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Home My WebLink About20220211Petition to Intervene.pdfJack Van Valkenburgh (lSB#: 3818) Van Valkenburgh Law, PLLC P.O. Box 531 Boise,lD,83701 (208) 918-1994 iack@vanva lkenbu reh law.com Attorney for petitioner STOP B2H Coalition . .,'.i:i\/rrr ,.,,'i IIi i ! PH !: fiE i;rlli-it BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR AUTHOR]TY TO PROCEED WITH RESOURCE PROCUREMENTS TO MEET IDENTIFIED CAPACITY DEFICIENCIES IN 2023, 2024, AND 2025 TO ENSURE ADEQUATE, RELIABLE, AND FAIR.PRlCED SERVICE TO ITS CUSTOMERS ) ) ) cAsE NO. |PC-E-21-41 ) ) sToP B2H COALTT|ON PETITION ) TO TNTERVTNE COMES NOW, the STOP B2H COALITION ("STOP" or "lnteryenor"), by and through its attorney, Jack Van Valkenburgh and, pursuant to the ldaho Public Utilities Commission Rules of Procedure, IDAPA 31.01.01.071-073, hereby petitions the Commission for leave to intervene and to appear and participate as a party, and as grounds therefore states as follows: 1) The name and address of the intervener is: Jim Kreider STOP B2H Coalition 60365 Marvin Rd La Grande, OR 97850 54t-406-O727 iim@stoob2h.ors 2l STOP will be represented in this proceeding by: Jack Van Valkenburgh Van Valkenburgh Law, PLLC P.O. Box 531 Boise, 1D,83701 (208) e18-1994 iack@va nvalkenbu rehlaw.com Please provide copies of all pleadings, production requests, production responses, Commission orders, and other documents to the names and addresses above. Electronic copies are preferred. 3) STOP is a growing alliance of citizen organizations and individuals who are opposed to the 305 mile Boardman to Hemingway ("B2H") 500kv Transmission line. We have an estimated 900 individual members, many ldaho Power customers in the Oregon service area, and 7 organizational members. Our purpose is to insure the accuracy of the information presented in support of this facility by all parties involved and provide alternatives to the construction of this 305 mib transmission line through Eastern Oregon and Western ldaho, to wit: fact checking the applicants STOP B2H Coalitions Petition to lntervene CASE NO. IPC-E-21-41 Page 1 of 4 information; offering alternative ideas and ways of thinking; representing the public of Oregon, specifically Eastern Oregon as we are doing in 202L-22 and did in 2019, 20L7 and 2015; protecting environmental, historicaland cultural resources; ensuring the health, safety, social, and economic well being of our region, preventing the degradation of agricultural, timber, range and other land assets; promoting energy conservation; and supporting the rapid development of new technologies in energy generation, storage and distribution throughout Eastern Oregon, the Mid - C trading HUB and the country. 4) Based on the information provided above in accordance with the Commission's rules of procedure, STOP has a direct and substantial interest in this proceeding and its involvement would not unduly broaden the scope of this proceeding, as filed. STOP's direct interests are the impacts this proceeding will have on the B2H. The annihilation of the competitive bidding process will have an impact on the permitting and construction of the B2H thus impacting 5 counties in eastern Oregon 2 with ldaho Power customers. There is substantial information in ldaho Powers 2021 IRP that will inform resource procurements into the future with what could be a permanent reguest for a waiver of the Oregon Public Utilities Resource Procurement Rules. The request for the elimination of Oregon Public Utilities Resource Procurement Rules disregards the need for transparency and erodes public trust in the process. A fair and competitive process could allow these resources to be built in ldaho as proposed and they could eliminate the "need" for the 82H. STOP has argued consistently that building renewables in ldaho will create the energy needed, produce jobs for ldahoans, and collect revenues for the state. Additionally ldaho Power contractual terms give them a clear advantage over the contractor with the ability to change the evaluation/contracting process at what seems to be any point in time up to the signing of a contract. To accept on face value the need for approximately 1,400 MW of new resources by 2026 when the 2019 IRP had a need of approximately 6 MW is a significant and costly change in the short term plan of action to ratepayers. ldaho Power seems to be saying trust us, we know what is best for you. Trust but verify! There is a process that the commission is charged with to ensure that a regulated monopoly cannot use it market position to unduly advantage itself. ldaho Powe/s forceful promotion of the advantages of the old vertically integrated model is concerning. lt appears that they want to turn back the clock of time and not deal with any competition or oversight moving into the future. 5) Thus, if granted intervention status in this case, STOP will address a variety of issues of importance to the general body of ldaho Power's ratepayers. STOP respectfully submits that it will serve an important role in this proceeding if given the opportunity to participate as a party. Without being granted party status, STOP's ability to fully participate in the proceeding will be compromised STOP B2H Coalitions Petition to Intervene cAsE NO. tPC-E-zL-4t Page2ot 4 STOP respectfully requests the right to participate in this proceeding and introduce testimony and exhibits, cross- examine witnesses, engage in oral argument file comments, and othenl/ise fully participate as a party. STOP may seek intervenor funding pursuant to IDAPA 31.01.01.151-155. WHEREFORE, STOP hereby requests that this Commission grant its Petition to lntervene in this proceeding and to fully appear and participate as a party with allthe rights and responsibilities as such. DATED, this 11th day of February 2022. Respectfully submitted, lsl Jock Von Volkenburoh Jack Van Valkenburgh Van Valkenburgh Law, PLLC lsl lim Kreider Jim Kreider STOP B2H Coalition STOP B2H Coalitions Petition to lntervene cAsE NO. rPC-E-21-41 Page 3 of 4 CERTIFICATE OF SERYICE I HEREBY certiry that I have on this 11th day of February 2022, served the foregoing Petition to lntervene by electronic mailto the following: Electronic mail only (See Order 35058): ldaho Public Utilities Commission Jan Noriyuki Commission Secretary P.O. Box 83720 Boise,lD 83720-0074 ian. norivu ki@ puc.idaho.eov John R. Hammond Deputy Attorney General ldaho Public Utilitles Commission P.O. Box 83720 Boise,lD 83720-0074 iohn. hammond@ puc.idaho.eov ldaho Power Donovan Walker Tim Tatum Regulatory Dockets PO Box 70 Boise,lD 83707-OO7O dwalker@ idahopower.com ttatum @ idahopower.com dockets@ ida hooower.com ldaHydro Tom Arkoosh Amber Dresslar Arkoosh Law Offices 913 W. River Street, Ste 450 PO Box 2900 Boise,lD 83701 tom.arkoosh@arkoosh.com amber.dresslar@arkoosh.com erin.cecil@arkoosh.com lndustrial Customers of ldaho Power PeterJ. Richardson Richardson Adams, PLLC 515 N.27th Steet PO Box 7218 Boise, TD 83702 oeter@ richa rdsonadams.com Dr. Don Reading 6070 HillRoad Boise, lD 83703 dreading@m indsprins.com ldaho Conservation League Benjamin J. Otto Emma E. Sperry lda ho Conservation League 710 N. 5th Street Boise,lD 83702 botto@ ida hoconservation.ors es oe rrv@ ida I roconservation. o rg /s/ Jock Von Volkenburoh Jack Van Valkenburgh STOP 82H Coalitions Petition to lntervene cAsE NO. tPC-E-21-41 Page 4 of4