20211115Petition to Intervene.pdf

Benjamin J. otto (lSB No. 8292)
710 N 6th Street
Boise,ID 83701
Ph: (208) 286-44s2
botto @i dahoconservation. org
IN THE MATTER OF ROCKY
MOUNTAIN
POWER'S FILING FOR
ACKNOWLEDGEMENT OF ITS 2021
INTEGRATED RESOURCE PLAN
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Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. PAC-8.2I-I9
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
The Idaho Conservation League ("lCL") 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]
[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
3 r.01.01.063.02-03.
2.The Idaho Conservation League has a direct and substantial interest in this maffer due
to our longstanding engagement in Idaho electricity regulation and our approximately 20
PAC-E-21-19
ICL Petition to Intervene November 15,2021
members who are residential customers of Rocky Mountain Power. This Commission has
consistently granted [CL's lntervention in Rocky Mountain Power dockets so that we can
represent the interests of our members, and our organizational interest, in assuring utility
resource plans set forth a least risk and least cost portfolio of demand and supply side resources
to maintain adequate service, as defined in Idaho Code 6l-302.ICL will respond to RMP's 2021
Integrated Resource Plan 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
31.01.0l.l6l-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this l5s day ofNovember202l.
Respectfully submitted,
/s/ Beniamin J Otto
Idaho Conservation League
PAC-E-21-19
ICL Petition to Intervene November 15,2021
CERTIHCATE OF SERVICE
I certi$ that on the l5th day of November 2021,ldelivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following via the service method noted:
/s/ Beniamin J Otto
Idaho Conservation League
Electronic Mail only:
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
secretary@puc. idaho.gov
Rocly Mountain Power
Ted Weston
Yvonne Hogle
Rocky Mountain Power
ted.weston@pacifi corp.com
yvonnne.hogle@pac ifi corp. com
datarequest@pacifi corp.com
[e-mail]
PAC-E-21-19
ICL Petition to Intervene November 15,2021