20120601Petition to Intervene.pdf

RECEIVE!)
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
DAHO PUELK. UTILITIES COMMISSIOi\
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY ) CASE NO. PAC-E-12-11 MOUNTAIN POWER FOR )
AUTHORITY TO DECREASE THE ) PETITION TO INTERVENE OF THE CUSTOMER EFFICIENCY SERVICES ) IDAHO CONSERVATION LEAGUE RATE )
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] x 12
Fax: [phone]
[e-mail]
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,
ICL'S PETITION TO INTERVENE 1 June 1, 2012
Commission orders, and other filings may be submitted via electronic mail in accordance
with IPUC Rules 31.01.01.063.02-03.
2.Although the Notice of Application indicates this proceeding will use Modified
Procedure, the Commission should grant ICUs petition. The Rules of Procedure state the
Commission "will grant intervention" when a petitioner "shows a direct and substantial
interest in any part of the subject matter of a proceeding and does not unduly broaden the
issues[.J" IDAPA 31.01.01.074. Rocky Mountain Power's Application initiates a formal
proceeding. IDAPA 31.01.01.25 and 51 - 52. ICL submits this petition in order to gain a
right to discovery and a right to participate in any potential settlement negotiations,
hearings, or arguments that may occur. IDAPA 31.01.01.038 and 222. Only by gaining
status as a party to this proceeding can ICL fully and fairly represent its direct and
substantial interests in this proceeding described in the following paragraph.
3.The Idaho Conservation League claims a direct and substantial interest in this
proceeding arising from the impact to its members served by Rocky Mountain Power and
to its long-term role advocating for public values. As Idaho's largest state-based
conservation organization, we have approximately many supporters who are residential
customers of Rocky Mountain Power. In addition to representing the interest of
residential customers, ICL has an interest in expanding energy efficiency and conservation
in Idaho. Rocky Mountain Power's proposal to reduce energy efficiency funding directly
effects this interest. As the only potential intervenor in this proceeding advocating for
investments specifically intended to fully incentivize energy efficiency and conservation,
ICL brings a unique and valuable perspective to this proceeding Because this Commission
ICL'S PETITION TO INTERVENE 2 June 1, 2012
has directed all utilities to pursue all cost effective efficiency and conservation measures,
ICL's intervention will not unduly broaden the issues in this proceeding.
4. 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 may seek intervenor
funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 1 day of June 2012.
Respeu11y submitted,
Benjamin J. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 3 June 1, 2012
CERTIFICATE OF SERVICE
I hereby certify that on this 1 ' day of June, 2012, I delivered true and correct copies
of the foregoing PETITION TO INTERVENE to the following persons via the method of
service noted:
Hand delivery
Jean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Ted Weston, Manager of Idaho Regulatory Affairs
Daniel E. Solander, Senior Counsel
PacifiCorp/dba Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
[e-mail]
[e-mail]
Benjamin J. Otto
ICL'S PETITION TO INTERVENE 4 June 1, 2012