20160406Petition to Intervene.pdf

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Benjamin I. Otto (ISB No. 8292)
710 N 6s Street ?1116 IiPS -6 FF1 l: I l+
Boise,ID 83701
Ph: [phone]xl2 , ,I,,,, l. ,;;-i!,,l,oltSt*fi
Fax [phone] r'ri:'i:iiLl'
[e-mail]
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-16-03
COMPANY FORA DETERMINATION )
oF 201s DEMAND-SIDE ) THE IDAHO CONSERVATION
MANAGEMENT EXPENSES AS 1 LEAGUE
PRUDENTLY 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
31.01.01.07I-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]
[e-mail]
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 T.lcLand 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 April6,2016
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 in 2015 produced
cost effective, verifiable energy savings and that Idaho Power continues to pursue all cost effective
energy efficiency 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 6th day of April20l6.
Benjamin J. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certi4/ that on this 6th day of April2016,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, ID 83702-5983
(Original and seven copies provided)
2
Electronic Mail:
Lisa D. Nordstrom
Connie Aschenbrenner
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
caschenbrenner@idahopower. com
dockets@idahopower. com
Benjamin I. Otto
ICL'S PETITION TO INTERVENE April6,2016