20160921Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
and the NW Energy Coalition
l~cCEIVED
ZO l&1:P 21 r ll :\8
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF INTERMOUNTAIN )
GAS COMPANY FOR THE )
AUTHORITY TO CHANGE ITS RATES )
AND CHARGES FOR NAUTRAL GAS )
SERVICE TO NATURAL GAS )
CUSTOMERS IN THE STATE OF )
IDAHO )
CASE NO. INT-G-16-02
PETITION TO INTERVENE
IDAHO CONSERVATION LEAGUE
AND THE NW ENERGY COALITION
COMES NOW the Idaho Conservation League ("ICL") the NW Energy Coalition
"NWEC" and hereby 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 and NWEC have direct and substantial interests in these proceedings, and therefore
should be granted intervention.
1. The name of this intervenor is:
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise, Idaho 83 702
Ph: [phone] x 12
Fax: [phone]
[e-mail]
F. Diego Rivas
NW Energy Coalition
1101 3th Ave
Helena, MT 59601
Ph: [phone]
[e-mail]
Please provide copies of all pleadings, production requests, production responses,
!CL'S PETITION TO INTERVENE 1 September 21 , 2016
Commission orders, and other documents to the names and addresses 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. The Idaho Conservation League and NW Energy Coalition claim a direct and
substantial interest in this proceeding arising from the impact to our members served by
Intermountain Gas and to our long-term role advocating for public values. As Idaho's largest
state-based conservation organization, ICL has approximately 9,500 members, about half of
which are customers of Intermountain Gas. NW Energy Coalition is has more than 110 member
organizations throughout Oregon, Washington, Montana, and Idaho. NWEC claims an interest
in this case on behalf of our 11 organizational members in Idaho. ICL and NWEC have a direct
and substantial interest in expanding of gas conservation in Idaho in order to ensure affordable
gas service for our members while reducing environmental harms attributable to fossil fuel
production and consumption. As the only potential intervenors in this proceeding advocating for
investments, customer incentives, and rate designs specifically intended to fully incentivize gas
conservation, and NWEC participation in similar Public Utilities Commission cases across the
region, we bring a unique and valuable perspective to this proceeding. Because the Idaho
Commission has directed all utilities to pursue all cost effective conservation measures, our
. intervention will not unduly broaden the issues in this proceeding.
3. ICL and NWEC intend to fully participate in this matter as a party. The nature and
quality of our intervention in the proceeding is dependant 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 21st day of September 2016.
!CL'S PETITION TO INTERVENE
Respectfully submitted, t:v~ &-ii:..-'~--
Benjamin J. Otto
On behalf of the Idaho Conservation League
and the NW Energy Coalition
2 September 21 , 2016
CERTIFICATE OF SERVICE
I hereby certify that on this 21st day of September 2016 I delivered true and correct
copies of the foregoing PETITION TO INTERVENE to the following persons via the method of
service noted: ~ ~
Hand delivery:
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original+ 7 copies provided)
Electronic Mail:
INTERMOUNTAIN GAS
Ronald L. Williams
Attorney for Intermountain Gas Company
1015 W. Hays Street
Boise, ID 83702
Phone: [phone]
[e-mail]
Michael P. McGrath
Director, Regulatory Affairs
Intermountain Gas Company
55 S. Cole Road
PO Box 7608
Boise, ID 83 707
Phone: [phone]
[e-mail]
COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
Brad M Purdy
Attorney at Law
2019 N. 171h St.
Boise, ID 83 702
Phone: [phone]
[e-mail]
ICL'S PETITION TO INTERVENE 3
Benjamin J. Otto
NORTHWEST INDUSTRIAL GAS USERS
cl o Edward A Finklea
Executive Director
545 Grandview Drive
Ashland, OR 97520
Phone: [phone]
[e-mail]
Chad M. Stokes
Tommy A Brooks
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Phone: [phone]
[e-mail]
[e-mail]
Michael C. Creamer (ISB No. 4030)
Givens Pursley LLP
601 W Bannock St.
Boise, ID 83 702
Phone: [phone]
[e-mail]
September 21 , 2016