20170906Petition to Intervene.pdf

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; i'i ,l .: i'/ i: nKelsey Jae Nunez,lSB No.7899
KELSEY JAE NUNEZ LLC
920 N. Clover Dr.
Boise,ID 83703
Telephone: [phone]
kelsey @ kel seyjaenune z.com
Attorney for Sierra Club
Zack Waterman
IDAHO SIERRA CLUB
503 W Franklin St
Boise, lD 83702
Telephone: [phone]
zack.waterman @ sierracl ub.org
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR AUTHORITY )
TO ESTABLISH NEW SCHEDULES FOR RESIDENTIAL )
AND SMALL GENERAL SERVICE CUSTOMERS WITH )
oN-stTE GENERATTON )
IPC-E-17-13
PETITION TO INTERVENE OF SIERRA CLUB
Pursuant to IDAPA 3l .01 .01 .042, Sierra Club hereby submits this petition to intervene in
the above captioned matter.
l. The name and address for Sierra Club is:
Sierra Club
Attn: Zack Waterman
503 W Franklin St
Boise, lD 83702
2. 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 3 200 members who live and
purchase utility services in Idaho,and many of those Sierra Club members are
customers of ldaho Power.
3. Sierra Club's Idaho members have a direct and substantial interest in this
proceeding. Sierra CIub'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
Intervention- IPC-E- l7- l3
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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 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 in Idaho.
4. 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
this proceeding because no other party adequately represents Sierra Club's
interests.
5. Sierra CIub requests that all future pleadings, correspondence, discovery, and
other documents should be provided to Kelsey Nunez andZack Waterman to the
addresses stated above as well as to Michael Heckler.
Michael Heckler
3606 N Prospect Way
Garden City,lD 83714
michael.o.heckler@ smai I .com
WHEREFORE, Sierra Club respectfully requests that the Commission issue an order
granting Sierra Club permission to intervene in this matter.
Dated this 6th day of September,2017.
Respectfully submitted,
Jae N
Attorney for S Club
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t
CERTIFICATE OF SERVICE
I hereby certify that on this 6'h day of September,2OlT,true and correct copies of the
above PETITION TO INTERVENE OF SIERRA CLUB were sent to the following
persons via the methods noted:
Hand delivered and emailed:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise, lD 83702
diane.holt@ puc.idaho.gov
(original plus seven copies)
Emailed:
Lisa D. Nordstrom
Timothy E. Tatum
Connie Aschenbrenner
Idaho Power Company
l22l W.ldaho St.
PO Box 70
Boise,ldaho 83707
lnordstrom @ idahopower.com
dockets @ idahopower.com
ttatum @ idahopower.com
cashenbrenner@ idahopower.com
Idahydro clo C. Tom Arkoosh
Arkoosh Law Offices
802 W. Bannock Street, Suite 900
PO Box 2900
Boise,lD 83701
tom.arkoosh @ arkoosh.com
erin.cecil @ arkoosh.com
Matthew A. Nykiel
Idaho Conservation League
PO Box 2309
102 S. Euclid #207
Sandpoint, ID 83864
mnykiel @ idahoconversation.org
Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
PO Box 6l l9
Pocatello,ldaho 83205
[e-mail]
Anthony Yankel
12100 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
vd It"na
Kelsey Jae
Attorney Club
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