20140407Petition to Intervene.pdf

Benjamin I. otto (ISB No. 8292) l:i,', ;1t'=- -J
710 N 6'h Street
Boise,lD 83701
Ph: [phone] x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF rDAHO POWER )
COMPANY'S APPLICATION FOR )
APPROVAL OF ITS AGREEMENT )
WITH ENERNOC,INC., TO )
IMPLEMENT AND OPERATE A )
VOLUNTARY COMMERCIAL )
DEMAND RESPONSE PROGRAM )
CASE NO. IPC-E-14-02
THE IDAHO CONSERVATION
LEAGUE
PETITION TO INTERVENE
The Idaho Conservation League (*ICL") petitions the Commission to intervene in
this 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 I. Otto
Idaho Conservation League
710 N. 6th st.
Boise, Idaho 83702
Ph: [phone]x12
Fax [phone]
[e-mail]
In the interest of conserving natural resources and reducing the costs, please
provide hard copies of pleadings, testimony, and briefs only to the name and address
above. 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 April}"2014
2. The Idaho Conservation League claims a direct and substantial interest in this
proceeding. As Idaho's largest state-based conservation organization, we have over
20,000 supporters, most of who are residential customers of Idaho Power. We have a
substantial interest in maintaining a robust demand response program to avoid burning
fossil fuels and the need for additional energy infrastructure both of which meet our
supporters' desire to protect Idaho's air quality and natural landscapes. ICL participated
in two prior cases that addressed the demand response programs, IPC-E-12-19 and IPC-
E-13-14, including extensive work on the workshops and settlement agreement approved
in IPC-E-13-14. ICL has an interest in ensuring Idaho Power's present application aligns
with the terms of the Commission approved settlement in IPC-E-13-14. Due to this long-
term involvement in restructuring Idaho Power's demand response programs, ICL brings
a unique and valuable perspective to this proceeding. 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. ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 2'd day of Aprilz}l(.
Respect!|ly submitted,wt 4---
Benjamin J. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE Aprilf,2014
CERTIFICATE OF SERVICE
I hereby certifr that on this 2nd day of April,20l4,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:
JuliaA. Hilton
Tami White
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
twhite@idahopower. com
[e-mail]
Benjamin I. Otto
ICL'S PETITION TO INTERVENE April{,2014