20161220Petition to Intervene.pdf

Matthew A. Johnson (ISB #7789)
Wm. F. Gigray, III (ISB #1435)
WHITE PETERSON GIGRA Y & NICHOLS, P .A.
5700 East Franklin Road, Suite 200
Nampa, Idaho 83687
Office: [phone]
Fax: [phone]
[e-mail]
Attorneys for Intervenor: City of Ketchum
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR A )
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY TO CONSTRUCT SYSTEM )
IMPROVEMENTS FOR WOOD RIVER VALLEY )
CUSTOMERS )
)
CASE NO. IPC-E-16-28
CITY OF KETCHUM
PETITION TO INTERVENE
The CITY OF KETCHUM hereby petitions to intervene in the above-captioned matter
pursuant to the Rules of Procedure of the Idaho Public Utilities Commission (IDAP A
31.01.01.71 et seq) and the Commission's Order No. 33657 with Notice of Application and
Notice of Intervention Deadline issued on November 29, 2016.
In support of this Petition, the City of Ketchum provides as follows:
1. The City of Ketchum ("City") is duly organized as a municipal corporation of the State of
Idaho under Idaho Code Title 50.
2. The City owns, governs, and controls public roadways and right-of-ways within the City
limits. Under Chapter 3 of Title 50 of the Idaho Code, the City is empowered to
supervise, regulate, create, widen, improve, and otherwise control and direct such public
roadways.
KETCHUM PETITION TO INTERVENE - 1 L
3. The City has a direct and substantial interest in the above captioned matter. The City is
clearly identified and recognized as an interested and impacted party in Idaho Power's
Application. The City is a customer, is the location of a substation, and is the location a
substantial population to potentially be served by the proposed redundant service. The
City has been actively involved in the prior public involvement and community input
efforts, including advocating for better evaluation of transmission alternatives such as
more locally generated energy resources. The City has an existing franchise agreement
with Idaho Power for the provision of facilities for electrical service, directly impacting
use and maintenance of City streets, rights-of-way, and public places. Further the City
has a direct interest in making sure there is no contravention of such franchise agreement
and/or any local requirements including permitting.
4. The City has a direct and substantial interest in that the Company's Application
specifically requests that certain costs be directly assessed against the City. Application
at page 4.
5. Intervention by the City will not unduly broaden the issues in this matter. The City's
comments, concerns, and issues have generally been previously communicated to Idaho
Power during conversations and community input processes and many of the issues are
already raised in the Application.
6. Intervention by the City is in the public interest. The City has comments and concerns
related to the public interest in traffic, roadways, public safety, and the general welfare.
7. Intervention by the City will not cause delay or prejudice to the parties in the above­
captioned matter. The City seeks to timely intervene at an early stage in this matter.
KETCHUM PETITION TO INTERVENE -2
.,.
8. Intervention by the City is appropriate to allow the City to express certain concerns,
objections, and protests in relation to the Application in this matter.
9. The City believes that status as an intervenor will allow for clearer communication about
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on the 20th day of December, 2016, a true and
correct copy of the above and foregoing instrument was served upon the following by the
method indicated below:
Jean Jewell U.S. Mail --Commission Secretary __ Overnight Mail
Idaho Public Utilities Commission __L Hand Delivery
472 West Washington Facsimile: --
Boise, ID 83702
Donovan Walker, Lead Counsel
Tim Tatum, Vice President, Regulatory Affairs X U.S. Mail
IDAHO POWER COMPANY __ Overnight Mail
P. 0. Box 70 __ Hand Delivery
Boise, ID 83 707 --Facsimile:
~~-for WHITE PETERSON
W:\Work\K\Ketchum, City of 24892\ldaho Power\Ketchum -!PUC Petition to lntervene.IDP Wood River Valley CPCN.docx
KETCHUM PETITION TO INTERVENE -3