20160629Petition to Intervene.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6ft Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
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BEFORE THE IDAHO PUBTIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER J cesE No. rpc_E_16_14coMPANY',S APPLICATION FOR ) -'^
APPROVAL OF NEW TARIFF ) PETITION TO INTERVENE OF THEscHEDr.rLE 63, A CoMMLTNITY I EfibtoNsEnveuoN LEAGUEsoLAR PrLOT PROGRAM. )
COMES NOW the Idaho Conservation League ("ICL") and hereby requests 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 should be granted intervention.
1. The name of this intervenor is:
Benjamin I. Otto
Idaho Conservation League
710 N.6tr st.
Boise,Idaho 83702
Ph: [phone]xt2
Fax [phone]
[e-mail]
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 maybe submitted via electronic mail in accordance with IPUC Rules
3r.0r.0r.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.lCL and our
supporters have a substantial interest in promoting clean energy alternatives that avoid burning
ICL'S PETITION TO INTERVENE Itne27,2016
fossil fuels and the need for additional energy infrastructure, both of which meet our supporters'
desire to protect Idaho's air quality and natural landscapes. We have a direct and substantial
interest in the design of the Community Solar Pilot program to ensure customers have a realistic
option to participate while non-participants are insulted from unwarranted impacts. ICL's
intervention will not unduly broaderi the issues in this proceeding; rather ICL will respond to
Idaho Power's proposal.
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. If necessary ICL may introduce evidence, be heard in argument, and call, examine,
and cross-examine witnesses. ICL intends to seek intervenor funding pursuant to IDAPA
31.01.01.161- 16s.
WHEREFORE,ICL respectfully requests the Commission grant this petition.
DATED this 28th day of |une 2016.
Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I (, /&0,x-eertifr that on this 28th day of June, z[ll,ldelivered 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 (Original and seven
copies provided)
Idaho Public Utilities Commission
42TW.Washington St.
Boise,ID 83702-5983
Electronic Mail:
Lisa D Nordstrom
Matt Larkin
Peter Pengilly
Idaho Power Company
1221 West Idaho St
PO Box 70
Boise, ID 83707
[e-mail]
[e-mail]
mlarkin@idahopower. com
ppengitty@idahop
ICL'S PETITION TO INTERVENE Iane27,2016