20140407Petition to Intervene.pdf

Benjamin l. otto (lSB No. Bzgz) i-' ' - - ' l' : i l
710 N 6'h Street
Boise, ID 83701
Ph: [phone]xt2
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A DETERMINATION
OF 2013 DEMAND.SIDE
MANAGEMENT ("DSM") EXPENSES
AS PRUDENTLY INCURRED.
CASE NO. IPC-E-14-04
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 J. Otto
Idaho Conservation League
710 N. 6'h 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 I AprilrQ,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. ICL also has an
interest as a small commercial customer of Idaho Power taking service under schedule 7.
ICL and our supporters 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. We have a direct and substantial interest in ensuring the $25.9 million
of ratepayer dollars spent on DSM activities in 2013 produced cost effective, verifiable
energy savings and that Idaho Power continues to pursue all cost effective energy
efficienry opportunities. Because this Commission has directed all utilities to pursue all
cost effective efficienry and conservation 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. 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}ll.
Benjamin J. Otto
Idaho Conservation League
2
Respectfully submitted,
[CL'S PETITION TO INTERVENE April{,2014
CERTIFICATE OF SERVICE
I hereby certiff 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:
Iean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Julia A. Hilton
Darlene Nemnich
Tami White
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
twhite@idahopower. com
[e-mail]
dockets@idahopower. com
&.t--
Benjamin J. Otto
ICL'S PETITION TO INTERVENE April).2014