20130111Petition to Intervene.pdf

I: -
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
ZUI3JANII PM3:1
QM-0JBI
-510 LTE 1M /MtS
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF THE IDAHO CASE NO. IPC-E-12-29 POWER COMPANY FOR AUTHORITY )
TO TEMPORARILY SUSPEND IT'S A/C ) PETITION TO INTERVENE OF THE COOL CREDIT AND IRRIGATION IDAHO CONSERVATION LEAGUE PEAK REWARDS DEMAND )
RESPONSE PROGRAMS )
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.
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 IPUC Rules 31.01.01.063.02-03.
ICL'S PETITION TO INTERVENE 1 January 11, 2013
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. As Idaho's largest state-based conservation
organization, we have approximately 20,000 supporters, most of who are are residential
customers of Idaho Power. Our supporters look to ICL to represent their substantial
interest in expanding cost-effective energy efficiency and conservation in Idaho. More
specifically in this case, maintaining a long-term, robust demand response program will
avoid burning fossil fuels and additional energy infrastructure both of which meet our
supporters desire to protect Idaho's air quality and natural landscapes. As the only
potential intervenor in this proceeding advocating for investments, rate designs, and rate
spreads specifically intended to fully incentivize energy efficiency and demand response,
ICL brings a unique and valuable perspective to this proceeding. Because this
Commission has directed Idaho utilities to pursue all cost effective demand side
management 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. Depending on the time and
resource expended 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 - day of
Respectfully submitted,
Benjamin J. Otto
On behalf of the Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 January 11, 2013
CERTIFICATE OF SERVICE
I hereby certify that on this 11th day of January, 2013, 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
Courtney Waites
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Eric Olsen
Racine, Olsen, Nye, Budge & Bailey, Chartered
P.O. Box 1391
Pocatello, ID 83204
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
[e-mail]
Benjamin J. Otto
ICL'S PETITION TO INTERVENE 3 January 11, 2013