20090331Petition to Intervene.pdf

Betsy Bndge
Idaho Conservation Leàgue
PO Box 844
710 N 6th Street
Boise,lD 83701
Ph: [phone] x 12
Fax: [phone]
bbridge~wildidaho.org
ZOM MAR 3 l PM 2: 41
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE LANGLEY
GULCH POWER PLANT
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CASE NO. IPC-E-09-03
PETITION TO INTERVENE
Pursuant to Idaho Public Utilties Commission Rules of Procedure 53 and 71
through 73, the Idaho Conservation League (((ICL") hereby seeks intervention in the
above-captioned matter. As discussed below, ICL has direct and substantial interests in
these proceedings, and therefore should be granted intervention.
For thirt-four years, ICL has been Idaho's voice for clean water, clean air, and
wilderness-values that are the foundation to Idaho's extraordinary quality of life. ICL
works to protect these values through citizen action, public education, and professional
advocacy. As Idaho's largest state-based conservation organization we represent over
9,500 members, many of whom have a deep personal interest in protecting our clean air,
clean water, and quality oflife. ICt's address is PO Box 844,710 Nort Six St, Boise,
Idaho 83701.
PETITION TO INTERVENE BY ICL -- 1
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ICL has direct and substantial interests in this proceedig because investments in
energy effciency programs, acquisition of renewable resources, and impacts on the
environment may be affected by the outcome of this proceeding. ICL has an interest in
promoting the responsible expansion of energy effciency and renewable energy in Idaho,
and decisions issued in this case may impact its abilty to advance that interest. Moreover,
ICL has individual members who are customers of the Idaho Power Company. The
interests advanced by ICL in this case seek to promote the acquisition ofleast-cost and
least-risk resources.
ICL seeks intervention in order to fuly paricipate in this matter as a part and
otherwse to present such materials as may be relevant to the Commission's decision(s) in
this matter. ICL intends to seek intervenor fuding pursuant to RP 161 through 165.
PLEASE TAKE NOTICE that ICL requests all documents in this matter be served
to the following persons:
Betsy Bridge
Idaho Conservation League
PO Box 844
710 Nort Sixth Street
Boise, Idaho 83701
bbridge~wildidaho.org
WHEREFORE, ICL respectfuly requests that the foregoing petition to intervene
be granted.
Dated: March 30, 2009 Respectfully submitted,
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PETITION TO INTERVENE BY ICL -- 2
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CERTIFICATE OF SERVICE
I hereby certify thàt on this 30th day of March, 2009, true and correct copies of the
foregoing PETITION TO INTERVENE were delivered to the followig persons via the
method of servce noted:
Hand delivery:
Jean Jewell
Commission Secretary (Origial and seven copies provided)
Idaho Public Utilties Commission
427 W. Washington St.
Boise, ID 83702-5983
U.S. Mail:
Barton L. Kline
Donovan E. Walker
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707-0070
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PETITION TO INTERVENE BY ICL -- 3