Loading...
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