20180320Petition to Intervene.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6'h Street
Boise,lD 83701
Ph: [phone]x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
TN THE MATTER OF THE )
APPLICATION OF AVISTA )
CORPORATION, dba AVISTA )
UTILITIES, REQUESTING )
AUTHORITY TO REVISE ITS )
ELECTRIC AND NATURAL GAS BOOK )
DEPRECIATION RATES )
RE C E IVED
?0tB HAR 20 Pt{ t: h2
ii:]:ii{il F'uBLlc
I il1 i-ilrs coFJMtssl0N
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. AVU-E-18-03
AVU-G-r8-02
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
31.01.01.071-073. As discussed below, ICL has direct and substantial interests in these
proceedings, and therefore should be granted intervention.
l. The name of this intervenor is:
Benjamin I. Otto
Idaho Conservation League
710 N. 6'h 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 may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
ICL'S PETITION TO INTERVENE 1 March 20,2018
2.The Idaho Conservation League has a direct and substantial interest in this matter. ICL
is a commercial customer of Avista in our Sandpoint, Idaho field office. ICL also has
approximately 700 current, dues-paying members who are residential customers of Avista. On
our own, and on behalf of our Avista-served members, ICL claims a direct and substantial
interest in this proceeding arising from the potential for book depreciation rates to impact future
electric rates and resource planning. We bring a unique and valuable perspective to this
proceeding due to our interest in aligning depreciation rates with the useful life of resources in
order to ensure the inevitable transition away from legary fossil fuels occurs in an orderly and
economically justified manner. Because we will focus on the appropriate depreciation rates for
certain assets, 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- l6s.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 20'h dayof March2OlT.
Benjamin J. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 March 20,2018
CERTIFICATE OF SERVICE
I certifu that on the 20th day of Mar ch, 2017 , I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following via the service method noted:
Hand delivery:
Diane Hanian
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.
Patrick Ehrbar
Avista Corporation
P.O.Box3727
1411 E. Mission Ave.
Spokane, WA99220-3727
David. meyer@avistaeqpcqnq
[e-mail]
Benjamin I. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE March 20,2018