20210630Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone]x112
botto @idahoconservation. org
IN THE MATTER OF THE
INDUSTRIAL CUSTOMERS OF
IDAHO POWER'S PETITION FOR
AN ORDER TO SHOW CAUSE
IPC-E-21-19
ICL Petition to Intervene
Attomey for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E,-2I.Ig
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]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.
I June 30,2021
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 organization, we have approximately I1,000 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 ensuring compliance with prior Commission orders
regarding the acquisition ofnew energy resources as this docket is a necessary precursor to
future proceeding that will impact customer rates. ICL will respond to the Industrial Customers
of Idaho Power's Petition as well as any response filed by Idaho Power or the Commission Staff
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. l6l-16s.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 30th day of June 2021.
Respectfully submitted,
/s/ Beniamin J Otto
Idaho Conservation League
IPC-E-21-19
ICL Petition to Intervene 2 June 30,2021
CERTIf,'ICATE O[' SERVICE
I hereby certifr that on this 30th day of June 2021,I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
/s/J Otto
Idaho Conservation League
Electronic mail only (See Order 34781):
Idaho Public Utilities Commission
JanNoriyuki, Secretary
[e-mail]. gov
Karl Klien, Director Legal Division
Deputy Attorney General
Idaho Public Utilities Commission
[e-mail]. gov
Idaho Power
Donovan Walker, Senior Counsel
Idaho Power Company
dwalker@idahopower. com
[e-mail]
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
dreading@mindspring. com
IPC-E-21-19
ICL Petition to Intervene J June 30,2021