20160122Petition to Intervene.pdf

Benjamin l. otto (ISB No. s2g2) i{f f;fi l'i" jl::
710 N 6'h Street
Boise, rD 83701 Z0l$ JAH ZZ pt{ L: tr5
Ph: [phone] xt2
Fax [phone] rJTrli?iijlc.r',:,l,s'ii$si,-.,.i
botto @idahoconservation. org
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY MOUTAIN
POWER FOR AUTHORITY TO
INCREASE SCHEDULES T9I _
CUSTOEMR EFFICIENCY SERVICES
RATE
CASE NO. PAC-E-16-02
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League (*ICL") and hereby requests 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 therefore should be granted intervention.
1. The name of this intervenor is:
Benjamin I. Otto
Idaho Conservation League
710 N. 6'h st.
Boise,Idaho 83702
Ph: [phone] xt2
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.
2. Idaho Conservation League claims a direct and substantial interest in this proceeding
arising from the impact to its members served by Rocky Mountain Power and to its long-term
role advocating for public values. As Idaho's largest state-based conservation organization, we
ICL'S PETITION TO INTERVENE I January 22,2016
have approximately
-
members who are residential customers of Rocky Mountain Power.
ICL and our members have an interest in expanding of energy efficiency and conservation in
Idaho. As the only potential intervenor in this proceeding advocating for investments, rate
designs, and rate spreads specifically intended to fully incentivize energF efficiency and
conservation, ICL brings a unique and valuable perspective to this proceeding. Because this
Commission has directed all utilities to pursue all cost effective efficienry and conservation
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 seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 22nd day of 2016.
Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I certifr that on the 22nd day of fanuary 2016,I delivered true and correct copies of the foregoing
PETITION TO INTERVENE to the following persons via the method noted:
Hand delivery:
fean fewell
Commission Secretary (Original and seven
copies provided)
Idaho Public Utilities Commission
427W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Ted Weston
Michael Snow
Daniel E. Solander
201 South Main, Suite 2300
Salt Lake City, UT 8411
ted.weston@pacifi corp.com
micheal.snow@pacifi corp.com
daniel.solander@pacifi corp.com
datarequest@pacifcorp. com
Respectfully submitted,
Benjamin J. Otto
ICL'S PETITION TO INTERVENE January 22,2016