20130626Petition to Intervene.pdf

l:.!-'l ,:'
?fi!i JUill 2f; ,li'i l! : LBBenjamin l. Otto (lSB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Far [phone]
botto@idahoconservation. org
Attomey for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPAT{Y FOR A DETERMINTION
OF 2OI2 DEMAND-SIDE
MANAGEMENT EXPENDITURSS AS
PRUDENTLY INCURRED
't,i,l
BEFORE THE IDAHO PUBLIC UTITITIES COMMISSION
CASE NO. IPC-E-13-08
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League ('lCL") requesting leave to
intervene in the above captioned matter pursuant to the Idaho Public Utilities
Commission Rules of Procedure, IDAPA 31.01.01.071-073.ICL has direct and substantial
interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Benjamin I. Otto
Idaho Conservation League
710 N. 6th st.
Boise,Idaho 83702
Ph: [phone] x12
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 3 1.0 1.0 1.063.02-03.
2. Although the Notice of Application indicates this proceeding will use Modified
Procedure, the Commission should grant ICL's petition. The Rules of Procedure state the
ICL'S PETITION TO INTERVENE June26,2013
Commission "will grant intervention" when a petitioner "shows a direct and substantial
interest in any part of the subject matter of a proceeding and does not unduly broaden the
issues[.]" IDAPA 31.01.01.074.ICL submits this petition in order to gain a right to
discovery and a right to participate in any potential hearings or arguments that may
occur. IDAPA 31.01.01.038 and 222. Only by gaining status as a party to this proceeding
can ICL fully and fairly represent its direct and substantial interests in this proceeding
described in the following paragraph.
3. 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-
standing interest in expanding cost effective energy efficiency and conservation in Idaho.
ICL also 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 25,000 supporters, most of whom are residential customers of Idaho Power. This
proceeding reviews over $49.3 million spent on DSM activities in2012 to ensure these
investments were cost effective and produced verifiable energy savings. ICL and our
members have a direct and substantial interest in ensuring this ratepayer money was
prudently spent and that Idaho Power continues to pursue all cost effective energy
efficiency opportunities. 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.
4. The nature and quality of ICL's intervention in the proceeding is dependent
upon the nature and effect of other parties in this proceeding. If a hearing or argument
does occur ICL may introduce evidence, be heard, and call, examine, and cross-examine
witnesses. 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.
Respectfully submitted this 26th day of fune 2013,
Benjamin I. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE June26,2013
CERTIFICATE OF SERVICE
I hereby certify that on this 26 th day of |une 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:
fean fewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, lD 83702-5983
Electronic Mail:
Julia a. Hilton
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
Darlene Nemnich
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
r
Benjamin J. Otto
ICL'S PETITION TO INTERVENE Jwre26,2013