20200310Petition to Intervene.pdf

Benjamin I. Otto (ISB No. 8292)
710'N 6ft Street
Boise,ID 83701
Ph: [phone]xt2
Fax [phone]
b otto@idaho conservation.org
Attorney fgr the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF INTERMOIJNTAIN
GAS COMPANY FOR AUTHORITY TO
REVISE ITS GENERAT SERVICE
PROVISIONS REIATED TO THE
INSTALLATION AND EXTENSION OF
NATURAL GAS MAINS AND
SERVICES
ilE{lElyED
j?C I'i.l,n I C Ptl l: L I
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASENO. INT-G-20-01
PETITION TO INTERVENE
IDAHO CONSERVATION TEAGUE
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.
1. The name of this intervenor is:
Benjamin J. Otto
Idaho Conservation League
710 N.6ft st.
Boise,Idaho 83702
Ph: [phone]x72
Fax [phone]
botto @idahoconservation. org
Please provide copies of all documents in this proceeding 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 3 1.01.01.063.02-03.
2. The Idaho Conservation League claims a direct and substantial interest in this
proceeding as a customer, on behalf our 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 ofwhich are customers of Intermountain Gas. ICL
IICL'S PETITION TO INTERVENE March 10,2020
has a direct and substantial interest in ensuring Intermountain's line extension policies accurately
calculate and collect the costs of new infrastructure from the cost causer and not incumbent
customers like ICL and our members.
3. ICL intends to frrlly participate in this matter as a party. The nature and quality of our
interventioh in the proceeding is dependant upon the nature and effect of other evidence in this
proceeding. If necessary we may seek discovery introduce evidence, be heard in argument, and
calI, 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 sub4p{tted this 10th day of March2020,6rZiK
Benjamin J. Otto
Idaho Conservation League
CERTIFICATE OF SERYICE
I hereby certifrthat on this 10th day of March 2020I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following pre$nsvia the method of servicenoted: a a_
Hand delivery:
I daho P ublic Utiliti es C o mmi s sio n
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
11331W. Chinden Blvd.
Building 8, Suite 201-A
Boise,ID 83714
(Original * 7 copies provided)
Benjamin J. Otto
Electronic Mail:
Intermountain G as Comp any
Preston N. Carter
Givens Pursley LLP
.com
Lori A. Blattner
Director - Regulatory Affairs
Intermountain Gas Company
Lori. Blattner@intergas. com
ICL'S PETITION TO INTERVENE 2 March 10,2020