20180413Petition to Intervene.pdf

Travis Ritchie, CA Bar# 258084 (pro hac vice pending)
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA94612
(4rs) 977-s127
travis.ritchie @ sierraclub. org
IN THE MATTER OF AVISTA
CORPORATION'S APPLICATION TO
CHANGE ITS ELECTRIC AND NATURAL
GAS DEPRECIATION RATES
RTC E IVE D
?il18 APR l3 AH g: I T
oC
SS '11
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
CASE NO. AVU-E- 18-03
AVU-G- 18-02
PETITION TO INTERVENE OF
SIERRA CLUB
Pursuant to IDAPA 31.01.01.071 et seq., and Order No. 34104 issued in the above-
captioned proceeding, Sierra Club hereby submits this petition to intervene on behalf of itself
and its Idaho members who are customers of Avista.
1. The name and address of Sierra Club is:
Sierra Club
2101 Webster Street, Suite 1300
Oakland, CA946l2
(4rs) e17-s727
[e-mail] r
2. Sierra Club is a national, non-profit environmental and conservation organization
incorporated under the laws of the State of California. The Sierra Club is dedicated to the
protection of public health and the environment. Sierra Club petitions to intervene on behalf
of itself and nearly 3,600 Sierra Club members who live and purchase utility services in
Idaho, many of whom are residential customers of Avista.
3. Sierra Club's Idaho members have a direct and substantial interest in this proceeding because
Avista's requested change to depreciation rates for its electric and natural gas assets will
impact their bills. These Sierra Club members have a right to participate in this proceeding to
inform the Commission of their interests, both environmental and economic, that relate to the
impacts of Avista's proposed rates.
ISierra Club's Petition to Intervene
4. 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 addressed in Avista's application.
Specifically, Sierra Club intends to evaluate and address Avista's estimates for the remaining
useful lives of Colstrip Units 3 and 4. Sierra Club notes that the currently applicable
depreciation schedule used by Avista for Colstrip Units 3 and 4 is substantially different than
the depreciation schedule used by several co-owners of Colstrip Units 3 and 4. Sierra Club
intends to explore the basis for this discrepancy and evaluate what actions may be
appropriate to address it. Sierra Club may also address other issues that arise in this
proceeding.
5. Sierra Club requests that all future pleadings, correspondence, discovery, and other
documents be served on the following:
Travis Ritchie,
CA Bar# 258084 Qtro hac vice pending)
Staff Attorney
Sierra Club
2l0l Webster Street, Suite 1300
Oakland, CA9461,2
(4rs) 971-s121
travis. ritchie @ sierraclub. org
WHEREFORE, Sierra Club respectfully requests that the Commission issue an order
granting Sierra Club permission to appear in this matter.
Dated this l2th day of April, 2018.
Respectfully submitted,
Travis Ritchie
Attorney for Sierra Club
2Sierra Club's Petition to Intervene
]
CERTIFICATE OF SERVICE
I hereby certify that on this 12th day of April 2018, I delivered true and correct copies of
the foregoing PETITION TO INTERVENE OF SIERRA CLUB to the following persons via the
method of service noted:
FedEx:
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
421W-WashingtonSt.
Boise,ID 83702-5983
diane.holt @ puc.idaho. gov
(Original and seven copies provided)
Email:
David J. Meyer
Patrick Ehrbar
Avista Corporation
POBox3721
1411 East Mission Avenue
Spokane, WA99220-3127
david. meyer @ avi stacorp.com
Patrick. ehrbar @ avistacorp.com
AvistaDockets @ avistacorp.com
Benjamin I. Otto
Idaho Conservation [rague
710 N. 6'h st.
Boise,Idaho 83702
botto @ idahoconservation. org
Ana
Legal Assistant
Sierra Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA946L2
Phone: [phone]