20211117Petition to Intervene.pdf

Rose Monahan, CA Bar No. 329861 Qtro hac vice pending)
Sierra Club
2l0l Webster Street, Suite 1300
Oakland, California 94612
Phone: [phone]
Email : [e-mail]
Attorney for the Sierra Club
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S FILING FOR
ACKNOWLEDGEMENT OF ITS 2O2I
TNTEGRATED RESOURCE PLAN
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CASE NO. PAC.E-21.19
PETITTON TO TNTERVENE OF
SIERRA CLUB
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW the Sierra Club and hereby requests leave to intervene on behalf of itself
and its ldaho members pursuant to the Idaho Public Utilities Commission Rules of Procedure,
IDAPA 31.01.01 .071-073 and OrderNo.35209 issued in the above-captioned matter. As
discussed below, Sierra Club has direct and substantial interests in these proceedings, and
therefore should be granted intervention.
The name and address of Sierra Club's national headquarters is
Sierra Club
2l0l Webster Street, Suite 1300
Oakland, California 94612
(4ts) 977-s704
rose.monahan@sierrac lub.org
2.The Siena Club is a national non-profit environmental and conservation association
incorporated under the laws of the State of Califomia. Sierra Club is dedicated to the
protection of public health and the environment. Sierra Club petitions to intervene in this
proceeding on behalf of over 4,000 members who live and purchase utility services in
PAC-E-21-19
Sierra Club Petition to Intervene I
J
Idaho, many of whom are residential customers of PacifiCorp dba Rocky Mountain
Power ("Company" or "RMP").
Sierra Club's Idaho members have a direct and substantial interest in RMP's Integrated
Resource Plan ("[RP"). Sierra Club has not fully determined the specific positions it will
take or the recommendations it may make to the Commission. Sierra Club seeks to
intervene for purposes of protecting its interests and the interests of its members,
particularly on issues of least-cost, least-risk energy planning and the economic impacts
of the Company's investments in renewable energy and its aging fleet of coal-fired power
plants. Sierra Club plans to evaluate RMP's analyses to ensure that the company is
properly valuing the relative costs and benefits ofenergy resources like coal generation,
nuclear, energy efficiency, and renewables. Sierra Club intends to explore these issues
and others that may arise in the proceeding.
Sierra Club's intervention will not unduly broaden the issues or delay the proceeding
because Sierra Club's interests are directly related to the subjects in the Company's
application for approval of its IRP.
The interests of both the Sierra Club and its members will not be adequately represented
by any other party to this proceeding. To the extent the interests of the Siena Club
overlap with any other party, Sierra Club will coordinate with that party to avoid
duplicative efforts.
Sierra Club requests that copies all future pleadings, production requests, production
responses, Commission orders, and other documents to the names and addresses listed
below.In the interest of conserving natural resources and reducing the costs to all parties,
4.
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6.
PAC-E-21-19
Siena Club Petition to Intervene 2
please provide copies of all documents via electronic mail in accordance with IDAPA
Rules 3 1.01.01.063.02-03.
Rose Monahan
Sierra Club
210l Webster Street, Suite 1300
Oakland, California 9 4612
(4t5) 977-s704
[e-mail]
Ana Boyd
Sierra Club
2l0l Webster St., Suite 1300
Oakland, CA946l2
(4ts)977-s649
ana.bovdr2sierraclub.ors
WIIEREFORE, Sierra Club respectfully requests that the Commission issue an order
granting Sierra Club permission to appear in this matter
DATED this 176 day of November 2021
Rft\,rn,tt^_
Rose Monahan
Sierra Club
PAC-E-21-19
Sierra Club Petition to Intervene 3
I hereby certiff that on this l7s day of November 2O2l,I delivered true and correct
copies of the foregoing PETITION TO INTERVENE OF SIERRA CLUB to the following
persons via the method of service indicated below:rffi
CERTIFICATE OF SERYICE
Ana Boyd
Sierra Club
Electronic mail only (see Order 35058)
Idaho Public Utilities Commission
Jan Noriyuki, Secretary
secretary@Auc. idaho. sov
Rocky Mountain Power
Ted Weston
Emily Wegener
ted.weston(Eoacifi com.com
emily.wegener@pacifi corp.com
datareouest@nacifi com.com
irnrDoacificom.com