20220124Petition to Intervene.pdf

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Benjamin J. otto (lSB No. 8292)
710 N 6ft Street
Boise, ID 83701
Ph: (208) 286-44s2
[e-mail]
[PC-E-zI-43
ICL PETITION TO INTERVENE
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Attorney for the Idaho Conservation League
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF rDArrO ) CASE NO. [PC-E-21-43
POWER COMPAI\TY'S 2021 )
INTEGRATED RESOURCE PLAN. ) PETITION TO INTERVENE OF TIIE
) IDATTO 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 name of this intervenor is:
Benjamin J. Otto
Emma E. Sperry
Idaho Conservation League
710 N. 6th st.
Boise,ldaho 83702
Ph: [phone]
botto@ idahoconservation.org
esperry@i dahoconservation.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.
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 and desire
January 24,2022
reliable, affordable, and clean energy service from the Company. 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 9 ldaho Power
customer. ICL and our members have a long-standing interest influencing the utilities long-term
resource plan in order to maintain reliable and affordable energy while transitioning to clean
sources that protect our air and reinvest our energy dollars in ldaho. ICL intervention here will
focus on the tools and quality of the inputs Idaho Power used in this planning process 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 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 intends to seek intervenor funding pursuant to
IDAPA 3 l.0l.0l.l6l -165.
WHEREFORE,ICL respectfully requests the Commission grant this petition.
DATED this 24th day of January 2022.
Respectfully submitted,
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Benjamin J. Otto
Idaho Conservation League
IPC-E-21-43
ICL PETITION TO TNTERVENE 2
January 24,2022
CERTIFICATE OF SERYICE
I hereby certit/ that on this 24th day of January 2022,I delivered true and correct copies
of the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
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Electronic mail onlv (See Order 35058):
Idoho Public Utilities Commission
Jan Noriyuki, Secretary
secretary@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Timothy E. Tatum
Allison Williams
[e-mail]
ttatum@idahopower. com
awi [e-mail]
[e-mail]
Individual
Kiki Leslie A. Tidwell, pro se
Ktidwell2022@emai l.com
rPC-E-21-43
ICL PETITION TO INTERVENE
Benjamin J. Otto
3
January 24,2022