20200917Petition to Intervene.pdf

r!1-*+irrF.a:Y-l!- I + i r.-" tu I tl+-i;.+n"!*tYLU
:";il Slf I ? PH 5: flrBenjamin J. Otto (ISB No. 8292)
710 N 6tr Street
Boise,ID 83701
Ph: [phone]x112
botto @idahoconservation.org
IN THE MATTER OF THE
APPLICATION OF
INTERMOUNTAIN GAS COMPAI\IY
FOR A DETERMINATION OF 2019
ENERGY EFFICIENCY EXPENCES
AS PRUDENTLY INCURREI)
l.-,'1jrj i i!.
:. i l: i :1: I =:l !Il,-,',t''l -.- , i"*jiLtlU
i r ii li ii i]&i il{;&*i$€t
Attomey for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
CASE NO. INT.G.2O.O6
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: (208) 34s-6933 x lr2
Fax: [phone]
botto @idahoconservation.org
Please provide copies of all pleadings, production requests, production responseso
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 September 17,2020
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 ldaho's largest state-based conservation organization, we have
approximately 11,000 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 programs 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 including our participation in Intermountain's 2016 General Rate Case and
as a member of Intermountain's Advisory Committee. 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 dependent upon the nature and effect of other evidence in
this proceeding. If necessary [CL may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. ICL intends to seek intervenor funding pursuant to
rDAPA 3 1.01.01. l6l-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfully submiued this lTth day of September 2020
/s/ Beniamin J Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 September 17,2020
CERTINCATE OF SERVICE
I hereby certify that on this lTth day of September, 2020,1delivered true and correct
copies of the foregoing PETITION TO INTERVENE to the following persons via the method of
service noted:
Electronic Mail (see Order 34781):
Idaho Public Utilities Commission
Jan Noriyuki, Commission Secretary
lan.non .idaho.sov
Int er mo unt ain Gas C omp any
Lori A Blattneq Director - Regulatory Affairs
[e-mail]
Preston N. Carter, Givens Pursley LLP
prestoncarter@ givenspursley.com
kendrah@ sivenspursley.com
/s/ BenjaminJ Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 3 September 17,2020