20180320Petition to Intervene - Avista.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Far [phone]
[e-mail]
Attorney for the Idaho Conservation League
IN THE MATTER OF THE )
INVESTIGATION INTO THE IMPACT )
OF THE FEDERAL TAX CODE )
REVISIONS ON UTILITY COSTS AND )RATEMAKING )
REC E IVED
?fl8 FifiR 20 PH t: t+3
SIONb
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. GNR-U-I8-01
The Idaho Conservation League ("ICL') 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. ICL acknowledges this Petition comes after the March 6'h deadline to intervene
established in Order No. 33991. As of March 6'h, ICL did not see a direct and substantial interest
in this investigation. On March 16th, ICL received a Notice filed by Avista at the Washington
Utilities and Transportation Commission that parties to the Avista and Hydro One merger
docket in Washington reached a settlement in principle that implicates federal tax issues. The
day before this notice, on March 15 2018, the Idaho PUC Staff asked parties to the Avista and
Hydro One merger docket in Idaho, including ICL, to reschedule the settlement conferences for
this docket in Idaho. The combined impact of the notice filed in Washington and the
rescheduling of the settlement conference in Idaho,leads ICL to claim a direct and substantial
interest in this investigation into the impact to Avista of federal tax code changes regarding how
this issue impacts our direct and substantial interest in the Avista and Hydro One merger docket.
Because no party has filed any proposals or information regarding Avista, and because ICL agrees
to be bound by any existing schedules, our late intervention will not prejudice other parties or
delay the proceedings.
1. The name of this intervenor is:
Benjamin I. Otto
Idaho Conservation League
710 N. 6'h st.
Boise,Idaho 83702
Ph: [phone] x12
ICL'S PETITION TO INTERVENE 1 March 20,2018
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
Fax [phone]
[e-mail]
Please provide copies of all 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
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 has a direct and substantial interest in this matter. ICL
is a commercial customer of Avista in our Sandpoint, Idaho field office. ICL also has
approximately 700 current, dues-paying members who are residential customers of Avista. On
our own, and on behalf of our Avista-served members, ICL claims a direct and substantial
interest in this proceeding arising from the potential for changes in the federal tax code to impact
electric rates and services. We bring a unique and valuable perspective to this proceeding due to
our interest in ensuring money collected for one public purposes, paylng taxes, is used for
another public purpose.
3. ICL's interest in the multi-utility docket is limited to Avista. ICL hereby waives service
for all filings not relevant to Avista in the docket. Otherwise, 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. If necessary ICL may
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.
DATED this 20'h day of March2OlT.
submitted,
Benjamin I. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 March 20,2018
CERTIFICATE OF SERVICE
I certiff that on the 20th day of Mar ch, 2017 ,I delivered true and correct copies of the
foregoing PETITION TO INTERVENE to the following via the service method noted:
H4nd deliygaa
Diane Hanian
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail only:
Avista
David f. Meyer, Esq.
Patrick Ehrbar
Avista Corporation
P.O.Box3727
1411 E. Mission Ave.
Spokane, WA99220-3727
David.meyer@avistacorp. com
[e-mail]
Clearwater Paper Corp
Peter J. Richardson
Richardson & Adams, PLLC
515 N. 27th Street
Boise, ID 83702
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise,ldaho 83703
dreadin [e-mail]
Idaho Forest Group
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
802 W. Bannock St., Suite 900
Boise,ID 83702
ron@williamsbrandb ury. com
Dean |. Miller
3620F,. Warm Springs Ave.
Boise,ID 83716
[e-mail]
Larry A Crowley
The Energy Strategies Institute, Inc
5549 Cliffsedge Avenue
Boise,Id837l6
[e-mail]
Benjamin J. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE March 20,2018
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