20130716Petition to Intervene.pdf

Benjamin J.Otto (ISB No.8292)21713 JUL 1 5 P;1710N6thStreet
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 IDAHO POWER )
COMPANY’S APPLICATION FOR A A EN IP E 13 16CERTIFICATEOFPUBLICC50.C---
CONVIENCE AND NECESSITY FOR PETITION TO INTERVENE OF THE
CATALYTIC REDUCTION CONTROLS )
ON JIM BRIDGER UNITS 3 AND 4.)
COMES NOW the Idaho Conservation League (“ICL”)requesting 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 I.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 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.
ICL’S PETITION TO iNTERVENE 1 July 16,2013
2.Idaho Conservation League claims a direct and substantial interest in this
proceeding arising from the impact to its members served by Idaho Power and to its long-
term role advocating for public values.As Idaho’s largest state—based conservation
organization,we have over 25,000 supporters,most of whom are residential customers of
Idaho Power.In addition,ICL,as an organization,is a small commercial customer of
Idaho Power.ICL has a long history of representing the interests of our supports on
issues affecting Idaho’s air,lands,and water,including impacts caused by Idaho Power’s
electrical system.This proceeding will directly affect the portfolio of generation Idaho
Power relies upon and,due to the Company’s request for binding ratemaking treatment,
Idahoans’electricity rates.Based on ICL’s expertise in both the Clean Air Act and utility
regulation ICL brings a unique and valuable perspective to this proceeding.ICL’s
intervention will not unduly broaden the issues in this proceeding;rather focus directly
on comparing the costs and benefits of Idaho Power’s various options to meet clean air
standards.
3.The nature and quality of ICL’s intervention in the proceeding is dependant
upon the nature and effect of other evidence in this proceeding.ICL intends to introduce
evidence,be heard in argument,and call,examine,and cross-examine witnesses.ICL
intends to seek intervenor funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE,ICL respectfully requests the Commission grant this petition.
DATED this 16th day of July 2013.
Respectfully submitted,
Benjamin J.Otto
Idaho Conservation League
ICL’S PETITION TO INTERVENE 2 July 16,2013
CERTIFICATE OF SERVICE
I hereby certify that on this 16th day of July,2013,I delivered true and correct
copies of the foregoing PETITION TO INTERVENE to the following persons via the
method of service noted:
Hand delivery:
Jean Jewel!
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W.Washington St.
Boise,ID 83702-5983
Electronic Mail:
Lisa D.Nordstrom
Jennifer Reinhardt-Tessmer
Idaho Power Company
P.O.Box 70
Boise,Idaho 83707
[e-mail]
[e-mail]
Benjamin J.Otto
ICL’S PETITION TO iNTERVENE 3 July 16,2013