20170808Petition to Intervene.pdf

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Gloria D. Smith, CA Bar No. 200824 (pro hac vice pending)
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA94612
(41s) 977-ss32
[e-mail]
IN THE MATTER OF IDAHO POWER
COMPANY'S 2OI7 INTEGRATED
RESOURCE PLAN
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-17-11
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PETITION TO INTERVENE OF
SIERRA CLUB
Pursuantto OrderNo.33827, and IDAPA 31.01.01.071 et seq.,Siera Club hereby
submits this petition to intervene on behalf of itself and its Idaho members who are customers of
Idaho Power Company ("company").
1. The name and address of Sierra Club is:
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA94612
(4ts) 977-ss32
[e-mail]
2. Sierra Club is a national, non-profit environmental and conservation organization
incorporated under the laws of the State of California. The Sierra Club is dedicated to the
protection of public health and the environment. Sierra Club petitions to intervene on behalf
of itself and over 3,400 Sierra Club members who live and purchase utility services in Idaho,
many of whom are residential customers of Idaho Power Company.
3. Sierra Club's Idaho members have a direct and substantial interest in this proceeding because
the company's IRP must identify all existing power supply resources and ensure the selected
resource portfolio balances cost, risk, and environmental concerns. Under Idaho Power
Company's 4-year action plan, the company seeks, among other things, to transition from
coal-fired generation overthe next l5 years. Sierra Club is particularly interested in whether
continued operation of the Jim Bridger coal plant in Wyoming is currently a cost-effective
resource for customers. More broadly, Sierra Club's members have an interest in ensuring
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that the company's future "resource menu" not only meets load but ensures cleaner, more
cost-effective resources that protect customer rates and reduce risk.
4. Sierra Club's intervention will not unduly broaden the issues or delay the proceeding because
Sierra Club's interests are directly related to the subjects addressed in the company's filed
IRP, i.e. an affordable, clean and cost-effective 20-year resource plan.
5. Sierra Club requests that all future pleadings, correspondence, discovery, and other
'documents be served on the following:
Gloria D. Smith
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA94612
(4ts) e77-ss32
[e-mail]
6. Sierra Club is in the process of associating with local counsel and will separately file a
motion for Ms. Smith to appear pro hac vice. Sierra Club requests that the Commission
conditionally grant this petition pending Sierra Club compliance with Rule 43.03 and Idaho
Bar Commission Prule 227.
WHEREFORE, Sierra Club respectfully requests that the Commission issue an order
granting Sierra Club permission to appear in this matter.
Dated this 7th day of August, 2017
Respectful ly submitted,
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Gloria D. Smith
Attorney for Sierra C lub
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CERTIFICATE OF SERVICE
I hereby certify that on this 7th day of August 2017, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE OF SIERRA CLUB to the following persons via the
method of service noted:
FedEx:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
diane.holt@puc. idaho.gov
(Original and seven copies provided)
Email:
Lisa D. Nordstrom
Timothy E. Tatum
MichaelJ. Youngblood
Idaho Power Company
1221 West Idaho Street (83702)
PO Box 70
Boise,ldaho 83707
lnordstrom @ idahopower.com
[e-mail]
[e-mail]
dockets@ idahopower.com
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dr eading@m i ndspri ng. com
Peter J. Richardson
Richardson Adams PLLC
PO Box 721 8
Boise. lD 83702
[e-mail]
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Alexa Zimbali{t
Legal Assistant
Sierra Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA94612
Phone: [phone]