20150629Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 66 Street
Boise,ID 83701
Ph: [phone] xL2
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF AVISTA
CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO
INCREASE ITS RATES AND
CHANRGES FOR ELECTRIC AND
NATURAL GAS SERVICE IN IDAHO
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. AVU-E-I5-05
AVU-G-1s-01
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
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
31.01.01.07I-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 I. Otto
Idaho Conservation League
710 N. 6th st.
Boise,Idaho 83702
Ph: [phone] xt2
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. [n 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.
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
ICL'S PETITION TO INTERVENE Juneff,2015
public values. As Idaho's largest state-based conservation organization, we have approximately
1,000 members who are residential customers of Avista. ICL's Sandpoint, Idaho office is also a
small commercial customer of Avista. ICL, on behalf of our members, has an interest in
expanding of energy efficienry 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 efficienry 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 3 1.01.01. 161- 165.
WHEREFORE,ICL respectfully requests the Commission grant this petition.
DATED this 29ft day of )une,2Ol5.
Respec;firlly submitted,
Idaho Conservation League
ICL'S PETITION TO INTERVENE Jvnefl,2015
CERTIFICATE OF SERVICE
I certifr that on the 29th day of June,20l5,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
427W. Washington St.
Boise,ID 83702-5983
Electronic Mail only:
Avista Utilities
David f. Meyer, Esq.
Vice President & Chief Counsel,
Regulatory and Government Affairs
KellyO. Norwood
Vice President - State and Federal
Regulation
Avista Corporation
P.O.Box3727
1411 E. Mission Ave.
Spokane, WA99220-3727
David.meyer@avistacorp. com
[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,Id837l6
[e-mail]
Clearwater Paper
Peter I. Richardson
GregoryM. Adams
Richardson & Adams, PLLC
515 N.27th Street
Boise, ID 83702
peter@richardsonadams. com
greg@richardsonadams. com
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
dreading@mindspring. com
b-
CERTIFICATE OF SERVICE
Benjamin I. Otto
June$,2015