20121218Petition to Intervene.pdf

RE CE v
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
701:2 DEC 18 PM 1.53
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER CASE NO. IPC-E-12-27 COMPANY FOR AUTHORITY TO
MODIFY ITS NET METERING )
) PETITION TO INTERVENE OF THE SERVICE AND TO INCREASE THE
GENERATION CAPACITY LIMIT. IDAHO CONSERVATION LEAGUE
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
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 IDAPA 31.01.01.063.02-03.
ICL'S PETITION TO INTERVENE 1 December 18, 2012
2.Idaho Conservation League claims a direct and substantial interest in this
proceeding arising from the impact to its members served by Idaho Power and to its long-
term role advocating for public values. ICL has an interest as a small commercial
customer of Idaho Power taking service under schedule 7, under which we may become
future net metering customers. As Idaho's largest state-based conservation organization,
we represent over 20,000 supporters, most of whom are residential customers of Idaho
Power. In addition, many of the current net metering customers are members of ICL and
these individuals have an interest in the current and future net metering rate schedules.
Combining the voices of net metering supporters--including current participants,
potential future participants, and non-participants who support clean energy--ICL brings
a unique and valuable perspective to this proceeding. ICL's intervention will not unduly
broaden the issues in this proceeding since it this case is focused squarely on the net
metering program.
3.ICL is petitioning for intervention because we intend to fully participate in this
matter as a party. Idaho Power's application includes detailed technical information and
represents a drastic change in the net metering program. Accordingly, ICL's participation
is likely to include conducting discovery, advocating for a technical hearing on this
matter, as well as participating in any potential settlement negotiations. For these
reasons, ICL specifically requests the Commission issue a timely order granting or
denying this petition following the seven-day opposition period in IDAPA 31.01.01.075.
Depending on the time and resources involved in this case ICL may seek intervenor
funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 18th day of December 2012.
Respectfully submitted,
A~~
Benjamin J. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 December 18, 2012
CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of December 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
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Matt Larkin
Greg Said
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
S' 6 z-'-
Benjamin J. Otto
ICL'S PETITION TO INTERVENE 3 December 18, 2012