20140715Petition to Intervene.pdf

Benjamin I. otto (ISB No. s292) R[Cr'i1'1iri']
710 N 66 Street
Boise' ID 83701 2ol! JUL I 5 AH ll: 33
i*,'L'r-J,'r1i;:i::*" ur,r',?fff#otn iustoto
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
COMMISSION'S INQUIRY INTO
IDAHO POWER COMPANY'S FIXED
COST ADIUTSMENT MECHANISM
CASE NO. IPC-E-14-17
PETITION TO INTERVENE
OF THE
IDAHO CONSERVATION TEAGUE
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 the Commission should grant intervention.
1. The name of this intervenor is:
Idaho Conservation League
c/o Benjamin I. Otto
710 N. 6'h st.
Boise,Idaho 83702
Ph: [phone] xt2
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 of
conserving natural resources and reducing the costs to all parties, please provide hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
ICL'S PETITION TO INTERVENE I July 15,2014
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 building additional energy infrastructure both of which meet our
supporters' desire to protect Idaho's air quality and natural landscapes. To address this interest,
ICL has long advocated for a robust Fixed Cost Adjustment as a necessary regulatory mechanism
to support utility sponsored energy efficiency programs. ICL 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 3 1.01.01. 16 1- 16s.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 15th day of |uly 2014.
Benjamin J. Otto
Idaho Conservation League
Respectfully submitted,
ICL'S PETITION TO INTERVENE July 15,2014
CERTIFICATE OF SERVICE
I hereby certifr that on this l5 th day of )uly, 2014,ldelivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Hand delivery:
|ean fewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427W. Washington St.
Boise, lD 83702-5983
Electronic Mail:
Idaho Power Company
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707 -0070
dockets@idahopower. com
Industial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N.27d'St
Boise,lD 83702
[e-mail]
Dr. Don Reading
6070 Hill Rd.
Boise,ID 83703
[e-mail]
Benjamin I. Otto
[CL'S PETITION TO INTERVENE July 15,2014