20150127Petition to Intervene.pdf

Steven Porter (Texas Bar No. 16150700)
Assistant General Counsel
Electricity and Fossil Energy
United States Department of Energy
1000 Independence Ave, SW
Washington, D.C.20585
Telephone: [phone]
Fax:[phone]
E-mail : Steven. [e-mail]. gov
Attomey for the United States Department of Energy and the
Federal Executive Agencies
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
oF PACTFICORP DIBIA ROCKY )
MOLTNTAIN POWER AND IDAHO ) CASE NO. IPC-E-14-41
POWER COMPANY FOR AN ORDER )
AUTHORIZTNG THE EXCHANGE OF ) CASE NO. PAC-E-14-I I
CERTAIN TRANSMTSSION ASSETS. )) PETITION TO INTERVENE OF THE
) I.]NITED STATES DEPARTMENT
) OF ENERGY AND THE FEDERAL
) EXECUTIVE AGENCTES
)
COMES NOW, the United States Department of Energy ("DOEi'or "Department") on
behalf of itself and the Federal Executive Agencies ("FEA"), hereinafter collectively referred to
as "Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 71 IDAPA
31.01.01.71, hereby petitions the Commission for leave to intervene herein and to appear and
participate herein as a party. In support of this petition, the Department states as follows:
l. The name and address of this Intervenor is:
The United States Department of Energy
c/o Steven Porter
Office of the General Counsel (GC-76)
1000Independence Avenue, SW (Room 6D-033)
DOE Petition to Intervene - IPC-E-14-41 ; PAC-E- l I
Washington, D.C. 20585
Telephone : [phone]
Fax:[phone]
E-mail : [e-mail]. gov
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Steven Porter as noted above and to:
Dwight Etheridge
10480 Little Patuxent Parkway
Suite 300
Columbia, MD 21044
Telephone: [phone]
Fax: [phone]
E-mail : [e-mail]
2. The Idaho Power Company ("IPC" or "Company") serves DOE's Idaho National
Laboratory ("INL"), a science-based, applied engineering laboratory located in southern Idaho
and dedicated to supporting DOE's research programs in nuclear energy, national and homeland
security, and clean energy. INL takes service from IPC under a special contract, in accordance
with the rates and charges set out in Electric Service Rate Schedule 30 and its successor
schedules. Therefore, DOE has a direct and substantial interest in these proceedings, which
would not be represented by other parties, in that the outcome of these proceedings may affect
the Company's electric rates for INL.
3. DOE has been delegated by the United States General Services Administration
pursuant to Sec. 210(il@) of the Federal Property Management and Administrative Services Act
of 1949, as amended (40 U.S.C. 501(c)), to represent the customer interests of the Federal
Executive Agencies of the United States Government in IPC proceedings. Other federal
facilities taking electric service from IPC include the United States Air Force's Mountain Home
Air Force Base, located in southwestern, Idaho.
DOE Petition to Intervene - IPC-E-14-41; PAC-E-l I
4. This Intervenor, on behalf of DOE as well as the FEA, intends to participate
herein as a party, and if necessary, to introduce evidence, submit comments, and fully participate
in any hearing that may occur including the calling and cross examination of witnesses. The
nature and quality of evidence which this Intervenor will introduce is dependent upon the nature
and effect of other evidence in this proceeding.
5. Without the opportunity to intervene herein, this Intervenor would be without any
effective means of participation in this proceeding which may have a material impact on the
electric rates and/or service provided to DOE/FEA facilities.
6. Granting this Intervenor's petition to intervene will not unduly burden the issues
nor will it prejudice any party to this case.
7. The undersigned DOE attorney, Steven A. Porter, is not admitted to practice
before the courts of the state of Idaho, and is admitted to practice before the courts of the state of
Texas. Mr. Porter has been in the active practice of law since 1981. Mr. Porter is not under
suspension or disbarment by any of the courts of the state in which he is admitted to practice.
Mr. Porter will in the future petition for leave to appear pro hac vice herein DOE respectfully
requests that this petition to intervene be granted subject to the condition that in the future Steven
A. Porter, or another DOE attomey, obtains approval from this Commission for a petition for
leave to apper pro hac vice herein.
WHEREFORE, the United States Department of Energy, on behalf of itself and the
Federal Executive Agencies respectfully requests that this Commission grant its Petition to
Intervene in these proceedings and to appear and participate in all matters as may be necessary
and appropriate; and to present evidence, call and examine witnesses, present argument at any
hearing that may occur, and to otherwise fully participate in these proceedings.
DOE Petition to Intervene - IPC-E- l4-4 I ; PAC-E- I I
DATED this 26th day of January 20t5.
Assistant General Counsel
Electricity and Fossil Energy
United States Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585
Telephone: [phone]
Fax:[phone] l6
E-mail : [e-mail]. gov
Respectfully Su
16150700)
4
DOE Petition to Intervene - IPC-E-14-41; PAC-E-I I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the26th day of January,2}ll, a true and correct copy of
the within and foregoing PETITION TO INTERVENE OF THE UNITED STATES
DEPARTMENT OF ENERGY AND THE FEDERAL EXECUTIVE AGENCIES, was served
by overnight mail, properly addressed and postage pre-paid, to the service list provided below.
United States Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585
Telephone : [phone] | 8
Fax:[phone]
E-mail : [e-mail]. gov
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P.O. Bor83720
Boise, Idaho 83720-007 4
Julia A. Hilton
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 837 07 -007 0
Daniel Solander
Rocky Mountain Power
201 South Main Street, Ste 2300
Salt Lake City, Utah 84111
Data Response Request Center
PacifiCorp
825 NE Multnomah, Ste 2000
Portland, Oregon 97232
Respectfully Submitted,
. Tshikororo
Attorney-Adviser
DOE Petition to Intervene - IPC-E-14-41; PAC-E-l I
Peter J. Richardson
Richardson & O'leary
515 N. 27fr Street
P.O. Box 7218
Boise,Idaho 83702
Attorneyfor Industrial Customers of ldaho
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
Representative for Industrial Customers of ldaho
6
DOE Petition to Intervene - IPC-E-14-41; PAC-E-I1