20211105Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto@ idahoconservation. org
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF IDAHO
POWER COMPANY'S
APPLICATION FOR APPROVAL
TO MODIFY ITS DEMAND
RESPONSE PROGRAMS
CASE NO.IPC.EAv!L
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
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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]
[e-mail]
Emma E. Sperry
Idaho Conservation League
710 N. 6e St.
Boise, Idaho 83702
Ph: 208-537 -7993 ext 230
[e-mail]
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the name and address above. [n 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
tPC-E-zt-32
ICL PETITION TO TNTERVENE November 5,2021
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
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 I 1,000 members most of
whom are residential customers of Idaho Power. ICL's Boise headquarters is a Schedule 9ldaho
Power customer and our Ketchum field office is a Schedule 7 customer. ldaho Power's proposed
changes to its Demand Response program directly impact ICL members who are enrolled in
Idaho Power DR programs and who are generally concerned about grid reliability and energy
affordability. ICL's intervention will respond directly to the issues raised in Idaho Power's
application 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 may seek intervenor funding pursuant to IDAPA
3 r.01 .0r. r 61-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 5th day of November,202l
Respectfully submitted,
/s/ Benjamin J. Otto
Benjamin J. Otto
Idaho Conservation League
LPC-E-ZI-32
ICL PETITION TO INTERVENE 2 November 5,2021
CERTIFICATE OF SERVICE
I hereby certiff that on this 5th day ofNovember, 2021,I delivered true and conect
copies of the foregoing PETITION TO INTERVENE to the following persons via the method of
service noted:
/s/ Benjamin J. Otto
Benjamin J. Otto
Electronic mail onlv (See Order 34781):
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
secretary@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Connie Aschenbrenner
[e-mail]
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association
Eric L. Olsen
Echo Hawk & Olsen, PLLC
[e-mail]
Lance Kaufman
AEGIS Insight
lance @ae gi s ins i ght. com
rPC-E-zt-32
ICL PETITION TO INTERVENE 3 November 5,2021