20140521Petition to Intervene.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6s Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO
TEMPORARILY SUSPEND ITS PURPA
OBLIGATION TO PURCHASE
ENERGY GENERATED BY SOALR-
POWERED QUALIFYING FACILITIES
("QF").
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASENO. IPC-E-14-09
IDAHO CONSERVATION LEAGUE
) PETITION TO INTERVENE
)
COMES NOW the Idaho Conservation League (*ICL") and hereby requests leave
to intervene in the above captioned 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]
botto @idahoconservation. org
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the name and address above. In the interest
ofconserving natural resources and reducing the costs to all parties, please provide hard
copies of pleadings, testimony, and briefs only. Production requests, responses, notices,
ICL'S PETITION TO INTERVENE May 21,2014
Commission orders, and other filings may be submitted via electronic mail in accordance
with IPUC Rules 3 1.01.01.063.02-03.
2. Idaho Conservation League claims a direct and substantial interest in this
proceeding arising from the impact to our members served by Idaho Power and to ICL's
long-term role advocating for public values. As Idaho's largest state-based conservation
organization, we have approximately 20,000 members who are residential customers of
Idaho Power. Our supporters have a strong interest in ensuring a predictable, stable
regulatory system to grow Idaho's clean energy resources in order to protect Idaho's air
and climate. ICL brings a unique and valuable perspective to this proceeding because our
supporters are also Idaho Power customers who support using their ratepayer dollars to
support clean energy projects. By focusing on the obligation to negotiate PURPA
contracts, and resolving the accurate integration costs to include in these contracts,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. If necessary ICL may introduce evidence, be heard in
argument, and call, examine, and cross-examine witnesses. ICL intends to seek
intervenor funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 21st day of May 2014.
Benjamin I. Otto
Idaho Conservation League
Respectfully submitted,
ICL'S PETITION TO INTERVENE May 21,2014
CERTIFICATE OF SERVICE
I hereby certifr that on this 2lst day of May,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,lD 83702-5983
Electronic Mail:
Donovan Walker
Idaho Power Company
12l West Idaho St
P.O. Box 70
Boise,Idaho 83707
[e-mail]
Benjamin J. Otto
[CL'S PETITION TO INTERVENE May 21,2014