20140915Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
botto @idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY CONFIRMING USE OF
THE CAPAPCITY DEFICIENCY
PERJOD FOR THE INCREMENTAL
COST, INTEGRATED RESOURCE
PLAN, AVOIDED COST
METHODOLOGY.
tPC-E-t4-22
ICL Petition to Intervene
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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 direct and substantial
interests in these proceedings, and therefore the Commission should grant intervention.
l. The name of this intervenor is:
Idaho Conservation League
c/o Benjamin I. Otto
710 N. 6m st.
Boise, Idaho 83702
Ph: [phone] x12
Far [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 3 1.01.01.063.02-03.
2. The 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 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
CASE NO. IPC.E-14-22
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
September 15,2014
charges for clean energy sources in order to foster clean energy development in Idaho
Power's service territory. This proceeding covers a foundational aspect of ensuring
accurate avoided costs and without intervening ICL will be unable t protect our members
interests in this area. 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, including submitting
discovery requests. The nature and quality of our intervention in the proceeding is
dependent upon the nature and effect ofother evidence in this proceeding. Ifnecessary
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 15h day of September 2014,
Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certiry that on this 15th day of September, 2014,I delivered true and
correct copies of the foregoing PETITION TO INTERVENE to the following persons via
the method of service note
Hand delivery:
]ean fewell - Commission Secretary
(Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Donovan E. Walker
Regulatory Dockets
Randy C. Allphin
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise, ID 83707
dwalker@idahopower. com
[e-mail]
[e-mail]
rPC-E-t4-22
ICL Petition to Intervene
tu
Benjamin Otto
September 15,2014