20240125Petition for Leave to Intervene.pdf

RECEIVED
Wednesday, January 25, 2024 4:25PM
IDAHO PUBLIC
UTILITIES COMMISSION
Eric L. Olsen(ISB#4811)
ECHO HAWK& OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: elo(a)echohawk.com
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION CASE NO. PAC-E-24-02
OF ROCKY MOUNTAIN POWER
REQUESTING APPROVAL FOR PETITION OF IDAHO IRRIGATION
ADJUSTMENTS TO THE IRRIGATION PUMPERS ASSOCIATION,INC.
LOAD CONTROL PROGRAM FOR LEAVE TO INTERVENE
COMES NOW Idaho Irrigation Pumpers Association, Inc.,herein called"this Intervenor,"
and pursuant to Rules 71 through 73 of the Rules of Procedure of the Idaho Public Utility
Commission, and by this Petition asks leave to intervene and to appear and participate as a party
herein, and as basis therefor states as follows:
1) The name and address of Intervenor is:
Idaho Irrigation Pumpers Association, Inc.
c/o Amy McKoon
1222 W. 90 S.
Blackfoot, ID 83221
This Intervenor will be represented by:
Eric L. Olsen
ECHO HAWK& OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
and requests that copies of all pleadings and production requests and responses should be
provided to the following:
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FOR LEAVE TO INTERVENE—Page 1
CASE NO.PAC-E-24-02

Eric L. Olsen
ECHO HAWK& OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: elo(cr�,echohawk.com
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
Email: lancegaegisinsi h
2) This Intervenor and its members have a direct and substantial interest in this
proceeding and intend to participate in all respects herein as a party as may be required to represent
its interests.
3) Without the opportunity to intervene herein, this Intervenor would be without a
manner or means of participating in the lawful determination of issues which will result in affecting
its rates for electric service.
WHEREFORE,this Intervenor requests that this Commission grant this Intervenor's leave
to intervene in these proceedings and to appear and participate in all matters as may be necessary
and appropriate.
DATED this 251h day of January, 2024.
ECHO HAWK& OLSEN
ERIC L. OLSEN
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FOR LEAVE TO INTERVENE—Page 2
CASE NO.PAC-E-24-02

CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 25th day of January, 2024, I served a true, correct and
complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to Intervene
to each of the following method as indicated below:
Jan Noriyuki, Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Hand Delivered
P.O. Box 83720 ❑ Overnight Mail
Boise, ID 83720-0074 ❑ Telecopy(Fax)
[e-mail] og_v ® Electronic Mail (Email)
Mark Alder ❑ U.S. Mail
Michael Snow ❑ Hand Delivered
Pacificorp ❑ Overnight Mail
1407 W. North Temple, Suite 330 ❑ Telecopy(Fax)
Salt Lake City, UT 84116 ® Electronic Mail (Email)
mark.alder@]2acificop2.com
michael.snow(&pacificorp.com
Joseph Dallas ❑ U.S. Mail
Pacificorp ❑ Hand Delivered
825 NE Multnomah, Suite 2000 ❑ Overnight Mail
Portland, OR 97232 ❑ Telecopy(Fax)
joseph.dallas@]2acificorp.com ® Electronic Mail (Email)
Data Request Response Center ❑ U.S. Mail
PacifiCorp ❑ Hand Delivered
825 NE Multnomah, Suite 2000 ❑ Overnight Mail
Portland, OR 97232 ❑ Telecopy(Fax)
[e-mail] ® Electronic Mail (Email)
Lance Kaufman, PH.D. ❑ U.S. Mail
Idaho Irrigation Pumpers Association, Inc. ❑ Hand Delivered
2623 NW Bluebell Place ❑ Overnight Mail
Corvallis, OR 97330 ❑ Telecopy(Fax)
lance@ae isg insi hg t.com ® Electronic Mail (Email)
ERIC L. OLSEN
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.FOR LEAVE TO INTERVENE—Page 3
CASE NO.PAC-E-24-02