20130111Petition to Intervene.pdf

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
? JAN ; F;: '
r:.. -)frtr. t) IJTIL fIlE
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF PACIFICOPR DBA
ROCKY MOUNTAIN POWER'S
APPLICATION FOR AUTHORITY TO
CANCEL ELETRCI SERVICE
SCHEUDLE NOS 72 AND 72A
IRRIGATION LOAD CONTROL
TARRIFFS AND APPROVE A NEW
DEMAND SIDE MANAGEMENT
CONTRACT
CASE NO. PAC-E-12-14
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.
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 January 11, 2013
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 arising from the impact to its members served by Rocky Mountain Power and
to its long-term role advocating for public values in Idaho. As Idaho's largest state-based
conservation organization, we have many members who are residential customers of
Rocky Mountain Power. Our supporters look to ICL to represent their substantial
interest in expanding cost-effective energy efficiency and conservation in Idaho. More
specifically in this case, maintaining a long-term, robust demand response program will
avoid burning fossil fuels and additional energy infrastructure both of which meet our
supporters desire to protect Idaho's air quality and natural landscapes. As the only
potential intervenor in this proceeding advocating for investments and programs
intended to fully incentivize energy efficiency and demand response programs, ICL brings
a unique and valuable perspective to this proceeding. Because this Commission has
directed all utilities to pursue all cost effective demand side management measures, ICL's
intervention will not unduly broaden the issues in this proceeding.
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. Depending on the time and
resource expended in this case, 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 11h day of January 2013.
Respectfully submitted,
Benjamin J. Otto
On behalf of the Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 January 11, 2013
CERTIFICATE OF SERVICE
I hereby certify that on this 11th day of January, 2013, 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:
Mark C. Moench
Daniel E. Solander
Ted Weston
PacifiCorp/dba Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
[e-mail]
[e-mail]
[e-mail]
Eric Olsen
Racine, Olsen, Nye, Budge & Bailey,
Chartered
P.O. Box 1391
Pocatello, ID 83204
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
[e-mail]
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey,
Chartered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Fax: [phone]
[e-mail]
Brubaker & Associates
17244 W. Cordova Court
Sunrise, Arizona 85387
Fax: [phone]
[e-mail]
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
Fax: [phone]
[e-mail]
Benj'a'min J. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 3 January 11, 2013