20170130Petition 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
':')~('Cl\'ED ,\_,, .,.1 L-V
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF IDAHO POWER )
COMPANY FOR A DETERMINATION )
OF HELLS CANYON COMPLEX )
RELICENSING COSTS THROUGH )
2015 AS PRUDENTLY INCURRED. )
CASE NO. IPC-E-16-32
THE IDAHO CONSERVATION
LEAGUE
PETITION TO INTERVENE
The Idaho Conservation League ("ICL") petitions the Commission to intervene in this
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. 61h st.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
[e-mail]
In the interest of conserving natural resources and reducing the costs, please provide hard
copies of pleadings, testimony, and briefs only to the name and address above. Production
requests, responses, notices, Commission orders, and other filings may be submitted via
electronic mail in accordance with IDAPA 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
supporters, most of who are residential customers ofldaho Power. ICL also has an interest as a
small commercial customer ofldaho Power taking service under Schedule 7. ICL and our
supporters have a substantial interest in ensuring a affordable, reliable, and timely transition
away from fossil fueled electricity to meet our supporters' desire to protect Idaho's air quality and
ICL 'S PETITION TO INTERVENE 1 January 30, 2017
natural landscapes. These interests are directly and substantially impacted by Idaho Power's
efforts to date studying the environmental impacts of the Hells Canyon Complex and possible
means to reduce and mitigate these impacts in the relicensing process. Because this Commission
has directed all utilities to comply with federal laws while maintaining affordable and reliable
service,, 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 of ICL's
intervention in the proceeding is dependant upon the nature and effect of other evidence in this
proceeding. ICL may seek intervenor funding pursuant to IDAPA 31.01.01.161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 30th day ofJanuary 2017.
Respe~bmitted,
~ 6Zc--
Benjamin J. Otto
Idaho Conservation League
!CL'S PETITION TO INTERVENE 2 January 30, 2017
CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of January 2017, 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
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
(Original and seven copies provided)
Electronic Mail:
Idaho Power
Lisa D. Nordstrom
Regulatory Dockets
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
[e-mail]
IIPA
Eric 1. Olsen
Echo hawk & 0 lsen, PLLC
505 Preshing Ave., Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail]
Anthony Y ankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
ICL'S PETITION TO INTERVENE 3
ICIP
Peter J. Richardson
Richardson Adams, PLLC
515 N 27th St.
Boise, ID 83702
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ID 83702
[e-mail]
Benjamin J. Otto
January 30, 2017