20210217Petition to Intervene.pdf

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., -: l-rJ i? PFI 3: 3trBenjamin J. Otto (ISB No. 8292)
710 N 6s Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto @idahoconservation.org
Attomey for the ldaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
*
IN TIIE MATTER OF THE
APPLICATION OF AVISTA
CORPORATION FOR THE
AUTHORITY TO INCREASE ITS
RATES AI\ID CHARGES FOR
ELECTRIC AI\ID NATURAL GAS
CUSTOMERS IN THE STATE OF
IDAHO
AW-E-2 1 -0 I /AW-G -21-01
ICL'S PETITION TO INTERVENE
CASE NO. AW.E.2I.OI
CASE NO: AVU-G-21-01
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
February 17,2021
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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:
Idaho Conservation League
Benjamin J. Otto -Attorney
Dainee Gibson-Webb - Technical Expert
710 N. 6ft st.
Boise,Idaho 83702
Ph: [phone] x ll2
[e-mail]
[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.
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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 ldaho's largest state-based conservation organization, we have approximately
1,000 members who are residential customers of Avista, both electric and gas. ICL's Sandpoint
ldaho office is a small commercial customer of Avista. ICL as an organization, and on behalf of
our members who are Avista customers, have a direct and substantial interest in ensuring prudent
capital investments and operational spending by Avista along with fair, just, and reasonable
utility rates for customers. ICL brings a unique and valuable perspective to this proceeding by
virtue of our focus on highlighting the full costs and future risks of spending on fossil fueled
generation resources. By responding to Avista's requests for additional revenues and rate
changes 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 l.0l.0l.l6l-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this lTth day of February,2\2l.
Respectfully submitted,
Benjamin J. Otto
Idaho Conservation League
AW-E-2 I -0 I /AVU-G -21 -01
ICL'S PETITION TO INTERVENE 2 February 17,2021
CERTIT'ICATE OF SERVICE
I certify that on the lTth day of February,202l,I served the foregoing PETITION TO
INTERVENE, by emailing a copy thereof, in accordance with Idaho Public Utilities
Commission OrderNo. 34602, to the following:
/s/ Beniamin Otto
Electronic Mail only:
Idoho Public Utilities Commission
Jan Noriyuki
Commission Secretary
secretary@puc. idaho. gov
j an.noriyuki@puc. idaho. gov
John Hammond
Deputy Attorney General
j [e-mail]
Avista Utilities
David J. Meyer, Esq.
Patrick D. Erhbar
[e-mail]
Pat.Ehrbar@avi stacorp.com
[e-mail]
CERTIFICATE OF SERVICE February 17,2021