20200917Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6ft Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto@idahoconservation. org
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
REVISE THE ENERGY
EFFICIENCY RIDER, TARIFF
SCHEDULE 91
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Attomey for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO.IPC.E.2O.33
PETITION TO INTERVENE OF THE
IDAIIO 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 3 I .01 .01 .07l-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] x 12
Fax: [phone]
botto @idahoconservation. org
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
IPC-E-20-33
ICL'S PETITION TO INTERVENE I September 17,2020
orders, and other filings may be submified 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
as an Idaho Power customer and on behalf of our members served by Idaho Power. As Idaho's
largest state-based conservation organization, we have approximately I1,000 members most of
whom are residential customers of ldaho Power. ICL, as an organization, is a Schedule 9
customer in our Boise office and Schedule 7 customer in our Ketchum office. ICL brings a
unique and valuable perspective to this issue due to our long-term engagement with Idaho Power
and other stakeholders to ensure adequate funding to pursue all cost effective energy
conservation. ICL's intervention will not unduly broaden the issues in this proceeding, other than
connecting this docket to Idaho Power's request to reduce rates connected to the Boardman plant
closure as the Company proposes inlPC-E-20-32.
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 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
rDAPA 3 1.01.01. 161-l 65.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfully submitted this lTth day of September 2020.
/s/.I Ono
Benjamin J. Otto
Idaho Conservation League
rPC-E-20-33
ICL'S PETITION TO INTERVENE 2 September 17,2020
CERTIFICATE OF SERYICE
I hereby certify that on this lTth day of September, 2020,I delivered true and correct
copies of the foregoing PETITION TO INTERVENE to the following persons via the method of
service noted:
/s/ Beniamin J. Otto
Electronic mail onlv (See Order 34602):
Idaho Public Uilities Commission
Jan Noriyuki, Secretary
Jan.noriyuki@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Connie Aschenbrenner
[e-mail]
[e-mail]
dockets@idahopower. com
IPC-E-20-33
ICL'S PETITION TO INTERVENE 3 September 17,2020