20200729Petition to Intervene.pdf

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Benjamin J. Otto (ISB No. 8292)
710 N 66 Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
IN THE MATTER OF IDAHO
POWER COMPANY'S
APPLICATION FOR AUTHORITY
TO ESTABLISH TARIFF
SCHEDULE 68,
INTERCONNECTIONS TO
CUSTOMER DISTRIBUTED
ENERGY R.ESOURCES
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Attomey for the Idaho Conservation lrague
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-20-30
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League ("lCL") and hereby requests leave to
intervene in the above captioned matter pursuant to the Idaho Public Utilities Commission Rules
ofProcedure, IDAIA 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. 66 st.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Please provide copies of alI pleadings, production requests, production responses,
Commission orders, and other documents to the name and address above. In the interest of
conserving natual resources, reducing costs, and in accordance with Order No 34602, please all
documents and other materials electronically to the email address above.
ICL PETITION TO INTERVENE July 29, 2020
2. The Idaho Conservation League claims a direct and substantial interest in this
proceeding as a customer and on behalfofour members who are customers ofldaho 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 and we may be impacted by
the details in the proposed Schedule 68. As Idaho's largest state-based conservation organization,
we have approximately 11,000 members most of whom are residential customers of ldaho
Power. Some of these members have customer-owned systems and some of lhese members are
interested in acquiring customer-owned systems in the future. ICL intervention here will focus
on the issues raised by Idaho Power - interconnection rules, smart inverter functions, and the
potential for non-exporting customer-owned systems - and 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 dependent upon the nature and effect ofother evidence in
this proceeding. Ifnecessary 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 petirion.
DATED this 29th day ofJuly 2020.
Respectfu lly submitted,
/s/ B
Benjamin J. Otto
Idaho Conservation League
ICL PETITION TO INTERVENE 2 luly 29,202O
CERTIFICATE OF SERVICE
I hereby certiS that on this 29th day ofJuly, 2020, I delivered Eue and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
/s/ Beniamin Otto
Benjamin J. Otto
Electronic mail only (See Order 34602)
Diane Hanian
Jan Noriyuki
Commission Secretary
[e-mail]. gov
[e-mail]. gov
Idaho Power
Lisa D. Nordstrom
Tim Tatum
Connie Aschenbrenner
[e-mail]
ttatum@idahopower. com
caschenbro:[e-mail]
[e-mail]
3ICL PETITION TO INTERVENE lttly 29,2020