20161220Petition to Intervene.pdf

Zack Waterman
IDAHO SIERRA CLUB
503 W Franklin St J·'lfl DEC 20 ~M 11: 24
Boise, ID 83702
Telephone:[phone]')3
zack. W atcnna n/g)sicrraclu b. org
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-16-28
COMPANY'S APPLICATION FOR )
CERTIFICATE OF PUBLIC CONVENIENCE )
AND NECESSITY FOR WOOD RIVER )
VALLEY )
PETITION TO INTERVENE OF SIERRA CLUB
Pursuant to IDAPA 31.01.01.042, Sierra Club hereby submits this petition to intervene in
the above captioned matter.
1. Sierra Club is a national, non-profit environmental and conservation organization
incorporated under the laws of the State of California, duly qualified to do
business in the State of Idaho. Sierra Club has 2,400 members who live and
purchase utility services in Idaho, many of those Sierra Club members are
customers ofldaho Power who live in the Wood River Valley. Sierra Club's Idaho
members have a direct and substantial interest in this proceeding.
2. Sierra Club's work includes advocating for the implementation of programs that
assist its members and utility consumers generally to access renewable energy and
increase energy efficiency. The Sierra Club's work includes intervening in dockets
at public utility commissions nationwide, submitting comments in numerous state
and federal agency energy-related proceedings and rule-makings, attending and
speaking at public hearings, speaking to students and civic and other
organizations, and holding seminars and symposia -all in support of policies to
PETITION TO INTERVENE OF SIERRA CLUB 1
reduce the impact of climate change and other air pollution by promoting clean
energy alternatives and energy efficiency. Sierra Club members have worked
tirelessly to promote clean energy alternatives and energy efficiency measures.
3. Sierra Club's Beyond Coal campaign seeks rapid replacement of fossil-fueled
generating units with cleaner forms of energy to eliminate or reduce global
climate change emissions, reduce utility bills, and generate renewable energy.
Previous requests that Idaho Power fairly consider alternatives to building a
redundant transmission line, including local renewable generation, are consistent
with Sierra Club's Beyond Coal campaign goals.
4 .. Sierra Club's Ready for 100 campaign seeks to assist cities in transitioning to
100% clean energy. City of Ketchum goals for 2030 including 50% per capita
energy reduction, 50% local renewable generation, 100% renewable power and a
75% reduction in GHG emissions are consistent with Sierra Club Ready for 100
goals.
5. Sierra Club has actively sought accurate and fair evaluation of the locational value
of distributed energy resources as alternatives allowing the deferment of or as
substitutes for adding transmission and distribution system resources. This docket
raises those issues.
6. Sierra Club's participation as an intervenor in this proceeding will not unduly
broaden the issues or delay the proceeding because Sierra Club's interest is
directly related to the subjects addressed in Idaho Power's application. Sierra
Club's involvement in this proceeding will not be duplicative of other parties in
PETITION TO INTERVENE OF SIERRA CLUB 2
this proceeding because no other party adequately represents Sierra Club's
interests.
7. The name and address of the intervenor is:
Sierra Club
c/o Zack Waterman
Director, Idaho Sierra Club
503 W Franklin St
Boise, ID 83 702
Telephone: {1Qfil_)84-1021
8. Copies of all pleadings, production requests, production responses, Commission
orders and other documents should be provided to Zack Waterman as noted above
and to:
Michael Heckler
3606 N Prospect Way
Garden City, ID 83714
Telephone: (2_Q_8_l_84 l-566z
!TI i c hael,n.. heck I er(ii; gmail. 9..9111.
WHEREFORE, Sierra Club respectfully requests that the Commission issue an order
granting Sierra Club permission to intervene in this matter.
Dated this 20th day of December, 2016
.2:ack Waterman
Director, Idaho Sierra Club
503 W Franklin St
Boise, Idaho 83 702
PETITION TO INTERVENE OF SIERRA CLUB 3
CERTIFICATE OF SERVICE
I hereby certify that on the 20 day of December 2016, I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
.lean.jewell/dlpuc.idaho.gov
Donovan W a\ker
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise, Idaho
Dwalker @idahopower.com
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BY: JJ~
zafk Waterman
Director, Idaho Sierra Club