20140423Petition to Intervene.pdf

Benjamin J. Otto (ISB No.
710 N 66 Street
Boise,ID 83701
Ph: [phone] x12
Far [phone]
82e2)
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
IMPLEMENT POWER COST
ADIUSTMENT ("PCA") RATES FOR
ELECTRJC SERVICE FROM JUNE I,
2014, THROUGH MAY 31, 2015, AND )
CASE NO. IPC-E-14-05
IDAHO CONSERVATION LEAGUE
PETITION TO INTERVENE
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
TO UPDATE BASE RATES IN
COMPLIANCE WITH ORDER NO.
33000.
The Idaho Conservation League (*ICL') petitions the Commission to intervene in this
matter pursuant to the Idaho Public Utilities Commission Rules of Procedure,IDAPA
31.01.01.07I-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. 6th st.
Boise,ldaho 83702
Ph: [phone]x12
Fax [phone]
botto @idahoconservation. org
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 April23,2014
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 ldaho Power. The supporters we represent
have a strong interest in ensuring accurate accounting of power costs as well as ensuring the
Power Cost Adjustment mechanism is implemented in a manner to serve the interests of
ratepayers and the public. Specifically in this case, Idaho Power proposes to use energy efficiency
funds to offlset power costs. ICL and our members have a long-standing interest in ensuring the
appropriate use of energy efficiency funds. The Power Cost Adjustment can also send price
signals to ratepayers that encourage them to change their energy consumption behaviors. ICL
and our members also have a long standing interest is preserving the price signal function. ICL's
intervention will not unduly broaden the issues in this proceeding because Idaho Power
proposed the use of different funding pools and the price signal function is inherent to the Power
Cost Adjustment.
3. ICL intends to fully participate in this matter as a party. The nature and quality of
ICL's intervention in the proceeding is dependent 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 23rd day of April2014.
Idaho Conservation League
Respectfully submitted,
ICL'S PETITION TO INTERVENE April23,2014
CERTIFICATE OF SERVICE
I hereby certiry 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
42TW.Washington St.
Boise, ID 83702-5983
Electronic Mail:
Lisa D. Nordstrom
TimothyE. Tatum
GregoryW. Said
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
ttatum@idahopower. com
[e-mail]
[e-mail]
ICIP
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27th Street
Boise,lD 83702
[e-mail]
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
dreading@mindspring. com
Benjamin I. Otto
[CL'S PETITION TO INTERVENE April23,2014