20161202Petition 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]
RECEIVED
ZOl fi O_c -2 PM 2:51
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RA TES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE NORTH
VALMYPLANT
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CASE NO. IPC-E-16-24
JOINT PETITION TO INTERVENE
OF IDAHO CONSERVATION
LEAGUE AND SIERRA CLUB
Pursuant to IDAP A 31.01.01.042, Idaho Conservation League ("ICL") and Sierra Club
hereby submit this petition to intervene as joint parties. ICL and Sierra Club share many strategic
goals and interests. Specifically for this docket, as discussed in more detail below, both ICL and
Sierra Club have direct and substantial interests in the accelerated depreciation of the North
Valmy coal plant.
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] x12
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
ICL/SC PETITION TO INTERVENE 1 December 2, 2016
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
transition away from coal power and toward the greater use of Idaho'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 of ICL and Sierra Club will not unduly broaden the issues or delay the
proceeding because the interests oflCL and Sierra Club are directly related to the subjects
addressed in Idaho Power's application.
ICL/SC PETITION TO INTERVENE 2 December 2, 2016
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]
Travis Ritchie,
CA Bar# 258084 (pro hac vice pending)
Associate Attorney
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA 94612
[phone]
[e-mail]
WHEREFORE, 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 2nd day of December, 2016.
Respectfully submitted,
~~ I
Benjamin J. Otto
Attorney for Idaho Conservation League
ICL/SC PETITION TO INTERVENE 3 December 2, 2016
CERTIFICATE OF SERVICE
I hereby certify that on this 2"d day of December 2016, 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
ECHOHA WK & OLSEN, PLLC
505 Preshing Ave., Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail]
Anthony Y ankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
MICRON
Pete Bennett
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83 707
[e-mail]
ICL/SC PET1TI0N TO INTERVENE
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Thorvald A. Nelson
Frederick J. Schmidt
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]
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Benjamin f"'Otto
December 2, 2016