HomeMy WebLinkAbout20210714Petition to Intervene.pdfRose Monahan, CA Bar No. 329861 Qtro hac uice pending)
Siena Club
210l Webster Street, Suite 1300
Oakland, California 9 4612
Phone: (415) 977-5704
Email : rose.monah an@sienaclub.org
Attorneyfor the Sierro Club
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER POWER PLANT
i+ FFi 5:*t
i :.'\
., -:-.i.".111!,'r'l ',r'-1..:,,i;:'j
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-21-17
PETITION TO INTERVENE OF
SIERRA CLUB
COMES NOW the Sierra Club and hereby requests leave to intervene in the above
captioned matter pursuant to the Idaho Public Utilities Commission Rules of Procedure, IDAPA
3 I .01 .01 .07 l-073 . As discussed below, Sierra Club has direct and substantial interests in these
proceedings, and therefore should be granted intervention.
1. The name and address of Sierra Club's national headquarters is:
Sierra Club
2101 Webster Street, Suite 1300
Oakland, California 94612
(41s) e77-s704
rose.monahan@ sierraclub. org
The Sierra Club is a national non-profit environmental and conservation association
incorporated under the laws of the State of California. Sierra Club is dedicated to the
protection of public health and the environment. Sierra Club petitions to intervene in this
proceeding on behalf of its nearly 3,750 members who live and purchase utility services
IPC-E-2I-17
Sierra Club Petition to Intervene
2
J
in Idaho, many of whom are residential customers of ldaho Power Company. Sierra Club
claims a direct and substantial interest in this proceeding on behalf of our members who
are customers of Idaho Power Company because the outcome will impact customer rates.
Sierra Club will respond to Idaho Power Company's request to increase its rates to
recover costs associated with the Jim Bridger Power Plant, and thus will not unduly
broaden the issues or prejudice any party to this case.
Sierra Club, in its capacity as a representative of its Idaho members, intends to participate
herein as a party, and, if necessary, to introduce evidence, cross-examine witnesses, call
and examine witnesses, and be heard in argument. Without the opportunity to intervene
herein, Sierra Club would be without any means of participating in this proceeding,
which may have a material impact on the rates its members pay for electric service.
Sierra Club requests that copies all future pleadings, production requests, production
responses, Commission orders, and other documents to the names and addresses listed
below. In the interest of conserving natural resources and reducing the costs to all parties,
please provide copies of all documents via electronic mail in accordance with IDAPA
Rules 3 1.01.01.063.02-03.
4.
Rose Monahan
Sierra Club
2101 Webster Street, Suite 1300
Oakland, Califomia 94612
(4ts) e77-s704
rose.monahan@ sierraclub. org
Ana Boyd
Siena Club
2101 Webster St., Suite 1300
Oakland, CA946I2
(4ts) 977-s649
ana.bovd@.sierraclub .org
WHEREFORE, Sierra Club respectfully requests that this Commission grant its Petition
to Intervene in these proceedings and to appear and participate in all matters as may be necessary
rPC-E-z1-17
Sierra Club Petition to Intervene 2
and appropriatc; and to present evidence, call md examine witnesses, prcsent argument, and to
otherwise fully participate in these proceedings.
DATED this 14fr day of July 2021
lr"Vi\-rtN^h^-
Rose Monahan
Sierra Club
IPC-E 2t-17
Sierra Club Petition to Interveme 3
CERTIFICATE OF SERVICE
I hereby certi$ that on this 14tr day ofJuly 2021, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
indicated below:
Ana Boyd
Sierra Club
Electronic mail only (See Order 35058)
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
secretary@Fuc. idaho. gov
Karl Klein
karl.klein@ouc. idaho. gov
Idaho Power Company
Lisa D. Nordstrom
Matt Larkin
lnordstrom@idahopower.com
mlarkin@ idatropower. com
dockets@i dahopower. com
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
peter@richardsonadams. com
Dr. Don Reading
dreadin g@mindspring. com
Idaho C onservation League
Benjamin J. Otto
botto@idahoconservation. org
City of Boise
Ed Jewell
BoiseCityAttomey@ citvofboise.org
ej ewell @cit]rofboise. org