20200423Petition to Intervene.pdf

IPC-E-20-15
ICL’S PETITION TO INTERVENE 1 April 23, 2020
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 League

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A DETERMINATION
OF 2019 DEMAND-SIDE
MANAGEMENT EXPENSES AS
PRUDENTLY INCURRED.
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CASE NO. IPC-E-20-15

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.
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]

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.
2. Idaho Conservation League claims a direct and substantial interest in this proceeding
arising from the impact to its members served by Idaho Power and to its long-term role
RECEIVED
2020 April 23,PM3:23
IDAHO PUBLIC
UTILITIES COMMISSION
IPC-E-20-15
ICL’S PETITION TO INTERVENE 2 April 23, 2020
advocating for public values. As Idaho's largest state‐based conservation organization, we have
approximately 11,000 members most of whom are residential customers of Idaho Power. ICL, as
an organization, is a Schedule 9 customer in our Boise office and Schedule 7 customer in our
Ketchum office. On behalf of our members, ICL has consistently engaged with Idaho Power and
other stakeholders to shape the Company’s Demand Side Management programs in order to
protect the interests of ensuring affordable energy bills and the continued pursuit of all cost-
effective energy conservation. Because this Commission has directed all utilities to pursue all
cost-effective energy 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. 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 31.01.01.161-165.

WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfully submitted this 23rd day of April 2020.
____/s/ Benjamin J. Otto_____
Benjamin J. Otto
Idaho Conservation League
IPC-E-20-15
ICL’S PETITION TO INTERVENE 3 April 23, 2020
CERTIFICATE OF SERVICE
I hereby certify that on this 23rd day of April, 2020, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
____/s/ Benjamin J. Otto_____

Electronic mail only (See Order 34602):
Idaho Public Utilities Commission
Diane Hanian, Secretary
[e-mail]

Idaho Power
Lisa D. Nordstrom
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson, Richardson Adams PLLC
[e-mail]

Dr. Don Reading
[e-mail]

Idaho Irrigation Pumpers Association
Lynn Tominaga
Eric L. Olsen, Echohawk & Olsen PLLC
[e-mail]

Tony Yankle
[e-mail]