20230222Petition to Intervene.pdf

Marie Callaway Kellner (ISB No. 8470)
710 N 6th Street
PO. Box 844
Boise, ID 83701
[phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPANY’S
APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY
FOR THE BOARDMAN TO
HEMINGWAY 500KV
TRANSMISSION LINE
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CASE NO. IPC-E-23-01
PETITION TO INTERVENE OF
THE IDAHO CONSERVATION
LEAGUE
COMES NOW the Idaho Conservation League (“ICL”) and hereby requests leave to
intervene in the above captioned matter pursuant to the Idaho Public Utilities Commission
(“IPUC”) Rules of Procedure, IDAPA 31.01.01.071-073. As discussed below, ICL has direct and
substantial interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Marie Callaway Kellner
Attorney for the Idaho Conservation League
PO Box 844
710 N. 6th St.
Boise, Idaho 83702
Phone: [phone]
Email:[e-mail]
Please provide copies of all pleadings, production requests, production responses, Commission
orders, and other documents the name and address above. Please provide the same documents to:
RECEIVED
2023 February 22, 4:36PM
IDAHO PUBLIC
UTILITIES COMMISSION
Brad Heusinkveld
Idaho Conservation League, Energy Associate
710 N. 6th St.
PO Box 844
Boise, Idaho 83702
Phone: [phone]
Email:[e-mail]
In the interest of reducing costs to all parties, pleadings, testimony, briefs, production
requests, responses, notices, Commission orders, and other filings may be submitted via
electronic mail in accordance with IPUC Rule 31.01.01.063.02-03. ICL reserves the right to
request hard copies of documents, as may be necessary, with appropriate notice and time.
2. ICL claims a direct and substantial interest in this proceeding on behalf of our members who
are customers of (“Idaho Power” or “Company”). As Idaho’s largest state-based conservation
organization, we have approximately 11,000 members, many of whom are customers of Idaho
Power. ICL represents its organizational interest, the interests of its members generally, and those
who are customers within the Company’s service territory. Additionally, ICL’s Boise office is an
Idaho Power customer. As a result, ICL and its members have a direct and substantial interest in
ensuring that the Company provides fair rates that do not unduly burden customers and those
interested in energy efficiency, conservation, and the environmental impacts of the energy
system. The Commission has consistently granted ICL’s intervention in dockets on similar
grounds. ICL’s intervention will respond directly to the issues raised in this proceeding and will
not unduly broaden the scope of the issues or this proceeding.
3. ICL intends to fully participate in this matter as a party. The nature and quality of ICL’s
intervention in this proceeding is dependent upon the nature and effect of other evidence in this
proceeding. If necessary, ICL may introduce evidence, be heard in argument, and call, examine,
and cross-examine witnesses. If available, ICL intends to seek intervenor funding pursuant to
IDAPA 31.01.01.161-165.
WHEREFORE, the Idaho Conservation League respectfully request the Commission grant
this petition.
DATED this 22d day of February, 2023.
Respectfully submitted,
/s/ Marie Callaway Kellner
Marie Callaway Kellner (ISB No. 8470)
Attorney for Idaho Conservation League
CERTIFICATE OF SERVICE
I hereby certify that on this 22d day of February, 2023, I delivered true and correct copies
of the foregoing PETITION TO INTERVENE to the following persons via email, pursuant to
PUC Order 35058:
/s/ Marie Callaway Kellner
Marie Callaway Kellner (ISB No. 8470)
Attorney for Idaho Conservation League
Idaho Public Utilities Commission:
Jan Noriyuki, Secretary
[e-mail]
IIPA:
Eric L. Olsen
Echo Hawk & Olsen, PLLC
P.O. Box 6119 505 Pershing Ave., Ste. 100
Pocatello, ID 83205
[e-mail]
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]
ICIP:
Peter J. Richardson
Richardson Adams, PLLC
PO Box 7218
515 N. 27th Street
Boise, ID 83701
[e-mail]
Dr. Don Reading
280 South Silverwood Way
Eagle, ID 83616
[e-mail]
City of Boise:
Ed Jewell, Deputy City Attorney
Boise City Attorney’s Office
Wil Gehl, Energy Program Manager
Boise City Dept. of Public Works
P.O. Box 500 150 N. Capitol Blvd.
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Idaho Power Company:
Donovan E. Walker
Tim Tatum
1221 W. Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]