20210521Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6ft Street
Boise, ID 83701
Ph: (208) 34s-6933 x ll2
Fax: [phone]
botto@idahoconservation. org
IN THE MATTER OF IDAHO
POWER COMPAIYY'S
APPLICATION FOR A
DETERMINATION
ACKNOWLEDGING ITS NORTH
VALMY POWER PLANT EXIT
DATE
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ira:i a'Li'- i, )^*.71\:
Attorney for the ldaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E-2I-I2
PETITION TO INTERVENE OF THE
IDAHO CONSERVATION LEAGUE
COMES NOW the Idaho Conservation League ("ICL") and hereby requests leave to
intervene in the above captioned matter pursuant to the Idaho Public Utilities Commission Rules
of Procedure, IDAPA 31.01.01 .071-073. As discussed below, ICL has direct and substantial
interests in these proceedings, and therefore should be granted intervention.
l. The name of this intervenor is
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise,Idaho 83702
Ph: [phone] x ll2
Fax: [phone]
botto@idahoconservation. org
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the name and address above. In the interest of
conserving natural resources and reducing the costs to all parties, please provide hard copies of
pleadings, testimony, and briefs only. Production requests, responses, notices, Commission
orders, and other filings may be submitted via electronic mail in accordance with IPUC Rules
31.01.01 .063.02-03.
ICL PETITION TO INTERVENE
2. Idaho Conservation League claims a direct and substantial interest in this proceeding
as a customer and on behalf of our members who are customers of ldaho Power. As ldaho's
largest state-based conservation organization, we have approximately 11,000 members most of
whom are residential customers of Idaho Power. ICL's Boise headquarters is a Schedule 9 Idaho
Power customer and our Ketchum field office is a Schedule 7 customer. ICL has sought the
optimal date for Idaho Power to exit Valmy for many years as a member of the Integrated
Resource Plan Advisory Committee and aparty to the Settlement in IPC-E-16-24 that lead to
Idaho Power's North Valmy Framework Agreement. ICL intervention here will respond to Idaho
Power's proposal and analysis in this Application and thus will not unduly broaden the issues.
3. ICL intends to fully participate in this maffer 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. If necessary ICL may introduce evidence, be heard in argument, and call,
examine, and cross-examine witnesses. ICL intends to seek intervenor funding pursuant to
IDAPA 3 1.01.01. 161-165.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 21st day of May 2021.
Respectfully submitted,
/s/ Beniamin J Otto
Idaho Conservation League
TCL PETITION TO INTERVENE 2
CERTIFICATE OX' SERYICE
I hereby certiff that on this 2lst day of May 2021,I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
/s/ Beniamin J Otto
Idaho Conservation League
Electronic mail only (See Order 34781):
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
secretary@puc. idaho. gov
Idaho Power
Lisa D. Nordstrom
Matt Larkin
lnordstrom@idahopower. com
mlarkin@idahopower. com
dockets@idahopower. com
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@ichardsonadams. com
Dr. Don Reading
dreading@mindspring. com
3ICL PETITION TO INTERVENE