20150327Petition to Intervene.pdf

Benjamin I. Otto (ISB No. S2g2) I r: i"'i:
710 N 6s Street
Boise, ID 83701 ?I1i [lii3 2l PH l: 5 I
Ph: [phone] x12
, i .r ,' :Fax [phone]
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'[e-mail] ' l
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-ls-06
COMPANY FOR A DETERMINATION )
oF 2014 DEMAND-SIDE ) THE IDAHO CONSERVATION
MANAGEMENT ("DSM") EXPENSES 1 LEAGUE
AS PRUDENTTY INCURRED. 1 PETITION TO INTERVENE
The Idaho Conservation League (*ICL') petitions the Commission to intervene in this
matter pursuant to the Idaho Public Utilities Commission Rules of Procedure, IDAPA
31.01.01.071-073. As discussed below,ICL has direct and substantial interests in these
proceedings, and therefore should be granted intervention.
l. The name of this intervenor is:
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise,Idaho 83702
Ph: [phone] xt2
Fax [phone]
[e-mail]
In the interest of conserving natural resources and reducing the costs, please provide hard
copies of pleadings, testimon|, 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.
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 25,000
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 the need for additional energy infrastructure both of which meet
ICL'S PETITION TO INTERVENE 1 March 27,2015
our supporters' desire to protect Idaho's air quality and natural landscapes. We have a direct and
substantial interest in ensuring the ratepayer dollars spent on DSM activities in2014 produced
cost effective, verifiable energy savings and that Idaho Power continues to pursue all cost effective
energy efficienry opportunities. Because this Commission has directed all utilities to pursue all
cost effective efficiency and conservation measures, 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. ICL may seek intervenor funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 27th day of March 2015.
Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certi$/ that on this 27th day of March 2015, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Hand delivery:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, lD 83702-5983
(Original and seven copies provided)
Electronic Mail:
Lisa D. Nordstrom
Darlene Nemnich
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
lnordstrom@idahopower. com
[e-mail]
dockets@idahopower. com
Respectfully submitted,
Benjamin I. Otto
[CL'S PETITION TO INTERVENE March 27,2015