20200917Petition to Intervene.pdf

RECEIVED
2020 SeptenberlT PM 2:26
IDAHO PUBLIC
UTILITIES COMMISSIONBenjamin J. Otto (ISB No. 8292)
710 N 6s Street
Boise,ID 83701
Ph: [phone] xt2
Fax: [phone]
botto@idahoconservation. org
Attomey for the ldaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATTON OF )
INTERMOUNTAIN GAS COMPAI\"Y )
FOR AUTHORITY TO IMPLEMENT )
A COMMERCIAL ENERGY )
EFHCIENCY PROGRAM AI\[D )
FT]NDING MECHANISM )
cAsE NO. rfT-G-20-04
PETITION TO INTERVENE OF THE
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 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] x t2
Fax: [phone]
botto @idahoconservation.org
Please provide copies ofall 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
ICL'S PETITION TO INTERVENE I September 18,2020
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01.063.02-03.
2. Idaho Conservation League claims a direct and substantial interest in this proceeding
arising from the impact to its members served by Intermountain Gas and to its long-term role
advocating for public values. As Idaho's largest state-based conservation organization, we have
approximately I1,000 members who are residential customers of Intermountain. ICL's Boise
office is commercial customer of Intermountain Gas. As such, ICL and our members have a
direct interest in this proceeding to ensure customer dollars are invested in cost-effective gas
conservation progftIms that deliver verifiable and durable savings. ICL brings a unique and
valuable perspective to this proceeding due to our long-standing engagement in utility sponsored
conservation program that benefit all utility customers, including advocating for a commercial
gas conservation program in Intermountain's 2016 General Rate Case. Because this
Commission has directed all utilities to pursue all cost-effective conservation measures, 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. [f 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 1.01.01. l6l-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfully submiued this l Tth day of September 2020.
/s/ Benjamin J Otto
ldaho Conservation League
ICL'S PETITION TO INTERVENE 2 September 18,2020
CERTIIilCATE OF SERYICE
I hereby certify that on this 17th day of September, 2020,I delivered true and correct
copies of the foregoing PETITION TO INTERVENE to the following persons via the method of
service noted:
Electonic Mail (see Order 34781):
Idaho Public Utilities Commission
Jan Noriyuki, Commission Secretary
i [e-mail]. qov
Intermountain Gas Company
Lori A Blattner, Director - Regulatory Affairs
[e-mail]
Preston N. Carter, Givens Pursley LLP
pnc@ givenspursley.com
kendrah@ sivenspursley.com
/s/ Benjamin J Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 3 September 18,2020