20170131Amended Petition 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 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
)
) IDAHO CONSERVATION LEAGUE
)
) AMENDED 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, IDAP A
31.01.01.071-073. As discussed below, ICL has direct and substantial interests in these
proceedings, and therefore should be granted intervention.
ICL acknowledges we file this petition after the intervention deadline ofJanuary 25, 2017
established in Order No 33686. This late filing is due to ICL council's mistake counting the 21-
day intervention period. Allowing this late intervention will not delay the case or prejudice any
party as no further action has occurred other than setting the intervention deadline.
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]
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.
ICL'S AMENDED PETITION TO INTERVENE
January 31 , 2017
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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 of Idaho 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 an affordable, reliable, and timely transition
away from fossil fueled electricity to meet our supporters' desire to protect Idaho's air quality and
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 31st day ofJanuary 2017.
Respectfully submitted, ~~
Benjamin J. Otto
Idaho Conservation League
ICL'S AMENDED PETITION TO INTERVENE
January 31, 2017
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CERTIFICATE OF SERVICE
I hereby certify that on this 31st day of January 2017, I delivered true and correct copies of
the foregoing AMENDED 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
Echohawk & 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 AMENDED PETITION TO INTERVENE
January 31, 201 7
ICIP
Peter J. Richardson
Richardson Adams, PLLC
515 N 271h St.
Boise, ID 83702
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise, ID 83702
[e-mail]
Benjamin J. Otto
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