HomeMy WebLinkAbout20220211Petition to Intervene.pdfJack Van Valkenburgh (lSB#: 3818)
Van Valkenburgh Law, PLLC
P.O. Box 531
Boise, 1D,83701
(208) e18-1e94
iack@va nva lkenbu rgh law.com
Attorney for petitioner STOP B2H Coalition
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 2021 INTEGRATED RESOURCE PLAN.
) cAsE NO. !PC-E-21-43
) sToP B2H COALTTTON PET|TTON
) TO TNTERVTNE
COMES NOW, the STOP B2H COALITION ("STOP" or "lntervenor"), 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 part% 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
54L-406-O727
iim@stopb2h.orR
2l STOP will be represented in this proceeding by:
Jack Van Valkenburgh
Van Valkenburgh Law, PLLC
P.O. Box 531
Boise,lD,83701
(208) s18-1994
iack@va nva lken bu rghlaw.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 ("82H") 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
STOP B2H Coalitions Petition to lntervene CASE NO. IPC-E-21-43 Page 1 of 3
information presented in support of this facility by all parties involved and provide alternatives to the construction
of this 305 mile transmission line through Eastern Oregon and Western ldaho, to wit: fact checking the applicants
information; offering alternative ideas and ways of thinking; representing the public of Oregon, specifically Eastern
Oregon as we are doing in 2O2t-22 by attending monthly IRPAC meetings and did in the 2OL9,2OL7 and 2015 IRP's;
protecting environmental, historical and 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.
4l 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.
5) Thus, if granted intervention 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 willserve an important role in this proceeding if given
the opportunity to participate as a party.
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 othenrise fully participate as a party. STOP may seek
intervenor funding pursuant to IDAPA 31.01.01.151-165.
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
Res pectfu lly su bm itted,
/s tock Van Volkenburoh
Jack Van Valkenburgh
Van Valkenburgh Law, PLLC
/st lim Kreider
Jim Kreider
STOP B2H Coalition
STOP B2H Coalitions Petition to lntervene CASE NO. |PC-E-21-43 Page 2 of 3
CERT!FICATE OF SERYICE
I HEREBY certify that I have on this 11th day of February 2022, sewed the foregoing Petition to lntervene by electronic
mailto the following:
Electronic mailonly (See Order 35058):
Jan Noriyuki
Commission Secretary
ldaho Public Utilities Commission
P,O. Box 83720
Boise,lD 83720-0074
ian.norivuki@puc. idaho.gov
John R. Hammond
Riley Newton
Deputy Attorney Genera I
ldaho Public Utilities Commission
P.O. Box 83720
Boise,lD 8372O-OO74
iohn. hammond@ puc.idaho.gov
rilev.newton@ouc.idaho.qov
ldaho Power
Donovan Walker
Tim Tatum
Alison Williams
Regulatory Dockets
PO Box 70
Boise,lD 83707-0070
dwa I ker@ ida hopower.com
ttatu m @ ida hopower.com
awilliams@idahooower.com
dockets@ ida hopower.com
lndustrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Steet
PO Box 7218
Boise, TD 83702
oeter@ richa rdsonada ms.com
Dr. Don Reading
5070 HillRoad
Boise, lD 83703
dreading@mindspring.com
Kiki Leslie A. Tidwell, pro se
ktidwell2022@email.com
lda ho Conservation League
Benjamin J. Otto
Emma E. Sperry
ldaho Conservation League
710 N. 5th Street
Boise,lD 83702
botto@ idahoconservation.org
es pe rrv@ ida I roconse rvation. org
/s tock Von Volkenburah
Jack Van Valkenburgh
STOP B2H Coalitions Petition to lntervene CASE NO. tPC-E-21-43 Page 3 of 3