20161205Petition to Intervene.pdf

Peter J. Richardson ISB No. 3195
Gregory M. Adams ISB No. 7454
Richardson Adams, PLLC
515 N. 2th Street
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone] Tel
Fax: [phone] Fax
[e-mail]
Attorneys for Kiki Leslie A. Tidwell
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
RE J -:1'/ED
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{ Ip ... ! 1~:::; L:c·1/;'iit'i1SS !ON
IDAHO POWER COMPANY FOR A ) CASE NO. IPC-E-16-28
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY TO CONSTRUCT SYSTEM) PETITION TO INTERVENE
IMPROVEMENTS FOR WOOD RIVER . ) OF KIKI LESLIE A. TIDWELL
VALLEY CUSTOMERS )
) ________________ )
COMES NOW, Kiki Leslie A. Tidwell, and pursuant to this Commission's Rules of
Procedure, Rule 71 ID APA 31.01.01. 71 , and pursuant to that Notice oflntervention Deadline -
issued on November 29, 2016, in Order No. 33657 and hereby petitions the Commission for
leave to intervene herein and to appear and participate herein as a party, and as grounds therefore
states as follows:
1. The name and address of this Intervenor is:
Kiki Leslie A. Tidwell
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 2th St.
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone]
Fax: [phone]
[e-mail]
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Peter Richardson as noted above and to:
Kiki Leslie A. Tidwell
300 Let 'er Buck Road
Hailey, Idaho 83333
[e-mail]
2. This Intervenor, Mrs. Tidwell, is an Idaho Power customer and the owner, and resident,
of real property located on the west side of Let 'er Buck Road in Hailey, Idaho. Mrs. Tidwell
has made substantial investments in said property.
3. Mrs. Tidwell claims a direct and substantial interest in this proceeding in that Idaho
Power's proposed transmission line will run directly adjacent to and along the entire eastern
boundary of her property. Mrs. Tidwell will suffer substantial economic impacts as the result of
the entire eastern boundary of her property being permanently marred by industrial transmission
towers that may be up to sixty feet high.
4. If the proposed overhead transmission line is constructed as proposed along Buttercup
Road (parallel to Let 'er Buck Road) Mrs. Tidwell will suffer substantial economic harm. Mrs.
Tidwell's property is maintained in compliance with the goals that are central to the Blaine
County Comprehensive Plan. Idaho Power's proposed transmission line is in direct conflict with
said Comprehensive Plan and will also directly impair Mrs. Tidwell's property value as well as
her ability to continue to enjoy the open views, scenic vistas and natural aesthetics that are
currently protected by the Blaine County Comprehensive Plan. The significant and irreparable
harm to Mrs. Tidwell as the result of the proposed transmission line gives her a direct and
substantial interest in the present action.
Intervention -rPC-E-1 6-28 2
5. Unless Mrs. Tidwell is permitted to intervene in this action, she will be without adequate
means to fully participate and represent her interests in the determination of either the need for
and/or the location of the proposed transmission line.
6. Mrs. Tidwell, through legal counsel, intends to participate herein as a party, and if
necessary, to introduce evidence, cross-examine witnesses, call and examine witnesses, and be
heard in argument. The nature and quality of evidence which Mrs. Tidwell will introduce is
dependent upon the nature and effect of other evidence in this proceeding.
7. Without the opportunity to intervene herein, Mrs. Tidwell would be without any means of
participation in this proceeding which may have a material impact on the value of her property.
8. Granting Mrs. Tidwell's petition to intervene will not unduly broaden the issues nor will
it prejudice any party to this case.
WHEREFORE, Mrs. Kiki Leslie A. Tidwell respectfully requests that this Commission
grant her 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 and to otherwise fully participate in these proceedings.
DATED this 5th day of December, 2016.
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Intervention -[PC-E-1 6-28 3
Richardson Adams, LLP
By PM,~ .
Peter J. Richardson
Attorneys for Mrs. Tidwell
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of December, 2016, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY KIKI LESLIE A. TIDWELL was served
by HAND DELIVERY, to:
Donovan Walker, Lead Counsel
Tim Tatum, Vice President, Regulatory Affairs
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83 707-0070
[e-mail]
[e-mail]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
4 72 West Washington
Bo~-
Kandi Walters
Administrative Assistant
Intervention -!PC-E-16-28 4