20210712Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x lI2
botto@idahoconservation. org
IN THE MATTER OF IDAHO
POWER COMPANY'S
APPLICATION TO INITIATE A
MULTI.PHASE COLLABORATIVE
PROCESS FOR THE STUDY OF
COSTS, BENEFTIS, AND
COMPENSATION OF NET EXCESS
ENERGY ASSOCIATED WITH
CUSTOMER ON.SITE
GENERATION
' .'. - ;2 P,i 2: 55
CASE NO. IPC.E.2I.2I
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
-:: ,.i I1"1I. i
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.
l. The name of this intervenor is
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise, Idaho 83702
Ph: [phone] x 112
botto@idahoconservation. org
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.
IICL PETITION TO INTERVENE
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 9 ldaho
Power customer and our Ketchum field office is a Schedule 7 customer. Idaho Poweros proposal
here directly impacts ICL's ability to ensure equitable treatment of customer-owned energy
systems. ICL's members and supporters want to meet their own energy needs in partnership with
the local utility and this docket provides a direct means to achieve this goal. [CL's intervention
will respond to Idaho Power's 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 flrnding pursuant to
IDAPA 3 1.01.01. I 61-l 6s.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this l2th day of July 2021.
Respectfully submitted,
/s/ Beniamin J Otto
Idaho Conservation League
2ICL PETITION TO INTERVENE
CERTIFICATE OF SERVICE
I hereby certifr that on this 12th day of July 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
[e-mail]. gov
Idaho Power
Lisa D. Nordstom
Connie Aschenbrenner
lnordstrom@idahopower. com
[e-mail]
dockets@idahopower. com
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
dreading@mindspring. com
IdaHydro
C. Tom Arkoosh
Arkoosh Law Offrce
Tom. arkoosh@arkoosh. com
Erin.cecil@arkoosh. com
JICL PETITION TO INTERVENE