20200423Petition to Intervene.pdf

GNR-U-20-03
ICL’S PETITION TO INTERVENE 1 April 23, 2020
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]

Attorney for the Idaho Conservation League

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF DEFERRED
ACCOUNTING OF INCREMENTAL
COSTS ASSOCIATED WITH THE
COVID-19 PUBLIC HEALTH
EMERGENCY.
)
)
)
)
)
)
CASE NO. GNR-U-20-03

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. 6th st.
Boise, Idaho 83702
Ph: [phone] x 12
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. Idaho Conservation League claims a direct and substantial interest in this proceeding
arising from the impact to its members served by investor-owned utilities serving various
RECEIVED
2020 April 23,PM4:29
IDAHO PUBLIC
UTILITIES COMMISSION
GNR-U-20-03
ICL’S PETITION TO INTERVENE 2 April 23, 2020
communities across Idaho and to its long-term role advocating for public values. As Idaho's
largest state‐based conservation organization, we have approximately 11,000 members most of
whom are residential customers of Idaho Power, Avista or Rocky Mountain Power. ICL’s work
has not traditionally engaged with water utilities, although we have members who are water
utility customers. ICL, as an organization, is an Idaho Power Schedule 9 customer in our Boise
office, and Idaho Power Schedule 7 customer in our Ketchum office, and a small commercial
customer of Avista in our Sandpoint office. The Commission has consistently granted ICL
intervention in Rocky Mountain Power dockets to protect our member’s and organization
interests impacted by decisions applicable to that utility. ICL understands this docket will not
result in direct rate increases at this time, but this docket does implicate important public policy
issues on the appropriate balance of potential impacts to utility shareholders and customers that
arise from reduced demand for services. ICL’s intervention will not unduly broaden the issues in
this proceeding as we will stay within the boundaries and procedure announced in Order 34643.
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. If necessary ICL may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses.

WHEREFORE, ICL respectfully requests the Commission grant this petition.
Respectfully submitted this 23rd day of April 2020.
____/s/ Benjamin J. Otto_____
Benjamin J. Otto
Idaho Conservation League
GNR-U-20-03
ICL’S PETITION TO INTERVENE 3 April 23, 2020
CERTIFICATE OF SERVICE
I hereby certify that on this 23rd day of April, 2020, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
____/s/ Benjamin J. Otto_____

Electronic mail only (See Order 34602):
Idaho Public Utilities Commission
Diane Hanian, Secretary
[e-mail]

Avista Utilities
David J. Meyer
Patrick Ehrbar
[e-mail]
[e-mail]

Idaho Power
Lisa D. Nordstrom
Matt Larkin
[e-mail]
[e-mail]
[e-mail]

Rocky Mountain Power
Ted Weston
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Falls Water Company/Gem State Water
Company
Preston N. Carter
[e-mail]
[e-mail]

Eric W. Nelson, NW Natural
Eric.nelson@nwnatural

Industrial Customers of Idaho Power
Peter J. Richardson, Richardson Adams
PLLC
[e-mail]

Dr. Don Reading
[e-mail]

Monsanto Company
James R. Smith, Monsanto
[e-mail]

Randle C. Budge, Racine Olson PLLP
[e-mail]
Thomas J. Budge, Racine Olson, PLLP
[e-mail]

Brian C. Collins, Brubaker & Associates
[e-mail]
Maurice Brubaker, Brubaker & Associates
[e-mail]