20180517Petition to Intervene.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6s Street
Boise,ID 83701
Ph: [phone] xtZ
Fax [phone]
[e-mail]
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Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLTCATION OF IDAHO POWER )
COMPANY FOR A DETERMINATION )
oF 2077 DEMAND-SIDE )
MANAGEMENT EXPENSES AS )
PRUDENTLY INCURRED. )
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. 6th 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 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 Schedules 7 andg in our
Ketchum and Boise offices respectively. ICL and our supporters have a substantial interest in
maintaining a robust energy conservation program to avoid burning fossil fuels and the need for
CASE NO. IPC-E-18-03
THE IDAHO CONSERVATION
LEAGUE
PETITION TO INTERVENE
1ICL'S PETITION TO INTERVENE May 17,2018
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 ensuring the ratepayer
dollars spent on DSM activities in2017 produced cost effective, verifiable energF 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 17th day of May 2018.
submitted,
Benjamin I. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 May 17,2018
RespectDllyh,a-
CERTIFICATE OF SERVICE
I hereby certifr that on this 17th day of May 2018, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Benjamin I. Otto
Hand delivery:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original and seven copies provided)
Electronic Mail:
Idaho Power
)uliaA. Hilton
Connie Aschenbrenner
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
[e-mail]
Idaho lrrigation Pumpers Association
Eric L. Olsen
ECHOHAWK & OLSEN, PLLC
505 Preshing Ave., Suite 100
P.O. Box 6119
Pocatello,Idaho 83205
[e-mail]
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
Industrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St
P.O. Box 7218 Boise,Idaho 83702
peter@richardsonadams. com
Dr. Don Reading
6070 Hill Road Boise, Idaho 83703
dr eading@mindspri ng. c om
ICL'S PETITION TO INTERVENE J May 17,2018