20120813Petition to Intervene.pdf

RECEIVED
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
P0 Box 844
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for Idaho Conservation League
20I2AUGI3 PM 2:15
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UTIL11I- COMMISSO
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF AVISTA )
CORPORATION REQUESTING ) CASE NO. AVU-E-12-07
APPROVAL TO DECREASE ITS ENERGY ) AVU-G-12-06
EFFICIENCY PUBLIC PURPOSE RIDER )
SCHEDULES 91 AND 191 )
PETITION TO INTERVENE
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 and address of this Intervenor to whom copies of all pleadings
production requests, production responses, Commission orders and other documents
should be provided is:
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
[e-mail]
ICL -- PETITION TO INTERVENE --1
2. Idaho Conservation League claims a direct and substantial interest in this
proceeding arising from the impact to its members served by Avista and to its long-term
role advocating for public values. As Idaho's largest state-based conservation
organization, we have approximately 1,000 members who are residential customers of
Avista in Idaho. In addition to representing the interest of residential customers, ICL has
an interest in promoting the responsible expansion of energy efficiency in Idaho. As the
only potential intervenor in this proceeding advocating for specifically for residential
customers, ICL brings a unique and valuable perspective to this proceeding.
This intervention petition is timely. As of August 13, 2012, the filing date of this
Petition, the Commission has not established an intervention deadline for this case.
Because this Commission has directed all utilities to pursue all cost effective
efficiency 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, and if
necessary, may introduce evidence, be heard in argument and call, examine and cross-
examine witnesses as may be relevant in this matter. The nature and quality of ICL's
intervention in the proceeding is dependant upon the nature and effect of other evidence
in this proceeding. ICL may seek intervenor funding pursuant to IDAPA 31.01.01.161-
165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 13th day of August 2012.
Respect submitted, Ze
Benjamin J. Otto
Idaho Conservation League
ICL -- PETITION TO INTERVENE --2
CERTIFICATE OF SERVICE
I hereby certify that on this 13th day of August, 2012, true and correct copies of
the foregoing PETITION TO INTERVENE were delivered to the following persons via the
method of service noted:
Hand delivery:
Jean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Email-9 pl-
David J. Meyer, Esq.
Vice President and chief counsel
For Regulatory and Government Affairs
Avista Corporation
P.O. Box 3717
1411 E. Mission Ave. MSC-13
Spokane, WA 99220-3727
[e-mail]
Bruce Folsom
Senior Manager, Energy Efficiency
Avista Corporation
P.O. Box 3717
1411 E. Mission Ave. MSC-15
Spokane, WA 99220-3727
[e-mail] a ~ I ~-- - -
Benjamin J. Otto
ICL - CERTIFICATE OF SERVICE