20161003Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation Lea.gue
P.~CE IVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY'S APPLICATION FOR
DEFERRAL AND RECOVERY OF
COSTS ASSOCIATED WITH
PARTICPATION IN THE ENERGY
IMBALANCE MARKET.
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CASE NO. IPC-E-16-19
THE IDAHO CONSERVATION
LEAGUE
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, ID APA
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. 6th st.
Boise, Idaho 83702
Ph: [phone] x 12
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 ofldaho 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 ensuring prudent utility investments and in the efficient
ICL'S PETITION TO INTERVENE 1 October 3, 2016
and robust integration of renewable resources to meet our supporters' desire to protect Idaho's
air quality and natural landscapes. Idaho Power's potential participation in the western Energy
Imbalance Market has the potential to achieve both of these goals. ICL will focus on the costs and
benefits ofldaho Power's request to join the EIM and thus our 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.
DA TED this 3rd day of October 2016.
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Benjamin J. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
. I hereby certify that on this 6th day of April 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:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original and seven copies provided)
Electronic Mail:
Idaho Power
Julia A. Hilton
Matt Larkin
Idaho Power Company
P.O. Box 70
Boise, Idaho 83 707
[e-mail]
[e-mail]
[e-mail]
ICL'S PETITION TO INTERVENE 2
ICIP
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83702
[e-mail]
Don Reading
6070 Hill Road
Boise, ID 83703
[e-mail]
Snake River Alliance
Ken Miller
PO Box 1731
Boise, ID 83701
[e-mail]
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Benjamin J. Otto
October 3, 2016