20140730Petition to Intervene.pdf

Benjamin J. Otto (ISB No. S2g2) RECHI\Ilril
710 N 6ft Street
Boise,ID 83701 20lt JUL 30 PH 2: 25
Ph: [phone]xt2 t*A['{CI i}t..]ili.i-Fax [phone] UTtLtTirs-iir,*itiiSsr,.:[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBTIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
IMPLEMENT SOALR INTEGRATION
RATES AND CHARGES.
IPC-E-14-18
ICL PETITION TO INTERVENE I
CASE NO. IPC-E-I4-18
PETITION TO INTERVENE
OF THE
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League (ICL) requesting 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 a 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 J. 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.
2. Idaho Conservation League claims a direct and substantial interest in this proceeding
arising from the impact to its members served by Idaho Power and to its long-term role
July 30,2014
advocating for public values. As Idaho's largest state-based conservation organization, we have
approximately 20,000 supporters many of who are customers of Idaho Power. ICL's members
have a direct interest in ensuring fair, accurate rates and charges for clean energy sources in order
to foster clean energy development in Idaho Power's service territory. ICL's intervention will not
unduly broaden the issues in this proceeding.
3. ICL's intend to fully participate in this matter as a party. The nature and quality of our
intervention in the proceeding is dependant upon the nature and effect of other evidence in this
proceeding. If necessary we may introduce expert testimony, be heard in argument, and call,
examine, and cross-examine witnesses. ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfully submitted this 30h day of fuly 2014,
CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of ]uly,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
Benjamin J. Otto
IPC-E-14-18
ICL PETITION TO INTERVENE
Electronic Mail:
Donovan E. Walker
Greg Said
Michael f. Youngblood
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise,lD 83707
dwalker@idahopower. com
[e-mail]
myoun gblood@idahopower. com
dockets@idahopower. com
Idaho Conservation League
July 30,2014