20100420Petition to Intervene.pdf

Benjamin Otto
ISB No. 8292
710 N 6th Street
PO Box 844
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservation.org
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Attorney for Idao .conservtion Leage
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF A VISTA CORPORATION DBA A VISTA
UTILIES FOR AUTHORITY TO INCREASE
ITS RATES AND CHARGES FOR ELECTRIC
AND NATURAL GAS SERVICE IN IDAHO
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CASE NO. AVU-E-I0-01
A VU-G-I0-0l
PETION TO INTERVENE
COMES NOW Idao Conservtion League CCeICL") and hereby requests leave to
intervene in the above captioned matter pursuat to the Idao Public Utilties
Commission Rules of Procedure, IDAPA 31.01.01.071-073. As discused below, ICL has
direct and substantial interests in these proceedigs, and therefore should be grted
in terven tion.
1. The name and address of this Intervenor to whom copies of al pleadigs
production requests, production responses, Commission orders and other documents
should be provided is:
Benjamin J. Otto
Idao Conseiytion League
710 N. 6th st.
P.O. Box 844
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
botto~idahoconservtion.org
ICL -- PETITION.TO INTERVENE -- 1
2. Idao Conservtion League clais a direct and substantial interest in this
proceeding arsing from the impact to its members served by Avista and to its long-term
role advocating for public values. As Idao's largest state-based conservtion organiztion,
we have approximately 1,000 members who are residential cusomers of Avista Utilties.
In addition to representing the interes of residential cusomers, ICL ha an interest in
promoting the responsible expansion of energy efficiency and renewable energ in Idao.
As the only potential intervenor in this proceedig advocating for investments, rate
designs, and rate spreads specificaly intended to fully incentivie energy efficiency and
conservtion, ICL brigs a unique and vauable persctive to thi proceedig. Because this
Commission ha diected al utilties to purue al cost effective effciency and conservation
measures, ICL's intervention wi not unduly broaden the issues in this proceedig.
3. ICL intends to fuly participate in this matter as a pary, and if necessary, may
introduce evidence, be heard in arguent and cal, examine and crossexamine witnesses
as may be relevat in this matter. The nature and quaity of ICL's intervention in the
proceedig is dependat upon the nature and effect of other evidence in this proceedig.
ICL intends to seek intervenor funding pursuat to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfuly requests that the foregoing petition to intervene be
grted.
DATED this 20th day of Apri 2010.
ReaubmiUed~~..
Benjamin J. Otto
On behaf of the Idao Conservation League
ICL -- PETITION TO INERVENE -- 2
CERTIFICATE OF SERVICE
I hereby certify that on thi 20th day of Apri, 2010, true and correct copies of the
foregoing PETITION TO INTERVENE were delivered to the followig persons via the
method of servce noted:
Hand delivery
Jean Jewell
Commission Secretar (Origial and seven copies provided)
Idao Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
U.S. Mai:
David J. Meyer, Esq.
Vice President and chief counsel
For Reguatory and Government Affais
AVISTA Utilties
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
Kelly Norwood
Vice President, State and
Federal Reguation
A VISTA Utilties
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
ICL -- PETITION TO INTERVENE -- 3
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Benjamin J. Otto
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