20191218Petition to Intervene.pdf

rdaho Public Utilities Commission
Office of lhe SecrotaryBECEIVED
DEC t8 20t9
Boise, ldaho
Benjamin J. Otto (lSB No.8292)
710 N 66 Street
Boise, ID 83701
Ph: [phone]x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
INTHEMATTEROF
INTERMOT]NTAIN GAS COMPANY'S
2019.2023 INTEGRATED RESOURCE
PLAN
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASENO. INT-G-T9-07
PETITION TO INTERVENE
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League ("ICL") 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 has a direct and substantial
interests in these proceedings, and therefore should be granted intervention.
L The name of this intervenor is:
Benjamin J. Otto
Matt Nvkiel
Idaho Conservation League
710 N. 6s st.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
[e-mail]
[e-mail]
Please provide copies ofall documents in this proceeding to the names and addresses
above. In the interest ofconserving natural resources and reducing the costs to all parties, please
provide hard copies ofpleadings, testimony, and briefs only. Production requests, respenses,
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 claims a direct and substantial interest in this
proceeding as a customer, on behalfour members served by Intermountain Gas, and based on
our long-term role advocating for public values. ICL's Boise headquarters is a customer of
Intermountain Gas. As Idaho's largest state-based conservation organization, ICL has
approximately 11,000 members, about half of which are customers of Intermountain Gas. ICL
has a direct and substantial interest in ensuring Intermountain's long-term resource plan
1ICL'S PETITION TO INTERVENE December 18,2019
develops a least cost, least risk portfolio ofoptions that takes full advantage of demand-side
measures before building additional supply-side capacity. We have a firrther interest in ensuring
Intermountain Gas engages with all types of customers instead of relying primarily on employees
of economic development associations for planning advice. Because the Idaho Commission has
directed all utilities, when developing long-term plans, to rely on meaningfhl public participation
and to pursue all cost-effective conservation measures before pursing supply-side options, ICL's
our intervention will not unduly broaden the issues.
3. ICL intends 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 ofother evidence in this
proceeding. Ifnecessary, we may seek discovery, introduce evidence, be heard in argument, and
call, examine, and cross-examine witnesses. ICL may seek intervenor funding pursuant to IDAPA
31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfully submitted this 18th day of December 2019,
Benjamin ]. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certifr that on this 18th day of December 2019 I delivered true and correct copies
of the foregoing PETITION TO INTERVENE to the foll ons via the method of service
noted:
owmg persa
#!lo"r,u"*,
Idaho Public Utilities Commission
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
(Original + 7 copies provided)
Benjamin J. Otto
Electronic lr4ail:
Int er fi o untain Gas Comp any
Preston N. Carter
Givens Pursley LLP
[e-mail]
[e-mail]
Lori A. Blattner
Director - Regulatory Affairs
Intermountain Gas Company
[e-mail]
December 18,2019ICL'S PETITION TO INTERVENE 2