20121030Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
20120C130 PM 3:12
'J UTILITIES ' ii
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF AVISTA ) CASE NO. AVU-E-12-08
CORPORATION DBA AVISTA ) AVU-G-12-07
UTILITIES FOR AUTHORITY TO )
INCREASE ITS RATES AND ) PETITION TO INTERVENE OF THE
CHANRGES FOR ELECTRIC AND ) IDAHO CONSERVATION LEAGUE
NATURAL GAS SERVICE IN IDAHO )
The Idaho Conservation League ("ICL") 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 J. Otto
Idaho Conservation League
710 N. 6th st.
Boise, Idaho 83702
Ph: [phone] x 12
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.
ICL'S PETITION TO INTERVENE 1 October 30, 2012
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 addition to representing the interest of residential customers, ICL has an
interest in expanding of energy efficiency and conservation by all customer groups in
Idaho. As the only potential intervenor in this proceeding advocating for investments,
rate designs, and rate spreads specifically intended to fully incentivize energy 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 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. 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 intends to seek
intervenor funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 30 day of October, 2012.
Respectfully submitted,
Benjamin J. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 October 30, 2012
CERTIFICATE OF SERVICE
I certify that on the 30th day of October, 2012, I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following via the service method noted:
Hand delivery:
Jean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail only:
Avista Utilities
David J. Meyer, Esq.
Vice President & Chief Counsel,
Regulatory and Government Affairs
Kelly 0. Norwood
Vice President - State and Federal
Regulation
Avista Corporation
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
[e-mail]
[e-mail]
Idaho Forest Group, LLC
Dean J. Miller
McDevitt & Miller, LLP
P.O. Box 2564
Boise, ID 83701
[e-mail]
Larry A Crowley
The Energy Strategies Institute
5549 Cliffsedge Avenue
Boise, Id 83716
[e-mail]
Clearwater Paper
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27th Street
Boise, ID 83702
[e-mail]
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
[e-mail]
Benjamin J. Otto
CERTIFICATE OF SERVICE October 30, 2012