20150204Petition to Intervene.pdf

Benjamin l. Otto (ISB No. 8292)
710 N 6m Street
Boise,ID 83701
Ph: [phone] xt2
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF rDAHO POWER ) casE No. rpc_E_ls_olcoMPANY',S PETITTON TO MODIFY ) -"'
TERMS AND CONDITIONS OF \
PROSPECTIVE PURPA ENERGY SALI ^ . PETITION TO INTERVENE OF THE
AGREEMENTS.
KPA tsNtsKUI JALES
J neTlo CONSERVATION LEAGUE
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 31.01.01.07I-073. As discussed below, ICL has direct and substantial interests
in these proceedings, and therefore should be granted intervention.
l. The name of this intervenor is:
Benjamin I. Otto
Idaho Conservation League
710 N. 6'h st.
Boise, Idaho 83702
Ph: [phone] x12
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
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 Idaho Power and to its long-term role
advocating for public values. As Idaho's largest state-based conservation organization, we have
ICL'S PETITION TO INTERVENE 1 February 4,2015
approximately 25,000 supporters, most of whom are residential customers of Idaho Power. ICL,
as an entity, is a small commercial customer of Idaho Power. ICL and our supporters have an
interest in ensuring Idaho Power's electric system provides reliable, fair-priced service that
protects the clean air, clean water, and stable climate that are foundational public values for
Idahoans. ICL brings a unique and valuable perspective to this proceeding because our members
are customers of Idaho Power who support the development of clean energy resources through
various means, including energy sales agreements between independent developers and Idaho
Power. ICL's intervention will represent our supporters interest in ensuring a fair balance
between fostering Idaho's clean energy resources and ensuring fair prices, and thus 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 eyidence, be heard in argument, and call,
examine, and cross-examine witnesses. ICL intends to seek intervenor funding pursuant to
IDAPA 3 1.01.0 l. 161 - 165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 4th day of February 2015.
Benjamin I. Otto
Idaho Conservation League
[CL'S PETITION TO INTERVENE February 4,2015
CERTIFICATE OF SERVICE
I hereby certiff that on this 4th day of February 2015 I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Hand deliverE
Jean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, lD 83702-5983
Electronic Mail:
Idaho Power
Donovan E. Walker
Lisa A. Grow
RandyAllphin
Idaho Power Company
1221 West Idaho Street
Boise,ID 83702
dwalker@idahop ower. com
[e-mail]
rallphin@idahopower. com
[e-mail]
lR Simplot Company
Peter I. Richardson
GregoryM. Adams
Richardson Adams, PLLC
515 N. 27n St
Boise,ID 83702
[e-mail]
greg@richardsonadams. com
Don Reading
6070 Hill Road
Boise,ID 83703
[e-mail]
Benjamin I. Otto
ICL'S PETITION TO INTERVENE February 4,2015