20170822Petition to Intervene.pdf

ill[ili::,VF.l)Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, lD 83702
208384-L299
bmpurdv@h otmai!.com
August 22,2OL7
Diane Hanian
Secretary
ldaho Public Utilities Commission
472W. Washington St
Boise, lD 83702
RE: Case No. IPC-E-17-11: LATE FILING OF PETITION TO INTERVENE
Dear Ms Hanian
Enclosed are an originaland seven (7)copies of STOP B2H's Petition to lntervene in the above -
referenced case. Pursuant to Order No. 33827 issued July 31,, 2017, the deadline for filing said
Petition was yesterday, August 2L,2OL7 . The filing is being made today, one day late.
The reasons for the belated filing are that my client was initially uncertain regarding the
requirements and process for obtaining legal counsel eligible to represent them in ldaho.
Consequently, it took my client additional time to find an attorney in ldaho with IPUC
experience and contacted me late Friday afternoon, August L8,2077 at which time I agreed to
take the case. I had previously agreed to participate in assisting with my High School Reunion
which started that evening and was unable to begin work on the intervention pleading until
later Saturday morning, August L9,2OL7. I awoke that morning with what became a fairly
severe lung infection but attempted to meet the deadline anyway.
Due to the above-mentioned factors, coupled with computer/printer problems that arose
shortly prior to today, I was unable to complete and file the Petition until today. I took the
precaution of contacting counsel for ldaho Power and Commission Stafl both of whom stated
that they would have no objection to a late filing of the Petition.
Rather than file a Motion for Late-Filed Petition and supporting Affidavit, I chose to file the
enclosed Petition one day late and spare the Commission's Legal Staff and the Commissioners
themselves from having to review such documents and issue an Order accordingly. Should the
Commission desire such pleadings, I am happy to prepare and file them promptly.
Thank you for your consideration of this filing.
i l ll ,'iI) ll t Pl'i 3: I J
'; I r''i i,
Sincerely,
Brad M. Purdy
/
Brad M. Purdy
Attorney atLavt
ISB Bar No. 3472
2019 N. 17th St.
Boise, lD. 83702
[phone] (Land)
(208) 384-851 I (Fax)
[e-mail]
Attorney for Petitioner
STOP B2H
flr*,-t:l\/EI'\i\,-,. "..r l.- i v L- r
::] i3 Pl{ 3: l6
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2017 INTEGRATED
RESOURCE PLAN.
CASE NO. IPC.E-[7-II
STOP B2H'S PETITION TO
INTERVENE
COMES NOW, STOP B2H ("STOP" or "Intervenor"), by and through its attorney, Brad
M. Purdy and, pursuant to Rules 071-076 of the Commission's Rules of Practice and Procedure,
IDAPA 31.01.01 .071-07 6, hereby petitions the Commission for leave to intervene in this
proceeding, initiated by Idaho Power Company ("Idaho Power" or "Company") on June 30,
2017, and to appear and participate with full party's rights. In support of this Petition, STOP
states as follows:
l. The name and address of the Petitioner, who is currently designated as Jim Kreider is as
follows:
Jim Kreider
STOP B2H
60366 Marvin Rd
La Grande, OR 97850
)
)
)
)
)
)
)
ISTOP BSH'S PETITION TO INTERVENE
2. STOP will be represented in this proceeding by, and pleadings. emails and other
correspondence and communications need only be sent to
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
Email: [e-mail]
3. STOP is a growing alliance of citizen organizations and individuals who are opposed to
the 305 mile Boardman to Hemingway ("B2H") 500kv Transmission line. The majority of
STOP's organizations and individuals are located within sight of the proposed B2H line. The
Alliance also includes Idaho Power ratepayers and Idaho residents. STOP intends to address
concerns that it has regarding the B2H transmission line including whether the B2H project is the
least cost and best resource option available under Idaho Power's IRP and from the perspective
of ratepayers to meet the need claimed by Idaho Power. Specifically, STOP believes that other,
more cost-effective resources exist including, among other things, altemative transmission
opportunities, renewable resources and battery storage and ancillary services. STOP further
contends that the Company should also work more collaboratively with entities engaged in steam
capture and cogeneration.
STOP currently is, and has been, working to: 1) challenge Idaho Power s Integrated
Resource Plan (IRP) conclusion that there is "a need" for additional energy supply in2025 that
can only be met by the construction of B2H, and;2) promote rapid deployment of new
technologies making the need for highly centralized distribution of power, (as well as, coal
generation), obsolete.
2STOP BSH'S PETITION TO INTERVENE
4. Based on the information provided above in accordance with the Commission's rules
of procedure, STOP has a direct and substantial interest in this proceeding and its involvement
would not unduly broaden the scope of this proceeding, as filed.
5) Thus, if granted intervention in this case, STOP will address a variety of issues of
importance to the general body of Idaho Power's ratepayers. STOP respectfully submits that it
would fulfill an important role in this proceeding if given the opportunity to participate as a
party.
STOP respectfully requests the right to participate in this proceeding and introduce
testimony and exhibits, cross-examine other witnesses, engage in oral argument, file comments,
and otherwise fully participate as a party.
WHEREFORE, STOP hereby requests that this Commission grant its Petition to
Intervene in this proceeding and to fully appear and participate as aparty with all the rights and
responsibilities as such.
DATED, this 22nd day of August,2017
Purdy
JSTOP BSH'S PETITION TO INTERVENE
CERTIFICATE OF SERVICE
I, the undersigned, hereby represent that on this 12th day of July,2017,I caused a true and
correct copy of this Petition to Intervene to be served on the following via U.S. Mail, First Class,
Postage Prepaid.
COMMISSION STAFF:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise, ID 83702
[e-mail]. gov
IDAHO POWER COMPANY:
Lisa Nordstrom
Senior Legal Counsel
Idaho Power Company
l22LW.Idaho
Boise, ID 83702
lnordstrom@,idahopower. com
dockets@ idahopower. com
Timothy Tatum
Michael J. Youngblood
Idaho Power Company
l22l W.Idaho St.
Boise, ID 83702
ttatum@idahopower. com
myoun [e-mail]
INDUSTRIAL CUSTOMERS OF IDAHO POWER
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
Richardson & Adams, PLLC
515 N. 27th St.
Boise, ID 83702
Phone: [phone]
Fax: [phone]
peter@ri chardsonadam s. com
4STOP BSH'S PETITION TO INTERVENE
Dr. Don Reading
6070 Hill Rd.
Boise, ID 83703
dreadin g@mindspring. com
SIERRA CLUB:
Gloria D. Smith
2101 Webster St., Ste 1399
Oakland, CA 94612
glori a. sm i th @ si erraclub. or g
MONSANTO:
Randall C. Budge
Thomas J. Budge
Box 1391
2018. Center
Pocatello, ID 83204-l 39 1
[e-mail]
[e-mail]
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]
k i verson@,consultbai.com
James R. Smith
Box 816
Soda Springs, ID 83276
iim.r.smi .com
IDAHYDRO:
C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock St., Ste 900
Boise, ID 83702
tom. arko o sh @, arkoo sh. com
erin.cecil@arkoosh. com
5STOP BSH'S PETITION TO INTERVENE
IDAHO IRRIGATION PUMPERS ASSOCIATION:
Eric L. Olsen
Echo Hawk & Olsen
505 Pershing Ave. Ste. 100
Pocatello, ID 83205
[e-mail]
Anthony Yankell
12700 Lake Ave., Unit 2505
Lakewood, OH 44107
tony@)zankel.net
DATED, this22nd day of August,2017
Brad M. Purdy
6STOP BSH'S PETITION TO INTERVENE