20210427Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6tr Street
Boise,ID 83701
Ph: [phone] x ll2
botto @idahoconseryation. org
Attomey for the Idaho Conservation League
BEFORE THE IDAHO PI]BLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPAI\IY'S
APPLICATION FOR A
DETERMINATION OF 2O2O
DEMAI\ID.SIDE MANAGEMENT
EXPENSES AS PRUDENTLY
INCURRED
IPC-E-21-04
ICL'S PETITION TO INTERVENE
CASE NO.IPC.E.zI.O4
PETITION TO INTERVENE OF TTTE
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 rurme of this intervenor is:
Benjamin J. Otto
Idaho Conservation League
710 N. 66 st.
Boise,Idaho 83702
Ph: (208) 34s-6933 x trZ
[e-mail]
Please provide copies ofall 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
advocating for public values. As Idaho's largest state- based conservation organization, we have
I Apil27,202l
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-
eflective 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 may seek intervenor funding pursuant to IDAPA
31.01.01.161-16s.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfully submitted this 27th day of April202l.
/s/ Beniamin J. Otto
Benjamin J. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certiff that on this 27th day of April,2021,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 only (See Order 34602):
Idaho Public Utilrties Commission
Jan Noriyuki, Secretary
secretary@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Connie Aschenbrenner
lnordstrom@idahopower. com
caschenbrenner@idahopower. com
dockets@idahopower. com
IPC-E-21-04
ICL'S PETITION TO INTERVENE
Adam Lowney
McDowell Rackner Gibson PC
[e-mail]
Industrial Customers of ldaho Power
Peter J. Richardson, Richardson Adams
PLLC
peter@richardsonadams. com
Dr. Don Reading
dreading@mindspring. com
2 Apil27,202l