20161220Petition to Intervene.pdf

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BEFORE THE 'I ' !
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FORA ) CASE NO. IPC-E-16-28
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY TO CONSTRUCT SYSTEM) PETITION TO INTERVENE
IMPROVEMENTS FOR WOOD RIVER ) OF LAURA MIDGLEY
VALLEY CUSTOMERS )
) _________________ )
COMES NOW, Laura Midgley, and pursuant to this Commission's Rules of Procedure,
Rules 43.02 (a "natural person" may represent herself) 71 IDAPA 31.01.01.71 (interventions
generally), 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:
I. The name and address of this Intervenor is:
Laura Midgley
231 Valley Club Drive
Hailey, Idaho 83333
[phone]
Mido!e 2215 omail.com
Copies of all pleadings, production requests, production responses, Commission orders
and other documents should be provided to Ms. Midgley as noted above.
2. This Intervenor, Ms. Midgley, is an Idaho Power customer and the owner, and resident,
of real property located in Hailey, Idaho. Ms. Midgley has made substantial investments in said
property.
3. Ms. Midgley claims a direct and substantial interest in this proceeding in that Idaho
Power's proposed transmission line will run adjacent to the Valley Club Development and it will
be in the direct vicinity of her property on Valley Club Drive in Hailey, Idaho. Ms. Midgley will
suffer economic impacts as the result of the construction of overhead transmission lines are in
the direct proximity of the western edge of her property.
4. If the proposed overhead transmission line is constructed as proposed along scenic
Highway 75 (parallel and adjacent to the Valley Club development, of which Ms. Midgley is a
member and resident) Ms. Midgley will suffer substantial economic harm. Ms. Midgley'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 Ms. Midgley'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
Ms. Midgley as the result of the proposed transmission line gives her a direct and substantial
interest in the present action.
5. Unless Ms. Midgley 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. Ms. Midgley 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 Ms. Midgley will introduce is dependent upon the nature
and effect of other evidence in this proceeding.
Intervention -IPC-E-16-28 2
7. Without the opportunity to intervene herein, Ms. Midgley would be without any means of
participation in this proceeding which may have a material impact on the value of her property as
well as her electric rates.
8. Granting Ms. Midgley's petition to intervene will not unduly broaden the issues nor will
it prejudice any party to this case.
WHEREFORE, Ms. Laura Midgley 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.
DA TED this 20th day of December, 2016.
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Intervention -I PC-E-16-28 3
Laura M. Midgley
Intervenor
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of December, 2016, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY LAURA M. MIDGLEY 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 83707-0070
dwalker@idahopoy.;er.com
ttatunl(cg idahopower.com
Kiki Leslie A. Tidwell
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th St.
P.O. Box 7218
Boise, Idaho 83702
peter@richardsona_dams.com
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho 83 702
Laura M. Midgley, lntevenor
Intervention -IPC-E-16-28 4