Larkin
Greg Said
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27th Street
Boise, ID 83702
[e-mail]
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[e-mail]
Benjamin J. Otto
CERTIFICATE OF SERVICE 1 November 19, 2012