20190717Petition to Intervene.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6ft Street
Boise,ID 83701
Ph: [phone] x12
Far [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE )
APPLICATION OF AVISTA )
CoRPORATION FOR THE )
EXTENSION OF AVISTA,S ELECTRIC )
AND NATURAL GAS FIXED COST )
ADIUSTMENT MECHANIMS IN THE )
STATE OF IDAHO )
P,TO E IVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASENO. AVU-E-19-06
CASE NO. AVU-FTS-OA
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.
1. The name of this intervenor is
Benjamin I. Otto
Idaho Conservation League
710 N. 6m 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.
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. ICL's Sandpoint Idaho office is a small
CERTIFICATE OF SERVICE July 16,2019
commercial customer of Avista. ICL as an organization, and on behalf of our members who are
Avista customers, has a direct and substantial interest in maintaining rate mechanisms that
support Avista's pursuit of all cost-effective energy conservation. ICL brings a unique and
valuable perspective to this proceeding by virtue of years-long engagement, on behalf of the
residential and small commercial customers we represent, in the negotiations and settlements
that led to the adoption and continuation of the Fixed Cost Adjustment mechanism By
responding to Avista's requests to extend the FCA mechanism, 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 31.01.01.161-16s.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this l7m day of luly,20l9.
submitted,
Benjamin J. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I certifr that on the lTth day of fuly,20I9,I delivered
PETITION TO INTERVENE to the following via the
true and correct copies of the foregoing
service method noted:
Hand deliverv:
Diane Hanian
Commission Secretary (Original and
seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
CERTIFICATE OF SERVICE
Benjamin I. Otto
Idaho Conservation League
Electronic Mail only:
Avista Utilities
David l. Meyer, Esq.
Patrick D. Erhbar
Avista Corporation
David.meyer@avistacorp. com
Pat.Ehrbar@avistacorp. com
AvistaDockets@avistacorp. com
July 16,2079