20160608Petition to Intervene.pdf

Benjamin I. otto (ISB No. 82s2) SilCEIVED
710 N 6'h Street
Boise,ID 83701 it]l[ it]]i -B PH 2: 23
Ph: [phone] x 12 , ,i,l-lCFax [phone] ,' , : ,:j1i]fi;i$Sf Ot'l
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
UPDATE SOTAR INTEGRATION
RATES AND CHARGES.
CASE NO. IPC-E-16-1I
PETITION TO INTERYENE OF THE
IDAHO CONSERVATION LEAGUE
The Idaho Conservation League ("lCL') 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 I. Otto
Idaho Conservation League
710 N. 6'h 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, testimony, and briefs onlyto 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 intervened in the prior solar integration docket, IPC-
E-14-18, and claims a direct and substantial interest in this new solar integration docket. 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 growing Idaho's clean reliable and affordable energy resources to avoid
burning fossil fuels and protect Idaho's air quality and natural landscapes. We have a direct and
ICL'S PETITION TO INTERVENE 1 June 8,2016
substantial interest in ensuring the Idaho Power collects fair, just, and reasonable rates and
charges from both customers and renewable energy providers. Because this Commission has
directed all utilities to pursue all cost efflective 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 8th day of fune 2016.
Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certifr that on this 8th day of fune 2016,I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following persons via the method of service noted:
Hand delivery:
)ean )ewell
Commission Secretary
Idaho Public Utilities Commission
42TW.Washington St.
Boise, ID 83702-5983
(Original and seven copies provided)
Electronic Mail:
Donovan E. Walker
Michael J. Youngblood
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
dwalker@idahopower. com
[e-mail]
[e-mail]
Benjamin
ICL'S PETITION TO INTERVENE June 8,2016