20130724Petition to Intervene.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation league
IN THE MATTER OF IDAHO POWER
COMPAI\rY'S 20 I 3 INTEGRATED
RESOURCE PI-A,N.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-I3-I5
IDAHO CONSERVATION LEAGUE'S
PETITION TO INTERVENE
Idaho Conservation League ("ICL") submits this Petition to Intervene in the
above captioned matter pursuant to 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. 6'h 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 IPUC Rules 3 1.0 1.01.063.02-03.
IPC-E-13-15
ICL'S PETITION TO INTERVENE 1 July 24,2013
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 over 25,000 supporters, most of whom are residential customers of
Idaho Power. In addition, ICL, as an organization, is a small commercial customer of
Idaho Power. ICL has a long history of representing the interests of our supports on
issues affecting Idaho's air,lands, and water, including impacts caused by Idaho Power's
electrical system. The Integrated Resource Plan (lRP) under review here includes several
issues that effect these interests such as the level of Demand Side Management efforts, the
evaluation of distributed energy options, consideration of the roll of coal plants, and plans
for the Boardman to Hemingway Transmission line. The IRP is the only chance to review
and provide input on current and future plans for Idaho Power's over all system. ICL's
intervention will not unduly broaden the issues in this proceeding; rather focus on the
contents and process underlying Idaho Power's 2013 IRP
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 may seek intervenor
funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 24'h day of |uly 2013.
Respectfully submitted,&<+<-
Benjamin J. Otto
On behalf of the Idaho Conservation League
[PC-E-13-15
[CL'S PETITION TO INTERVENE IuJy 24,2013
CERTIFICATE OF SERVICE
I hereby certifr that on this 24th day of |uly,20l3,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 Iewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427W. Washington St.
Boise, lD 83702-5983
Electronic Mail:
Snake River Alliance
Ken Miller
Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise,ID 83701
kmiller@snakeriveralliance. org
Benjamin J. Otto
IPC-E-13-15
ICL'S PETITION TO INTERVENE July 24,2013