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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