20211222Motion to Dismiss.pdf

IPC-E-21-41 ICL Motion to Dismiss December 22, 2021
Benjamin J. Otto (ISB No. 8292)
710 N 6th Street Boise, ID 83701 Ph: [phone] Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
POWER COMPANY’S APPLICATION FOR AUTHORITY TO PROCEED WITH RESOURCE PROCUREMENTS TO MEET IDENTIFIED CAPACITY DEFICIENCIES IN 2023, 2024, AND 2025 TO ENSURE ADEQUATE, RELIABLE, AND FAIR-PRICED
) ) ) )
)
) ) ) )
CASE NO. IPC-E-21-41
IDAHO CONSERVATION LEAGUE
MOTION TO DISMISS
The Idaho Conservation League (ICL) hereby seeks the same relief as requested in the
Motions to Dismiss filed by the Industrial Customers of Idaho Power and IdaHydro. ICL
reviewed both motions. We will not repeat the arguments raised therein. ICL consistently
participates in a variety of Idaho Power process and Commission dockets which provides us the
direct experience to say we support the positions and facts asserted by both of these intervenors.
ICL’s Motion is timely filed by December 22, 2021. IDAPA 31.01.01.256.04 states:
“When a prehearing motion has been filed, all parties seeking similar substantive or procedural
relief must join in the motion or file their own motions within seven (7) days after receiving the
original motion.” ICL received the Industrial Customers of Idaho Power’s Motion to Dismiss on
December 15, 2021.1 This establishes December 22, 2021 as the seventh day after receiving the
original motion where we seek similar relief.
Respectfully submitted this 22nd day of December 2021,
/s/ Benjamin J. Otto Benjamin J. Otto Idaho Conservation League
1 ICL did not receive IdaHydro’s Motion to Dismiss, filed on December 10, 2021, which is no surprise because
IdaHydro appropriately only served the parties to the docket.
RECEIVED
2021 DEC 22 PM 3:58
IDAHO PUBLIC
UTILITIES COMMISSION
IPC-E-21-41 ICL Motion to Dismiss December 22, 2021

CERTIFICATE OF SERVICE I hereby certify that on this 22nd day of December, 2021, I delivered true and correct copies of the foregoing MOTION TO DISMISS to the following persons via the method of
service noted:
/s/ Benjamin J. Otto Benjamin J. Otto Electronic mail only (See Order 35058):

Idaho Public Utilities Commission Jan Noriyuki, Secretary [e-mail]
Idaho Power
Donovan E. Walker Tim Tatum [e-mail] [e-mail]
[e-mail]

IdaHydro C Tom Arkoosh Amber Dresslar [e-mail]
[e-mail] [e-mail] Industrial Customers of Idaho Power
Industrial Customers of Idaho Power
c/o Peter J. Richardson Richardson Adams, PLLC [e-mail]
Dr. Don Reading
[e-mail]