20141002Petition to Intervene.pdf

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?0lE 0CT -2 Al{ 9: 2l+Benjamin I. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] xt?
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF PACIFICORP DBA
ROCKY MOUNTAIN POWER FOR
AUTHORITY TO MAKE REVISIOSN
TO ITS ETECTRIC SERVICE
SCHEDUTE I55, AGRICULTURAT
ENERGY SERVICES
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-T4-08
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 J. Otto
710 N.6'h st.
Boise,Idaho 83702
Ph: [phone] xt2
Fax [phone]
botto @idahoconservation. org
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 1.01.01.063.02-03.
October 1,2014ICL'S PETITION TO INTERVENE I
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 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.
Respectfully submitted this 2nd day of October 2014,fr.-
Beiriamin J. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I certifr that on the 2nd day of October,2014, I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following persons via the method noted:
Hand deliverE Electronic Mail:
Jean Iewell Ted Weston
Commission Secretary (Original and seven Daniel E. Solander
copies provided) 201 South Main, Suite 2300
Idaho Public Utilities Commission Salt Lake City, UT 8411
427 W. Washington St. [e-mail]
Boise, lD 83702-5983 [e-mail]
Benjamin I. Otto
[CL'S PETITION TO INTERVENE 2 October 1,2014