20130606Petition to Intervene.pdf

Benjamin I. Otto (lSB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
IN THE MATTER OF PACIFCORP DBA
ROCKY MOUNTAIN POWER'S 2013
INTEGRATED RTSOURCE PLAN
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BEFORI THE IDAHO PUBLIC UTILITIES COMMISSION
) cAsE NO. PAC-E-13-05
)) PETITION TO INTERVENE OF THE
) IDAHO CONSERVATION LEAGUE
The Idaho Conservation League ('ICL") petitions to intervene in the above
captioned matter pursuant to the Idaho Public Utilities Commission Rules of Procedure,
IDAPA 31.01.01.07I-073. As discussed below, ICL has direct and substantial interests in
these proceedings, and therefore the Commission should grant intervention.
1. The name of this intervenor is:
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise,Idaho 83702
Ph: [phone] x12
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 3 1.01.0 1.063.02-03.
ICL'S PETITION TO INTERVENE June 6,2013
2. ICL claims a direct and substantial interest in this proceeding arising from the
impact to its members served by Rocky Mountain Power ("RMP") and to its long-term
role advocating for public values. As Idaho's largest state-based conservation
organization, ICL submits this petition to protect the interest of our hundreds of
members served by RMP and our long-term role advocating for public values. ICL and
our membership have a direct interest in ensuring the Integrated Resource Plan ('IRP")
includes accurate and through analysis of RMP's future resource needs. This IRP is
particularly important as RMP faces substantial investments in transmission, coal plants,
and considering expanding demand-side management activities to achieve the full cost-
effective potential. ICL's intervention will not unduly broaden the issues in this
proceeding, since we will be responding to RMP's plans.
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 advocate for a technical hearing and
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 6th day of )une 2013.
Benjamin J. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE June 6, 2013
CERTIFICATE OF SERVICE
I hereby certiff that on this 6 th day of June, 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:
|ean |ewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Pacificorp
Ted Weston
Yvonne Hogle
Rocky Mountain Power
201 S. Main St., One Utah Center,23rd
Salt Lake City, UT 8411I
Ted.Weston@pacifi corp.com
Yvonne.Hogle@pacifi corp.com
[e-mail]
Data Request Response Center
825 NE Multnomah, Suite 2000
Portland, OR97232
datarequest@pacifi corp.com
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Benjamin J. Otto
Floor
ICL'S PETITION TO INTERVENE June 6,2013