20140804Petition to Intervene.pdf

Benjamin l. Otto (ISB No. 8292)
710 N 6m Street
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF ROKCY
MOUNTAIN POWER REQUESTING
PRUDENCY DETERMINATION ON
DEMAND-SIDE MANAGEMENT
EXPENDITURES
F.ECIlt'i]:: il
20ltr AUG -tr PH 2: 53
uTrLtftfffctffi!$n'oo-
BEFORT THE IDAHO PUBTIC UTILITIES COMMISSION
CASE NO. PAC-E-14-07
PETITION TO INTERVENE
OF THE
IDAHO CONSERVATION LEAGUE
The Idaho Conservation League (ICL) requests leave to intervene in this 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 the Commission should grant intervention.
1. The name of this intervenor is:
Idaho Conservation League
Benjamin I. Otto
710 N. 6'h st.
Boise,Idaho 83702
Ph: [phone] x12
Fax [phone]
[e-mail]
P1ease 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 1.01.01.063.02-03.
ICL'S PETITION TO INTERVENE August 4,2014
2. Idaho Conservation League claims a direct and substantial interest in this
proceeding arising from our long-term role advocating for public values and the impact
to our members served by Rocky Mountain Power. As Idaho's largest state-based
conservation organization, we have hundreds of members who are residential customers
of Rocky Mountain Power. ICL and our members have an interest in ensuring the
prudent administration of energy efficiency programs to mitigate electric bills and protect
Idaho's air,lands, and water. Because this Commission has directed all utilities to pursue
all cost-effective efficiency 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. ICL may to seek intervenor
funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfrrlly submitted this 4'h day of August 2014, ,4/a /
Idaho Conservation League
CERTIFICATE OF SERVICE
I certifr that on the 4th day of August, 2014, I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following persons via the method noted:
Hand delivery:
Jean Iewell
Commission Secretary (Original and seven
copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
2
Electronic Mail:
Ted Weston
Daniel E. Solander
201 South Main, Suite 2300
salt Lake city, uT 8411
ted.weston@pacifi corp.com
daniel.solander@pacifi corp.com
Benj6min J. Otto
ICL'S PETITION TO INTERVENE August 4,2014