20130322Petition to Intervene.pdf

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Benjamin J. Otto (ISB No. 8292)
710 N. 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for Idaho Conservation League
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER TO ) CASE NO. PAC-E-13-04
INITIATE DISCUSSIONS WITH )
INTERESTED PARTIES ON ) PETITION TO INTERVENE
ALTERNTATIVE RATE PLAN )
PROPOSALS )
COMES NOW the Idaho Conservation League ("ICL") requesting 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 the Commission should grant this petition.
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, Commission
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
PETITION TO INTERVENE 1 March 22, 2013
2.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[.]" IDAPA 3 1.01.01.074. As Idaho's largest
state-based conservation organization, the Idaho Conservation League submits this petition to
protect the interest of our members served by Rocky Mountain Power and our long-term role
advocating for public values. As the only potential intervenor in this proceeding focused
primarily on advocating for investments, policies, and rate designs specifically intended to fully
incentivize energy efficiency and conservation, ICL brings a unique and valuable perspective to
this proceeding. Because this Commission has directed Idaho utilities to pursue all cost effective
energy efficiency and conservation measures, ICL's intervention will not unduly broaden the
issues in this proceeding. The "Alternative Rate Plan" mentioned in RP's application might
implicate all of these issues. Only by gaining status as a party to this proceeding can ICL fully and
fairly represent its direct and substantial interests in this proceeding.
3.ICL intends to fully participate in this matter as a party, and if necessary, may
introduce evidence, be heard in argument and call, examine, and cross-examine witnesses as may
be relevant in this matter. The nature and quality of ICL's intervention in the proceeding is
dependant upon the nature and effect of other evidence in this proceeding. ICL may seek
intervenor funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant the foregoing petition.
DATED this 22nd day of March 2013.
Respectfully submitted,
Benjamin J. Otto
Idaho Conservation League
PETITION TO INTERVENE 2 March 22, 2013
CERTIFICATE OF SERVICE
I hereby certify that on this 22nd day of March 2013, I delivered true and correct copies
of the foregoing PETITION TO INTERVENE to the following 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 Only:
Rocky Mountain Power
Daniel E. Solander
Ted Weston
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
danie1.solanderpacificorp.com
[e-mail]
Community Action Partnership Associations
of Idaho
Brad M. Purdy
Attorney At Law
2019 N. 17thst
Boise, Id 83702
Ph: 208-384-1299
Fax: [phone]
[e-mail]
Benjamin J. Otto
PETITION TO INTERVENE 3 March 22, 2013