20140915Petition to Intervene.pdf

F. E C [: i\1 i:' 'i
?01[ SEP I 5 AH ll: l+2Benjamin I. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPTICATION OF AVISTA
CORPORATION FOR A FINDING OF
PRUDENCE FOR 2OI3
EXPENDITURES ASSOCIATED WITH
PROVIDING ELECTRIC AND
NATURAT GAS EFFICIENCY SERVICE
IN THE STATE OF IDAHO
AVU-E-14-07
ICL Petition to Intervene
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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.6s st.
Boise,Idaho 83702
Ph: [phone] x12
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 maybe submitted via electronic mail in accordance
with IPUC Rules 3 1.01.01.063.02-03.
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
CASE NO. AW-E-14-07
AVU-E-14-02
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
September 15,2014
Avista. In addition to representing the interest of residential customers, ICL has an
interest in expanding of energy efEciency and conservation by all customer groups in
Idaho. Because of our broad public interest in conserving energy, 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 may seek intervenor
funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE,ICL respectfully requests the Commission grant this petition.
RESPECTFULLY SUBMITTED this 15'h day of Septyb_er 2014,
t2-L44 ,
u*i "-illiot8lrr.*u,ion League
CERTIFICATE OF SERVICE
I certiff that on the 15th day of September 2014,I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following via the service method noted:
Hand delivery:
Iean Iewell
Commission Secretary (Original and
seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail only:
David ]. Meyer, Esq
Linda Gervais
Avista Corporation
l4ll E. Mission Ave.
Spokane, WA99220-3727
David. meyer@avistacorp. com
Linda. gervais@avistacorp. com
AVU-E-14-07
ICL Petition to Intervene
Benjamin I. Otto
September 15,2014