20160406Petition to Intervene.pdf

Benjamin l. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATTON OF rDAHO POWER )
COMPANY TO IMPLEMENT FIXED )
COST ADJUSTMENT ("FCA") RATES ) THE IDAHO CONSERVATION
FOR ELECTRIC SERVICE FROM ILINE 1 LEAGUE
L,2OL6,THROUGH MAY 31, 2017. )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.
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
In the interest of conserving natural resources and reducing the costs, please provide hard
copies of pleadings, testimony, 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
CASE NO. IPC-E-16-02
ICL'S PETITION TO INTERVENE April6,2016
our supporters' desire to protect Idaho's air quality and natural landscapes. The Fixed Cost
Adjustment is an important mechanism to support utility sponsored energy conservation
programs and we have a direct and substantial interest in reviewing Idaho Power's proposed
rates. 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 respectfrrlly requests the Commission grant this petition.
DATED this 6th day of April20l6.
Respectfully submitted,
L2? ..t--
Benjamin J. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certifr that on this 6th day of April20l6,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 ]ewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original and seven copies provided)
Electronic Mail:
Lisa D. Nordstrom
Zachary L. Harris
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
[e-mail]
Benjamin I. Otto
[CL'S PETITION TO INTERVENE April6,2016