20161220Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FORA )
CERTIFICATE OF PUBLIC )
CONVENIENCE AND NECESSITY TO )
CONTRUCT SYSTEM )
IMPROVEMENTS TO SECURE )
ADEQUATE AND RELIABLE SERVICE )
TO CUSTOMERS IN THE WOOD )
RIVER VALLEY. )
CASE NO. IPC-E-16-28
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League ("ICL") and hereby requests leave to
intervene in the above captioned matter pursuant to the Idaho Public Utilities Commission Rules
of Procedure, ID APA 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 J. 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 name and 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.
2. The Idaho Conservation League claims a direct and substantial interest in this
proceeding. As Idaho's largest state-based conservation organization, we have over 25,000
ICL'S PETITION TO INTERVENE 1 December 20, 2016
supporters, most of who are residential customers ofldaho Power. ICL also has an interest as a
small commercial customer of Idaho Power taking service under Schedule 7. ICL and our
supporters have a substantial interest in promoting reliable, fair-priced energy resources while
limiting impacts to natural vistas and wildlife habitat--values that may be impacted by the
proposed Wood River Valley redundant transmission line. ICL's intervention will not unduly
broaden the issues in this proceeding.
3. ICL intends to fully participate in this matter as a party. The nature and quality ofICL's
intervention in the proceeding is dependant upon the nature and effect of other evidence in this
proceeding. If necessary ICL may introduce evidence, be heard in argument, and call, examine,
and cross-examine witnesses. ICL may seek intervenor funding pursuant to IDAPA 31.01.01.161-
165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 201h day of December 2016.
Respectf~bmitted,
--,.,::;;;.,i~-
Benjamin J. Otto
Idaho Conservation League
ICL'S PETITION TO INTERVENE 2 December 20, 2016
CERTIFICATE OF SERVICE
I ~ ~ certify that on this 20th 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 ( Original and seven
copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Donovan E. Walker
Tim Tatum
Idaho Power Company
1221 West Idaho St
PO Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
Kiki Leslie A Tidwell
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St.
P.O. Box 7218
Boise, ID 83 702
[e-mail]
Kiki Leslie A Tidwell
300 Let 'er Buck Road
Hailey, Idaho 83333
[e-mail]
Sierra Club
cl o Zack Waterman
Director, Idaho Sierra Club
503 W. Franklin St
Boise, ID 83702
Zack. [e-mail]
ICL'S PETITION TO INTERVENE 3
Michael Heckler
3606 N. Prospect Way
Garden City, ID 83714
Michael. [e-mail]
December 20, 2016