20210629Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: [phone] x ll2
botto @idahoconservation. org
IN THE MATTER OF'THE
APPLICATION OF ROCKY
MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS
RATES AI\[D CHARGES IN IDAHO
AND APROVAL OF PROPOSED
ELETRIC SERVICE SCHEDULES
AND REGULATIONS
CASE NO. PAC.E.2I.O7
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
'I Fla, r.. - *l
i ,t d. .i d
Afforney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The ldaho Conservation League ("ICL") hereby petitions 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.
l. The name of this intervenor is
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise,Idaho 83702
Ph: [phone] x ll2
botto@idahoconservation. org
Please provide copies ofall 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 .0 I .0 1 .063 .02-03.
PAC-E-21-07
ICL Petition to lntervene Jwre29,202l
2. The Idaho Conservation League has a direct and substantial interest in this matter due
to our longstanding engagement in Idaho electricity regulation and our approximately 20
members who are residential customers of Rocky Mountain Power. This Commission has
consistently granted ICL's Intervention in Rocky Mountain Power dockets so that we can
represent the interests of our members, and our organizational interest, in assuring utility
maintains adequate service, as defined in Idaho Code 61-302,and,utility rates are just and
reasonable as required by Idaho Code 6l-301. ICL will respond to RMP's proposal and thus our
intervention here will not unduly broaden the issues raised by RMP's Application.
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-r65.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 296 day of June 2021.
Respectfully submitted,
/s/ Beniamin J Otto
Idaho Conservation League
PAC-E-21-07
ICL Petition to lntervene Jwrc 29,2021
CERTIFICATE OF SERVICE
I certifr that on the 29th day of June 2021,I delivered tme and correct copies of the foregoing
PETITION TO INTERVENE to the following via the service method noted:
/s/ Beniamin J Otto
Idaho Conservation League
Elechonic Mail onl]r:
Idaho Public Utilittes Commission
Jan Noriyuki
Commission Secretary
secretary@puc. idaho. gov
Roclqt Mountain Power
Ted Weston
Emily Wegner
Mathew D. McVee
Rocky Mountain Power
ted.weston@pacifi corp.com
Ernily.weener@pacifi corp.com
Mathew. m cv ee @pacifi corp. com
Idaho lrrisation Pumpers Association
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
[e-mail]
Anthony Yankel
[e-mail]
Bqver Corporation
Randall C. Budge
Thomas J. Budge
Racine Olson, PLLP
randy@rac ineolson. com
tt sen.col11
James R. Smith
Mike Veile
P4 Production, L.L.C.
Jim.r. [e-mail]
[e-mail]
PAC-E-21-07
ICL Petition to Intervene
P acificorp ldaho Industrial Customers
Ronald L. Williams
Williams Bradbury, P.C.
ron@willi amsbradbury.corn
Bradley Mullins
MW Analytics, Energy & Utilities
brmullins@mwanalvtics. com
Val Steiner
Itafos Conda, LLC
V al. steiner@itafo s. c om
Kyle Williams
BYU Idaho
[e-mail]
Adam Gardner
Idahoan Foods
AGardener@ idahoan. com
Jvne29,202l