20170118Petition to Intervene.pdf

Benjamin J. Otto, ISB No. 8292
Idaho Conservation League
Post Office Box 844
Boise, Idaho 83701
[phone] X 12
[e-mail]
Travis Ritchie, CA Bar# 258084 (pro hac vice pending)
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA 94612
[phone]
[e-mail]
RECE IVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RA TES
DUE TO REVISED DEPRECIATION RA TES
FOR ELECTRIC PLANT-IN-SERVICE
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CASE NO. IPC-E-16-23
JOINT PETITION TO INTERVENE
OF IDAHO CONSERVATION
LEAGUE AND SIERRA CLUB
The Idaho Conservation League ("ICL") and Sierra Club hereby submit this petition to
intervene as joint parties. ICL and Sierra Club file this petition to intervene after the filing
deadline established by the Commission in Order 33652. Below, ICL and Sierra Club explain our
good cause for this late intervention, agree to abide by any existing orders and not unduly
broaden the issues. ID AP A 31.01.01. 071-073
On October 21, 2017 Idaho Power filed two dockets concerning electric plant
depreciation: IPC-E-16-23, to revise depreciation rates generally, and IPC-16-24 to revise the
depreciation schedule for the North Valmy plant specifically. At that time, ICL and Sierra Club
considered intervening in both dockets, but decided to focus our resources on our primary
interest the North Valmy docket, IPC-E-16-24. On December 13, 2016 the Commission granted
our intervention in the North Valmy docket. Order No. 33672.
There are several common parties in both dockets: Idaho Power, the PUC Staff, the
Department of Energy, the Idaho Irrigation Pumpers Association and Micron. The parties to IPC­
E-16-23, the general depreciation docket, have proposed a similar docket schedule for both cases
including possible settlement negotiations in the general depreciation docket. ICL and Sierra
Club believe settlement negotiations are possible in IPC-E-16-24, the North Valmy docket, and
reuse PETITION TO INTERVENE 1 January 18, 2017
regardless our interests there may be impacted by negotiations in the general depreciation docket.
Parties in both dockets have suggested, and we agree, that holding concurrent settlement
discussions could facilitate the efficient resolution of issues in both dockets. However, ICL' s and
Sierra Club's ability to participate in concurrent settlement discussions would be complicated
unless we intervene in IPC-E-16-23. Therefore, good cause exists to grant ICL and Sierra Club's
request for late intervention in order to promote judicial efficiency and encourage settlement of
the issues presented to the Commission in both dockets. ICL and Sierra Club contacted each of
the parties in docket IPC-E-16-23, and no party objects to this petition for intervention.
In order to protect our interests and facilitate settlement negotiations ICL and Sierra Club
seek to intervene in docket IPC-E-16-23 for the limited issue of possible implications to the
North Valmy docket. ICL and Sierra Club hereby agree to sign the protective order and agree to
any schedule established by the parties to docket IPC-E-16-23 prior to the Commission granting
our intervention.
Idaho Conservation League
1. The name and address of Idaho Conservation League is:
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83 702
Ph: [phone] xl2
Fax [phone]
[e-mail]
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, ICL represents
25,000 supporters, most of whom are residential customers ofldaho Power. ICL, as an entity,
is a small commercial customer ofldaho Power. ICL and our supporters have an interest in
ensuring Idaho Power's electric system provides reliable, fair-priced service that protects the
clean air, clean water, and stable climate that are foundational public values for Idahoans.
ICL brings a unique and valuable perspective to this proceeding because our members are
customers of Idaho Power who support the transition from coal to clean energy resources.
ICL's intervention will represent our supporters' interest in ensuring fair rates in the
ICL/SC PETITION TO INTERVENE 2 January 18, 201 7
transition away from coal power and toward the greater use ofldaho's clean energy
resources.
Sierra Club
3. The name and address of Sierra Club is:
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA 94612
[phone]
[e-mail]
4. Sierra Club is a national, non-profit environmental and conservation organization
incorporated under the laws of the State of California. The Sierra Club is dedicated to the
protection of public health and the environment. Sierra Club petitions to intervene on behalf
of itself and over 2,600 Sierra Club members who live and purchase utility services in Idaho,
many of whom are residential customers ofldaho Power.
5. Sierra Club's Idaho members have a direct and substantial interest in this proceeding because
the scheduled depreciation of the North Valmy coal plant will have environmental, health
and economic consequences for Sierra Club members who are customers ofldaho Power.
These Sierra Club members have a right to participate in this proceeding to inform the
Commission of their interests, both environmental and economic, that relate to the impacts of
continued reliance on the North Valmy coal plant.
6. The joint intervention ofICL and Sierra Club will not unduly broaden the issues or delay the
proceeding because the interests ofICL and Sierra Club are directly related to the subjects
addressed in Idaho Power's application.
7. Sierra Club and ICL request that all future pleadings, correspondence, discovery, and other
documents be served on the following:
Ben Otto
ISB No. 8292
Energy Associate
Idaho Conservation League
Post Office Box 844
Boise, Idaho 83701
208-345-6933 X 12
[e-mail]
ICL/SC PETITION TO INTERVENE 3
Travis Ritchie,
CA Bar# 258084 (pro hac vice pending)
Associate Attorney
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA 94612
[phone]
[e-mail]
January 18, 2017
WJIEREFORE, ICL and Sierra Club respectfully request that the Commission issue an
order granting ICL and Sierra Club permission to appear in this matter as joint parties.
Dated this 18th day of January 2017.
ICL/SC PETITION TO INTERVENE
Re~ly submitted,
~
Benjamin J. Otto
Attorney
4 January 18, 2017
CERTIFICATE OF SERVICE
I hereby certify that on this 18th day of January 2017, 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 Jewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original and seven copies provided)
Electronic Mail:
Idaho Power
Lisa D. Nordstrom
Matt Larkin
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]
IIPA
Eric 1. Olsen
ECHOHAWK & OLSEN, PLLC
505 Preshing Ave., Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail]
Anthony Yanke!
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
MICRON
Pete Bennett
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
[e-mail]
Thorvald A. Nelson
Frederick J. Schmidt
ICL/SC PETITION TO INTERVENE 5
Emanuel T. Cocian
Brian T. Hansen
Holland & Hart, LLP
6380 Fiddlers Green Circle, STE. 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
ICIP
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83702
[e-mail]
Don Reading
6070 Hill Road
Boise, ID 83703
[e-mail]
Department of Energy
The United States Department of Energy
c/o Steve Porter
Office of the General Counsel (GC-76)
1000 Independence Ave., SW (Room 6D-
033)
Washington, D.C. 20585
[e-mail]
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Benjamin J. Otto
January 18, 2017