20200710Petition to Intervene.pdf

ICL PETITION TO INTERVENE 1 July 10, 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 IDAHO
POWER COMPANY’S
APPLICATION FOR AUTHORITY
TO MODIFY SCHEDULE 84’S
METERING REQUIREMENT AND
TO GRANDFATHER EXISTING
CUSTOMERS WITH TWO METERS
)
)
)
)
)
)
)
CASE NO. IPC-E-20-26

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
RECEIVED
2020 July 10, PM 1:49
IDAHO PUBLIC
UTILITIES COMMISSION
ICL PETITION TO INTERVENE 2 July 10, 2020
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
2. The 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 fair, just, and reasonable rules governing customer-owned distributed energy systems.
ICL’s Boise headquarters is a Schedule 9 and Schedule 84 customer who currently suffers from
the two-meter rule under review here. As Idaho's largest state‐based conservation organization,
we have approximately 11,000 members most of whom are residential customers of Idaho
Power. While this docket addresses commercial customers, all Idaho Power customers have a
direct and cognizable interest in ensuring fair and reasonable program rules. ICL intervention
here will focus on the issues raised by Idaho Power – metering needs for future, and legacy rate
treatment for existing, Schedule 84 customers 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 31.01.01.161-165.

WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 10th day of July 2020.
Respectfully submitted,
____/s/ Benjamin Otto_________
Benjamin J. Otto
Idaho Conservation League
ICL PETITION TO INTERVENE 3 July 10, 2020
CERTIFICATE OF SERVICE
I hereby certify that on this 10th day of July, 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 Otto_________
Benjamin J. Otto

Electronic mail only (See Order 34602)

Diane Hanian
Commission Secretary
[e-mail]

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

Idaho Irrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen PLLC
[e-mail]

Anthony Yankel
[e-mail]