20230314Petition to Intervene.pdf

IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01 Page 1
Idaho Conservation League & NW Energy Coalition, Petition to Intervene
Marie Callaway Kellner (ISB No. 8470)
710 N 6th Street
Boise, ID 83701
[phone]
[e-mail]
Attorney for the Idaho Conservation League

F. Diego Rivas (MT State Bar No. 68806741, pro hac vice admission pending)
1101 8th Ave
Helena, MT 59601
[phone]
[e-mail]
Attorney for the NW Energy Coalition

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE
APPLICATION AVISTA
CORPORATION FOR THE
AUTHORITY TO INCREASE ITS
RATES AND CHARGES FOR
ELECTRIC AND NATURAL GAS
SERVICE FOR ITS ELECTRIC
AND NATURAL GAS CUSTOMERS
IN IDAHO
)
)
)
)
)
)
)
)
)
CASE NO. AVU-E-23-01;
AVU-G-23-01

PETITION TO INTERVENE

IDAHO CONSERVATION LEAGUE
AND NW ENERGY COALITION

COMES NOW the Idaho Conservation League (“ICL”) and the NW Energy Coalition
(“NWEC”) and hereby requests leave to intervene in the above captioned matter to pursuant to
the Idaho Public Utilities Commission Rules of Procedure, IDAPA 31.01.01.071-073. As
discussed below, ICL and NWEC have direct and substantial interests in these proceedings, and
therefore should be granted intervention.
1. The name of this intervenor is:

Marie Callaway Kellner
Attorney for the Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]
RECEIVED
2023 March, 14 1:31PM
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01 Page 2
Idaho Conservation League & NW Energy Coalition, Petition to Intervene

F. Diego Rivas
Attorney for the NW Energy Coalition
1101 8th Ave
Helena, Montana 59601
Phone: [phone]
Email: [e-mail]

Please provide copies of all pleadings, production requests, production responses, Commission
orders, and other documents to the names and addresses above. Please provide the same
documents to the following:

Brad Heusinkveld
Idaho Conservation League, Energy Associate
710 N. 6th St.
Boise, Idaho 83702
Phone: [phone]
Email: [e-mail]

In the interest of reducing costs to all parties, pleadings, testimony, briefs, production
requests, responses, notices, Commission orders, and other filings may be submitted via
electronic mail in accordance with Idaho Public Utilities Commission Rule 31.01.01.063.02-03.
ICL and NWEC reserve the right to request hard copies of papers and documents, as may be
necessary with appropriate notice and time.
2. Idaho Conservation League and NW Energy Coalition claim a direct and substantial
interest in this proceeding on behalf of our members who are customers of Avista Corporation.
As Idaho’s largest state-based conservation organization, ICL has approximately 11,000
members, many of whom are residential customers of Avista. ICL represents its organizational
interest, the interests of its members generally, and those who are customers within the
Company’s service territory. NWEC has over 100 organizational members throughout Idaho,
Montana, Washington, and Oregon. NWEC claims an interest in this case on behalf of its eleven
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01 Page 3
Idaho Conservation League & NW Energy Coalition, Petition to Intervene
member organizational members in Idaho. As a result, ICL and NWEC and their members have
a direct and substantial interest in ensuring that Avista Corporation provides a fair rate structure
that does not unduly burden residential and small commercial customers, and those interested in
energy savings and conservation. The Commission has consistently granted ICL’s intervention in
Avista dockets on similar grounds. The NW Energy Coalition has also intervened in other utility
dockets in Idaho on these grounds. ICL and NWEC’s intervention will respond directly to the
issues raised in the Company’s application and will not unduly broaden the scope of the issues or
this proceeding. Joint intervention is intended to limit duplicative filings and efforts.
3. ICL and NWEC intend to fully participate in this matter as a party. The nature and
quality of ICL’s intervention in this proceeding is dependent upon the nature and effect of other
evidence in this proceeding. If necessary, we may introduce evidence, be heard in argument, and
call, examine, and cross-examine witnesses. ICL and NWEC may seek intervenor funding
pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL and NWEC respectfully request the Commission grant this petition.

DATED this 14th of March 2023.

Respectfully submitted

/s/ Marie Callaway Kellner
Marie Callaway Kellner (ISB No. 8470)
Attorney for Idaho Conservation League

/s/ F. Diego Rivas
F. Diego Rivas (MT State Bar No.
68806741, pro hac vice admission pending)
Attorney for NW Energy Coalition

IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01 Page 4
Idaho Conservation League & NW Energy Coalition, Petition to Intervene
CERTIFICATE OF SERVICE
I hereby certify that on this 13th day of March, 2023, I delivered true and correct copies of
the foregoing PETITION TO INTEVENE to the following persons via the method of service
noted:

/s/ Marie Callaway Kellner

Marie Callaway Kellner (ISB No. 8470)
Attorney for the Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
[e-mail]

Electronic Mail Only (See Order No.
35058):

Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
[e-mail]
[e-mail]

Commission Staff
Dayne Hardie
Claire Sharp
Chris Burdin
Deputy Attorneys General
Idaho Public Utilities Commission
[e-mail]
[e-mail]
[e-mail]

Avista Corporation
David J. Meyer
P.O. Box 3727
1411 W. Mission Ave
Spokane WA, 99220
[e-mail]

Clearwater Paper
Peter Richardson
Richardson Adams PLLP
515 N. 27th St.
Boise ID, 83702
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Dr. Don Reading
280 Silverwood Way
Eagle ID, 83616
[e-mail]

Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 W. Main St, Suite 1300
Boise ID, 83702
[e-mail]

Justina A. Caviglia
Parsons Behle & Latimer
50 W. Liberty St., Suite 750
Reno NV, 89502
[e-mail]
IDAHO PUBLIC UTILITIES COMMISSION, Case No. AVU-E-23-01; AVU-G-23-01 Page 5
Idaho Conservation League & NW Energy Coalition, Petition to Intervene

Steve W. Chriss
Walmart Inc.
2608 SE J St.
Bentonville AR, 72716
[e-mail]

Idaho Forrest Group
Elijah M. Watkins
Stoel Rives LLP
101 S. Capitol Blvd., Suite 1900
Boise ID, 83720
elijah.watkins@stoel .com

Andrew P. Moratzka
Stoel Rives LLP
33 S. Sixth St, Suite 4200
Minneapolis, MN 55402
andrew.moratzka @stoel.com