20140407Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
IMPLEMENT FIXED COST
ADIUSTMENT (FCA) RATES FOR
ETECTRIC SERVICE FROM JUNE I,
2OI4 THROUGH MAY 3I, 2015.
li: i ,, ,l .':'' .li. !i_1
BEFORE THE IDAHO PUBLIC UTITITIES COMMISSION
CASE NO. IPC-E-I4-03
THE IDAHO CONSERVATION
TEAGUE
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 J. Otto
Idaho Conservation League
710 N. 6'h st.
Boise,Idaho 83702
Ph: [phone] xrZ
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 Apri& 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 energy conservation 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. Over the years
ICL has participated extensively in the Fixed Cost Adjustment because the mechanism is a
critical regulatory policy to align Idaho Power's financial signals with Idaho's policy of
pursuing all cost-effective energy efficienry. The annual rate adjustment covered by this
application is an important part of maintaining a well functioning FCA mechanism. Due
to this long-term involvement in restructuring the regulatory environment to promote
energy efficienry in Idaho, 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}l4.
Benjamin J. Otto
Idaho Conservation League
Respectfully submitted,
ICL'S PETITION TO INTERVENE AprilJ* 201a
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 Iewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Lisa D. Nordstrom
Zachary L. Harris
Greg Said
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
ICL'S PETITION TO INTERVENE 3 Aprilfu 2014