20210629Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x ll2
botto @idahoconservation. org
IN THE MATTER OF IDAHO
POWER COMPANY'S
APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES FOR
ELETRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE
JIM BRIDGER POWER PLAI\T
CASE NO. IPC-E-21-I7
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
Attorney for the ldaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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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]x112
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
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
LPC-E-2I-17
ICL Petition to Intervene 1 Jwre29,202l
2. 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. As Idaho's
largest state-based conservation orgarization, we have approximately 11,000 members most of
whom are residential customers of Idaho Power. ICL's Boise headquarters is a Schedule 9Idaho
Power customer and our Ketchum field offrce is a Schedule 7 customer. ICL and our members
have a direct and substantial interest in the proper accounting for the cost associated with the Jim
Bridger plant because this will impact customer rates. ICL will respond to Idaho Power's request
to change the financial accounting methods for the recovery of the outstanding Bridger costs and
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 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
IDAPA 3 1.01.01. I 6l-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 29th day of June 2021.
Respectfully submitted,
/s/ Beniamin J Otto
Idaho Conservation League
rPC-E-2t-17
ICL Petition to lntervene 2 Jtne29,202l
CERTIFICATE OF SERVICE
I hereby certiS that on this 2lst day of May 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
Idaho Conservation League
Electronic mail only (See Order 34781):
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
secretary@puc. idatro. gov
Idaho Power
Lisa D. Nordstom
Matt Larkin
lnordstrom@idahopower. com
mlarkin@idahopower. com
dockets@idahopower. com
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
dreading@mindspring. com
rPC-E-zt-17
ICL Petition to Intervene 3 Jwrc 29,2021