20221215Petition to Intervene.pdf

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::;:'uiil I 5 PH L: 32Marie Callaway Kellner (ISB No. 8470)
710 N 6ft Street
Boise,ID 83701
(208) s37-7e93
mke llner@idahoconservation. org
IN THE MATTER OF )
INTERMOUNTIAN GAS )
C0MPANY'S APPLICATION FOR )
AUTHORTTY TO INCREASE ITS )
RATES AI\D CHARGES FOR )
NATURAL GAS SERCVICE IN )
TIrE STATE OF IDAHO )
. a r ll-al tI , ,,, i',t_;Ji_i- ,r -r iiSi,4lril ssrol{
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMIVISSION
CASE NO. INT.G.22-07
IDAHO CONSERVATION LEAGUE
PETITION TO INTERVENE
COMES NOW the Idaho Conservation League ("ICL") and hereby requests leave to
intervene in the above captioned matter to 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.
l. The name of this intervenor is:
Marie Callaway Kellner
Attomey for the Idaho Conservation League
710 N. 6ft St.
Boise, Idaho 83702
Phone: (208\ 537-7993
Email : [e-mail]
Please provide copies of all pleadings, production requests, production responses, Commission
orders, and other documents the name and address above. Please provide the same documents to
the following:
IDAHo PUBLIC UilLITTBS COMMISSION, Case No. INT.G-22-07
Idaho Conservation League, Petition to Intervene
Page I
Brad Heusinkveld
Idaho Conservation League, Energy Associate
710 N. 6ft St.
Boise,Idaho 83702
Phone: [phone]
Email : [e-mail]
In the interest of reducing costs to all parties, pleadings, testimony, briefs, production
requests, responses, notices, Commission orders, and other filings may be submitted via
electronic mail in accordance with Idaho Public Utilities Commission Rule 31.01.01.063.02-03.
ICL asks to reserve the right to request hard copies of papers and documents, as may be
necessary with appropriate notice and time.
2. Idaho Conservation League claims a direct and substantial interest in this proceeding on
behalf of our members who are customers of Intermountain Gas Company ("Intermountain" or
"Company"). As Idaho's largest state-based conservation organization, we have approximately
I1,000 members, many of whom are customers of Intermountain Gas. ICL represents its
organizational interest, the interests of its members generally, and those who are customers
within the Company's service territory. As a result, tCL and its members have a direct and
substantial interest in ensuring that Intermountain provides fair rates that do not unduly burden
customers and those interested in energy efficiency, conservation and the environmental impacts
of the energy system. The Commission has consistently granted ICL's intervention in
Intermountain Gas dockets on similar grounds. ICL's intervention will respond directly to the
issues raised in the Company's application and will not unduly broaden the scope of the issues or
this proceeding.
3. ICL intends to fully participate in this matter as a party. The nature and quality of ICL's
intervention in this proceeding is dependent upon the nature and effect of other evidence in this
proceeding. If necessary, ICL may introduce evidence, be heard in argument, and call, examine,
IDAHO PUBLIC UuLInss CoMMISSIoN, Case No. INT-G-22-07
Idaho Conservation League, Petition to Intervene
Page2
and cmss-cxamine witnesses. ICL may seok intervenor funding pursuant to IDAPA
3t.0l.0l.l6t-165.
WJIEREFORE, Tho Idaho Conservation Ieaguo reqpoctfully request the Commission grant
this petition.
DATED this 15th day of December, 2A22.
Respecfrrlly submined
/s/ Moie Callaway Kefitur
Made Callaway Kellner 0SB No. 8470)
Attomey for Idabo Conservatioa League
IDAHO PUBLTC UTILITTES COr\rIrrrSSION, Case No. INT4-22{7
Idatro Conservation League, Petition to Intervene
Page 3
CERTIFICATE OF SERVICE
I hereby certify that on this l5th day of December, 2022,I delivered true and correct
copies of the foregoing PETITION TO INTEVENE to the following persons via the method of
service noted:
/s/ Marie Callaway Kellner
Marie Callaway Kellner (ISB No. 8470)
Attorney for the ldaho Conservation League
710 N. 6s St.
Boise,Idaho 83702
[e-mail]
Elechonic Mail Only (Fee Order No. 35058
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
j an.noriyuki@puc. idaho. gov
secretary@puc. idaho. gov
Commission Staff
Riley Newton
Claire Sharp
Deputy Attorneys General
Idaho Public Utility Commission
riley.newton@puc. idaho. gov
claire.sharp@puc. idaho. gov
IDAHO PUBLIC UTILITIES CoNffvflSSIoN, Case No. INT.G.22-07
Idaho Conservation League, Petition to Intervene
Intermountain Gas C ompany
Lori A. Blattner
Director of Regulatory Affairs
Intermountain Gas Company
Post Office Box 7608
Boise, Idaho 83707
[e-mail]
Preston N. Carter
Attorney for lntermountain Gas Company
Givens Pursley LLP
601 W. Bannock St.
Boise,Idaho 83702
[e-mail]
stephaniew@givenspursl ey.com
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