20181031Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
IN THE MATTER OF THE )
APPLICATION OF rDAHO POWER )
COMPANY TO STUDY THE COSTS, )
BENEFTIS, AND COMPENSATION OF )
NET EXCESS ENERGY SUPPLIED BY )
CUSTOMER ON-SITE GENERATION )
Fi[ C E IVED
?ilt8 0[T 3l PH Z:29
SS ON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-I8-15
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
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.
l. The name of this intervenor is:
Benjamin J. Otto
Idaho Conservation League
710 N. 6ft st.
Boise,Idaho 83702
Ph: [phone]x12
Far [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 may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03
IICL PETITTON TO INTERVENE October 31,2018
2. Idaho Conservation League claims a direct and substantial interest in this proceeding
as a customer and on behalf of our members who are customers of Idaho Power and desire
equitable access to clean energy options. As Idaho's largest state-based conservation
organization, we have approximately I1,000 members most of whom are residential customers of
Idaho Power. ICL and our members have a long-standing interest in ensuring utility rates and
programs are fair, just, and reasonable while expanding access to Idaho's clean resource options.
ICL intervention here will focus on the full range of costs and benefits that influence the value
customer-owned generation brings to Idaho Power's system and thus will not unduly broaden
the issues.
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 3 1.01.01. 161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 31st day of October 2018.
Resoectfullv,4 submitted,A-
Benjamin J. Otto
Idaho Conservation League
ICL PETITION TO INTERVENE 2 October 31,2018
CERTIFICATE OF SERVICE
I hereby certiS, that on this 31" day of October, 2018, I delivered true and correct copies
of the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
]ean Iewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,lD 83702-5983
Electronic Mail:
Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
lnordstrom@idahopower. com
ttatum@idahopower. com
caschenbrenner@idahopower. com
[e-mail]
Idaho PUC Staff
Sean Costello
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]. gov
Idahohydro
C Tom Arkoosh
Arkoosh Law Offices
tom. arkoo sh@arkoo sh. com
erin.cecil@arkoosh. com
Idaho lrrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen PLLC
[e-mail]
Anthony Yankel
[e-mail]
Idaho Clean Energt Association
Preston N. Carter
Deborah E. Nelson
Givens Pursley LLC
[e-mail]
den@givenspursley. com
Sierra Club
Kelsey Jae Nunez, LLC
Sierra Club
kelsey@kel seyj aenunez. com
Zack Waterman
Idaho Sierra Club
zack. waterman@sierraclub. org
[e-mail]
City of Boise
Abigail R. Germaine
Deputy City Attomey
agermaine@cityofbo i se. org
Vote Solar
David Bender
Earthjustice
dbender@earthj ustice. com
Briana Kober
Vote Solar
360 22nd Street, Suite 730
Oakland, CA946l2
[e-mail]
JICL PETITION TO INTERVENE October 31,2018
Hand delivery:
Snake River Alliance and NWEC
John R. Hammond, Jr.
Fischer Pusch, LLP
[e-mail]
Wendy Wilson
Executive Director, Snake River Alliance
wwilson@snakeriveralliance. org
Diego Rivas
Policy Associate, NW Energy Coalition
[e-mail]
Intermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Bumett
[e-mail]
[e-mail]
Intermountain Wind and Solar, LLC
doug@imwindandsolar. com
dale@imwindandsolar. comHk-
Benjamin J. Otto
4ICL PETITION TO INTERVENE October 3 l, 2018